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SR 06-21-2022 8B City Council Report City Council Meeting: June 21, 2022 Agenda Item: 8.B 1 of 8 To: Mayor and City Council From: David Martin, Director, Administration Subject: Housing Element Draft Redline Revisions Recommended Action Staff recommends that the City Council direct staff to transmit draft redline revisions to the adopted 6th Cycle (2021-2029) Housing Element Update to the California Department of Housing and Community Development for review and comment. Summary On February 8, 2022, the California Department of Housing and Community Development (“HCD”) determined that although Santa Monica’s adopted 6th Cycle (2021-2029) Housing Element Update meets many statutory requirements, further revision is necessary in order to comply with all aspects of State Housing Element law (Attachment A). Because Santa Monica did not adopt an HCD-certified Housing Element by October 15, 2021 or within the additional 120-day period (i.e. February 12, 2022), Santa Monica was formally deemed out of compliance for the 6th Cycle Housing Element. Since receipt of the letter, staff has had consultations with HCD staff regarding revisions to the Housing Element to address HCD’s comments. On April 26, 2022, staff provided a progress update to the City Council on consultations with HCD. On June 15, 2022, the Planning Commission provided a recommendation to the City Council on the draft redline revisions, which is summarized in the Background section of this report. 8.B Packet Pg. 46 2 of 8 This report presents draft redline revisions to all of HCD’s comments on the Housing Element as shown in the attached table (Attachment B). City staff’s draft redline revisions (Attachments C-F) have been viewed by HCD staff who have preliminarily provided generally favorable feedback on City staff’s approach to addressing the comment, subject to full review and public comment once draft redline revisions are submitted to HCD. Upon City Council’s direction, these redline revisions to the Housing Element will be transmitted to HCD with a goal to receive HCD’s approval of draft revisions before formal adoption of a revised Housing Element in the Fall, when additional environmental analysis is complete. Past Council Actions Below are past Council actions related to the 6th Cycle Housing Element process. Date Description 10/12/2021 City Council adopted the 6th Cycle 2021-2029 Housing Element. The adopted Final Housing Element was transmitted to HCD for their 90- day review period for certification. 3/15/2022 City Council held SB9 Study Session and gave direction to staff 4/26/22 City Council received progress update on potential revisions to Housing Element as a result of consultations with HCD staff Background On February 2, 2022, pending completion of HCD’s review, the Planning Commission reviewed the first phase of implementation of priority housing programs per the schedule in the adopted 6th Cycle Housing Element. The first phase of implementation included proposed amendments to the Land Use and Circulation Element (LUCE}, Bergamot Area Plan, Downtown Community Plan, and the Zoning Ordinance for consistency with the Housing Element. 8.B Packet Pg. 47 3 of 8 Planning Commission Recommendation on Draft Redline Revisions On June 15, 2022, the Planning Commission voted 5-2 to recommend that the City Council direct staff to transmit draft redline revisions to the Housing Element with the following changes: • Mixed Use Creative zone south of Expo Bike Path and north of Pennsylvania Avenue (between Stewart St and Stanford St) - 3.25 FAR and 70 feet • Add language to Programs 2E, 2F, and 6C indicating the City’s past and future commitment to support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing. The Planning Commission’s recommendation has been incorporated into the draft redline revisions. Discussion The redline revisions are grouped into three main categories and the below provides a brief summary: • Technical Revisions – Suitable Sites Inventory, Constraints Analysis • Affirmatively Furthering Fair Housing o Housing preservation programs o Rezoning in commercial districts o R1 zone metrics and monitoring • City-owned Sites Technical Revisions The proposed redline revisions are technical in nature and primarily address HCD’s comments on assumptions used in the Suitable Sites Inventory that are the basis for calculating overall capacity. As previously explained at the April 26, 2022 City Council meeting, the overall housing capacity analyzed in the Housing Element has increased to over 13,000 units in order to address HCD’s technical comments. The revisions also address HCD’s comments on the constraints analysis on such issues as emergency shelters, fees, and Accessible Dwelling Units (ADUs). 8.B Packet Pg. 48 4 of 8 Affirmatively Furthering Fair Housing (AFFH) The proposed redline revisions address HCD’s comments on AFFH and as noted above, focus on three general areas: • Housing preservation programs – City staff clarified for HCD staff that Santa Monica’s fair housing strategy leads first and foremost with housing preservation. The City’s long record of rent control, tenant protection policies, use of the City’s housing trust funds to provide loans for substantial rehabilitation of existing buildings with low-income tenants, and programs to assist vulnerable households most at-risk of displacement are evident in the list of housing programs in Chapter 5. Revisions focused on adding program background, clarifying geographic targeting, and adding metrics where available. • Distribution of housing capacity throughout the city – Given Santa Monica’s relative homogeneity as a highest/high resource city, HCD placed a greater emphasis on reviewing local data and factors. This means that Santa Monica’s AFFH strategy is different compared to other cities with significant demographic and socioeconomic disparities between census tracts. HCD staff did not have objection to the strategy to distribute housing capacity throughout the city. The draft redline revisions include floor area ratio (FAR) and corresponding building height increases largely in commercial boulevards north of the I-10 freeway (Wilshire, Santa Monica Boulevard, Broadway, Colorado, Olympic), Bergamot, and Downtown in exchange for lesser development standards in Pico neighborhood and neighborhood commercial areas such as Montana Avenue, Main Street, and Ocean Park Boulevard. • R1 zone metrics and monitoring – HCD staff clarified that in order to address comments, appropriate metrics would need to be added to demonstrate commitment to increasing housing choice and type in R1 zones. In addition to the existing program to incentivize additional ADUs, two new programs (4E and 4F) have been added to incentivize SB9 units, particularly on larger parcels, and 8.B Packet Pg. 49 5 of 8 also add a target to issue building permits for 47 additional housing units per year in the R1 zones coupled with mid-cycle monitoring to assess progress. City-Owned Sites HCD staff clarified that a more explicit explanation of the City’s commitments to offer City-owned sites for affordable housing would need to be provided, and the draft redline revisions in Program 2E reflect changes necessary to address HCD’s comments. The Housing element identifies five City-owned sites to meet the City’s lower income targets in the RHNA. Program 2E indicates that 1,880 affordable housing units can be accommodated on City-owned sites as shown in the following table: Sites Unit Capacity Constraints Parking Structure 3 (pending project) 104 None Wilshire Parking Lots (3 sites) 130 None 4th/Arizona 362 Bank leases don’t terminate until 2026 Bergamot Arts Center 707 Property management agreement until April 2027. Annual leases with 30 businesses that renew each calendar year until redevelopment Main Street Parking Lots 577 None but replacement parking will be necessary (Coastal Zone) Total 1,880 The City-owned sites are also being relied upon to address the lower-income shortfall – a statutory requirement in Housing Element where the City must calculate the difference in lower-income affordable housing capacity between existing zoning standards and the lower-income RHNA allocation. The lower-income shortfall has been calculated to be 1,433 lower-income units and thus the 1,880 affordable units that could be accommodated on City-owned sites would cover that shortfall. Government Code Section 65583.2(h) and (i) require that identified land must allow 100% residential use and can only be redeveloped with a minimum 50% residential floor area in mixed-use 8.B Packet Pg. 50 6 of 8 projects (i.e. 100% commercial projects would be prohibited). The City has the greatest amount of control over city-owned sites, particularly in terms of being able to impose a minimum requirement for residential uses and thus, Program 1K states that City-owned sites are addressing the lower-income shortfall. Next Steps As explained in the April 26, 2022 Council report providing a progress update on HCD consultations in addition to a summary table of consequences of being out of compliance, October 15, 2022 is the next consequential milestone in Housing Element law as it is the date by which the City must rezone to accommodate the RHNA allocation. As also explained in the April 26, 2022 Council report, the consequences for jurisdictions that have failed to adopt a housing element that has been found by HCD to be in substantial compliance include the following: 1. Denial of state funding where eligibility is contingent upon a housing element that has been found by HCD to be in substantial compliance. Gov’t Code § 65589.11 2. Required by-right approval of housing development projects with at least 20% of units affordable to 60% AMI households or 100% Moderate, even if the project exceeds zoning or general plan maximums. Any conditions placed on such projects cannot render the project infeasible. Gov’t Code § 65589.5(d)(1) & (5)(B) 3. By-right approval of housing developments that comply with standards listed in the housing programs for rezoning and for which 49% of the housing units are affordable for very low, low-, and moderate-income households proposed on a site required to be rezoned. Gov’t Code § 65583(g) 4. Legal action by any interested party to enforce programs of the housing element authorized under Code of Civil Procedure § 1085. Gov’t Code §§ 65583(h), 65587(b) 5. HCD notification to the Attorney General and potential judicial action to force substantial compliance plus fines in the amount of $10,000 per month, not to 8.B Packet Pg. 51 7 of 8 exceed $100,000 per month, plus continuing court jurisdiction. Gov’t Code § 65583(j, k, l) If Council directs staff to transmit the draft redline revisions to HCD, HCD would have up to 60 days to review the draft redlines and provide written comments to the City. As noted in this report, staff’s goal is to receive a “draft in compliance” letter from HCD on the attached draft redlines, which would provide a path forward for the City Council to adopt a revised compliant Housing Element. However, the primary schedule driver for Council to adopt a revised compliant Housing Element is the preparation of additional environmental analysis, which is not anticipated to be complete until September. The following represents a potential schedule for next steps through the Fall should HCD determine that the draft redlines are in compliance with Housing Element law: • July 2022 – transmit draft redline revisions to HCD • July-September 2022 – HCD timeframe to provide written comments on draft redline revisions. Additional environmental analysis underway. Should HCD letter on draft redline revisions be received relatively quickly, staff could return to working on Housing Element first phase implementation (i.e., zoning changes) that was underway with Planning Commission in February 2022. • September/before October 15, 2022 – Council adopts both Housing Element and first phase implementation together (i.e., zoning changes) Financial Impacts and Budget Actions There is no immediate financial impact or budget action necessary as a result of the recommended action. 8.B Packet Pg. 52 8 of 8 Prepared By: Jing Yeo, Planning Manager Approved Forwarded to Council Attachments: A. HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 B. Attachment B - Summary of City Responses to HCD Comments C. Housing Element (Chapters 1-5) Redline June 2022 D. Appendix E Constraints Redline June 2022 E. Appendix F SSI Report Redline June 2022 F. Appendix F SSI Table Redline June 2022 G. Housing Element (Chapters 1-5) Clean June 2022 H. Appendix E Constraints Clean June 2022 I. Appendix F SSI Report Clean June 2022 J. Appendix F SSI Table Clean June 2022 K. October 12, 2021 City Council Meeting L. March 15, 2022 City Council Meeting M. April 26, 2022 City Council Meeting N. February 2, 2022 Planning Commission Meeting O. June 15, 2022 Planning Commission Meeting P. Written Comments Q. PowerPoint Presentation 8.B Packet Pg. 53 STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 (916) 263-2911 / FAX (916) 263-7453 www.hcd.ca.gov August 30, 2021 Jing Yeo, Planning Manager Community Development Department City of Santa Monica 1685 Main Street – Mail Stop 28 Santa Monica, CA 90401 Dear Jing Yeo: RE: Review of the City of Santa Monica’s 6th Cycle (2021-2029) Draft Housing Element Thank you for submitting the City of Santa Monica’s (City) draft housing element received for review on July 1, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a telephone conversation on August 24, 2021 with you, Rachel Kwok, George Cardona, David Martin, Heidi von Tongeln, and the City’s consultant John Douglas. In addition, HCD considered comments from Abundant Housing LA, the California Department of Fish and Wildlife, the Santa Monica Housing Council, Jason Mastbaum, Tieira Ryder, Brad Ewing, Matthew Millen, Adam Buchbinder, Ann Paulson, Matthew Stevens, Ken Kutcher, Lee Kaplan, and Haley Feng, pursuant to Government Code section 65585, subdivision (c). The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law. To remain on an eight-year planning cycle, the City must adopt its housing element within 120 calendar days from the statutory due date of October 15, 2021 for Southern California Association of Government (SCAG) localities. If adopted after this date, Government Code section 65588, subdivision (e)(4), requires the housing element be revised every four years until adopting at least two consecutive revisions by the statutory deadline. For more information on housing element adoption requirements, please visit HCD’s website at: http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sb375_final100413.pdf. Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element 8.B.a Packet Pg. 54 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Jing Yeo, Planning Manager Page 2 process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources. We appreciate your hard work and the diligent effort and cooperation of the entire housing element update team. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact John Buettner, of our staff, at john.buettner@hcd.ca.gov. Sincerely, Shannan West Land Use & Planning Unit Chief Enclosure 8.B.a Packet Pg. 55 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 1 August 30, 2021 APPENDIX CITY OF SANTA MONICA The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code. Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources. A. Housing Needs, Resources, and Constraints 1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Fair Housing Enforcement and Outreach: While the element provides an analysis for Affirmatively Furthering Fair Housing (AFFH) beginning on page 27, it generally does not address the requirement to provide an Assessment of Fair Housing (AFH) within the City. The element must include the City’s ability to provide enforcement and outreach capacity which can consist of actions such as the City’s ability to investigate complaints, obtain remedies, or the City’s ability to engage in fair housing testing. Additionally, the analysis must also describe compliance with existing fair housing laws and regulations and include information on fair housing outreach capacity. For further guidance, please visit HCD’s AFFH in California webpage at https://www.hcd.ca.gov/community-development/affh/index.shtml. Integration and Segregation: The element includes data and analysis on integration and segregation by race and income. However, the element must also analyze segregation and integration by familial status and persons with disabilities. Areas of Concentrated Poverty and Affluence: The element includes information relative to Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) but should also address concentrated areas of affluence. The combination of the R/ECAP and areas of affluence analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region). Disproportionate Housing Needs including Displacement Risk: The element includes an adequate analysis regarding displacement risk. Additionally, the element should analyze the trends and patterns for overpayment (i.e. cost burden), overcrowding, substandard housing conditions, and persons experiencing homelessness. 8.B.a Packet Pg. 56 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 2 August 30, 2021 Local Data and Knowledge, and Other Relevant Factors: The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique attributes about the City related to fair housing issues. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers. Also, the element includes meaningful analysis related to historical practices but should also discuss past, present and future investment practices and other information as appropriate. Sites Inventory: The element includes a general conclusion of the site inventory relative to access to opportunity. However, the element should address all components of the AFFH (e.g., segregation and integration and disproportionate housing needs, including displacement). The analysis should also address sites for all income groups separately (e.g., lower, moderate and above moderate), whether conditions are improved or exacerbated and any isolation of the lower-income regional housing needs allocation. Goals, Priorities, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Currently, the element identifies programs to promote and conserve affordable housing; however, most of these programs do not appear to facilitate any meaningful change nor address affirmatively furthering fair housing requirements. Actions must have metrics and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. 2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).) Extremely Low-Income (ELI) Households: The element includes quantification of ELI households but must also identify projected housing needs. The projected housing need for ELI households can be calculated by using available census data to determine the number of very low-income households that qualify as ELI households or presume that 50 percent of the regional housing need allocation (RHNA) for very low-income households qualify as ELI households. Additionally, given the unique and disproportionate needs of ELI households, the element should expand its analysis to better formulate policies and programs. For example, the element could analyze tenure, cost burden, overcrowding and other household characteristics then examine the availability of resources to determine gaps in housing needs. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing-needs/extremely-low-income-housing- needs.shtml. 8.B.a Packet Pg. 57 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 3 August 30, 2021 3. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Housing Stock Condition: The element identifies the age of the housing stock and provides basic ACS data on substandard conditions (beginning on page B-17). However, it must also include analysis of the condition of the existing housing stock and estimate the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable organizations. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing-needs/housing-stock-characteristics.shtml. 4. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).) Progress in Meeting the RHNA: The City’s RHNA may be reduced by the number of new units built since July 1, 2021. The element indicates (p. F-9) 1,670 approved and 756 pending units (before applying a 10 percent reduction) toward the RHNA but must also demonstrate the affordability of the units. Specifically, the element must assign these units to the various income groups based on actual or anticipated sales price or rent level of the units or other mechanisms ensuring affordability (e.g., deed- restrictions) and demonstrate their availability in the planning period. Realistic Capacity: The element must include an estimate of the number of units that can be accommodated on each site in the inventory. The estimate may rely on established minimum density standards or include analysis demonstrating how the number of units for each site was determined. The estimate of the number of units accounts for land use controls and sites improvements however does not support assuming maximum floor areas for every site. The element should include additional and clear supporting information on typical densities of existing or approved residential developments at a similar affordability level. For example, the element could clearly list recent projects, the zone, acreage, built density, allowable density or floor areas, level of affordability and presence of exceptions such as a density bonus. In addition, the element appears to assume residential development on sites with zoning that allow 100 percent nonresidential uses. The element must account for the likelihood of nonresidential uses. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculation, policies, and program accordingly. The element should include analysis based on factors such as development trends, performance standards or other relevant factors. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/site-inventory-analysis/analysis-of-sites-and-zoning.shtml#zoning. 8.B.a Packet Pg. 58 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 4 August 30, 2021 Suitability of Nonvacant Sites: The element does not adequately address this requirement. The element must include an analysis to demonstrate the potential for additional development within the planning period. The analysis shall consider factors including, the extent to which existing uses may constitute an impediment to additional residential development, the City’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. For example: • the element should discuss recent redevelopment trends and how those trends relate to identified sites and categories (p. F-2) in the planning period; • denote the site categories in the inventory, including whether the site is a high potential site; • discuss why some approved and pending projects do not have high potential and any impacts on their development in the planning period; • describe recent experience with developing some of the site categories and relate those characteristics to the inventory; • identify all sites in the inventory with known development interest, expiring leases or other indicators of turnover in ownership that may lead to development; • support the use of factors such as age of structure and assessor value ratio and reflect those values on a parcel basis; and • include additional analysis demonstrating the potential for redevelopment in each of the categories In addition, for your information, the element relies on nonvacant sites to accommodate 50 percent or more of the housing needs for lower-income households, which triggers requirements to make findings based on substantial evidence that the existing use is not an impediment and will likely discontinue in the planning period. Finally, the element identifies sites with existing residential uses. Absent a replacement housing policy, these sites are not adequate sites to accommodate lower-income households. The replacement housing policy has the same requirements as set forth in Government Code section 65915, subdivision (c)(3). The housing element must be revised to include analysis, if necessary and a program. City-Owned Sites: The element must include additional discussion on each of the City-owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). 8.B.a Packet Pg. 59 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 5 August 30, 2021 Zoning Appropriate for Lower-Income Households: The element must demonstrate densities appropriate to accommodate housing for lower-income households. For communities with densities that meet specific standards (at least 30 units per acre for Santa Monica), no analysis is required. (Gov. Code, § 65583.2, subd. (c)(3).) Otherwise, an analysis must demonstrate appropriate densities based on factors such as market demand, financial feasibility and development experience within identified zones. The element states (page F-13) that sites identified for lower-income households can accommodate densities greater than 30 units per acre; however, the inventory assigns maximum densities less than 30 units per acre toward the lower-income RHNA. As a result, the element should explain how these sites can allow up to 30 units per acre or more (without exceptions), include analysis as described above or programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). Accessory Dwelling Units (ADU): ADUs may be counted toward the RHNA based on past permitted units in the prior planning period, affordability, resources and incentives and other factors. The element organizes recent ADU trends into three categories: in-progress, permits issued and completed. Based on communications, these categories are mutually exclusive; however, the element should clarify that ADUs are not counted across multiple categories. Also, while information on in-progress may be utilized to inform the potential for ADUs in the planning period, the analysis should be based on permitted ADUs and the in-progress information should be ancillary to permitted ADU. Finally, for your information, HCD records indicate permitted ADUs of 20 in 2018, 30 in 2019 and 27 in 2020. These numbers are significantly less than the City’s assumptions. The element should reconcile these numbers and adjust assumptions as appropriate Small Sites: Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence the site is adequate to accommodate lower income housing. While the element lists some recent development on smaller sites, it should relate these trends to identified sites. For example, almost all of the recent developments, particularly developments 100% affordable to lower-income households, had at least 30 units but the element should also discuss typical sizes on identified sites. This analysis should also relate zoning and allowable densities from recent projects to identified sites. Further, many sites appear to necessitate consolidation. As a result, the element should demonstrate the potential for consolidation. Based on the outcomes of the analysis, the sites inventory should be adjusted as needed and programs should be added or modified. Infrastructure: The element should clarify sufficient existing and planned total infrastructure capacity (water and sewer) to accommodate the RHNA and include programs, if appropriate. 8.B.a Packet Pg. 60 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 6 August 30, 2021 Water Sewer Priority: Water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. The element should discuss compliance with this requirement and if necessary, add or modify programs to establish a written procedure by a date early in the planning period. For additional information and sample cover memo, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/other-requirements/priority-for-water-sewer.shtml. Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml for a copy of the form and instructions. The City can reach out to HCD at sitesinventory@hcd.ca.gov for technical assistance. Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to sitesinventory@hcd.ca.gov. Sites with Zoning for a Variety of Housing Types: • Emergency Shelters: The element must demonstrate the BTV, MUC, and PL zones have sufficient capacity to accommodate the need for emergency shelters. This analysis should address typical parcel sizes, opportunities for redevelopment or reuse, proximity to transit, services and hazards. In addition, the element should describe how emergency shelter parking requirements comply with AB 139 (Chapter 335, Statutes of 2019) or include a program to comply with this requirement. • Permanent Supportive Housing: Supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with this requirement and include programs as appropriate. • Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.) or add or modify programs. Specifically, section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. • Accessory Dwelling Units (ADUs): The element indicates the City modified its zoning code to ease barriers to the development of ADUs. However, after a cursory review of the City’s ordinance, the department discovered several areas which were not consistent with State ADU Law. This includes, but is not limited to, standards for ADUs and JADUs established by converting floor areas of existing structures, as found in section 9.35.025. HCD will provide a complete listing of ADU noncompliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance to comply with State law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU 8.B.a Packet Pg. 61 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 7 August 30, 2021 development; see link: https://www.hcd.ca.gov/policy- research/docs/adu_december_2020_handbook.pdf. Please also note that any applications for an ADU / Junior Accessory Dwelling Unit (JADU) permit must be permitted in accordance with current state law, regardless of the City’s adopted ordinance. 5. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures… (Gov. Code, § 65583, subd. (a)(5).) Land-Use Controls: The element must identify and analyze all relevant land-use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land-use controls independently and cumulatively with other land-use controls. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. Fees and Exaction: The element must describe all required fees for single family and multifamily housing development, including planning and impact fees, and analyze their impact as potential constraints on housing supply, cost, timing and affordability. While the element identifies these fees, the City should also analyze the impacts of these fees and include programs as appropriate. For example, the element should address planning fees for conditional use permits. The element should also address the total fees for 3-Unit/Condominium developments (page E-38) and typical multifamily development. Finally, the element should evaluate the cumulative impact of fees on development costs instead of sales prices. For additional information and a sample analysis and tables, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/constraints/fees-and-exactions.shtml. Local Processing and Permit Procedures: The element describes the Development Review Permit (DRP) and Architectural Review Board (ARB) discretionary processes (pages E-43, E-44) but must also analyze impacts on housing cost, supply and approval certainty. For example, the analysis should address approval findings such as “…both compatible and relate harmoniously to surrounding sites and neighborhoods”, “…expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity and individuality.”, “inferior quality” “…cause the nature of the local neighborhood or environment to materially depreciate in appearance and value.”, and “… compatible with developments on land in the general area.” Based on the findings of the additional analyses, programs may need to be added or modified to address identified constraints. SB 35 Streamlined Ministerial Approval Process: While the element notes the City is not subject to SB 35 (Chapter 366, Statutes of 2017), conditions may change in the 6th 8.B.a Packet Pg. 62 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 8 August 30, 2021 cycle planning period. As a result, the element should clarify whether the City has a written procedure and if not, add or modify programs as appropriate. Codes and Enforcement: While the element provides a general description on implementation of the building code, the element must also identify any local amendments to the building code and analyze their impact as potential constraints on housing supply and affordability On-/Off-Site Improvements: The element describes the City may require on- and off-site improvements but should also identify and analyze the actual standards for impacts on the cost and supply of housing. For additional information and a sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/constraints/codes-and-enforcement-on-offsite-improvement-standards.shtml. Constraints on Housing for Persons with Disabilities: The element must include analysis of potential constraints on housing for persons with disabilities, as follows: • Reasonable Accommodations: The element should generally describe and analyze approval findings for reasonable accommodation. • Group Homes for Seven or More Persons: The element appears to indicate that some group homes for seven or more persons are excluded from single-family zones and subject to a conditional use permit. The element should specifically analyze these constraints for impacts on housing supply and choices and approval certainty and objectivity for housing for persons with disabilities and add or modify programs as appropriate. • Definition of a Family/Household: The element defines a Household as “One or more persons living together in a single dwelling unit, with access to and use of all common living and eating areas and all common areas and facilities for the preparation and storage of food and who maintain a single mortgage, lease, or rental agreement for all members of the household (page E-32).” The element should analyze the provision to “maintain a single mortgage, lease, or rental agreement for all members of the household”, whether this is a potential constraint on housing for persons with disabilities and add or modify programs as appropriate. 6. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).) 8.B.a Packet Pg. 63 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 9 August 30, 2021 Time between Approval and Building Permit: The element must analyze the length of time between receiving approval for a housing development and submittal of an application for building permits and any hinderance on the construction of a locality’s share of the regional housing need. 7. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).) Farmworkers: The element states (page B-33) Santa Monica does not support the agriculture industry and there is no need for farmworkers. Farmworkers from the broader area and those employed seasonally may have housing needs. As a result, the element should at least acknowledge the housing needs of permanent and seasonal farmworkers at a county-level (e.g., USDA county-level farmworker data) and include programs as appropriate. 8. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).) The element identifies certain “at-risk” projects and provides basic analysis and assessment but should also expand the list of eligible entities. Qualified entities are public and private non-profit corporations known to the City to have the legal and managerial capacity to acquire and manage at-risk units. For more information, please see https://www.hcd.ca.gov/policy-research/preserving-existing-affordable-housing.shtml. B. Housing Programs 1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single- room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding A4, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition: 8.B.a Packet Pg. 64 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 10 August 30, 2021 • Shortfall of Sites: The parcel listing indicates some sites will need to be rezoned to accommodate the regional housing needs allocation. If so, program(s) must specifically commit to acreage, allowable densities and anticipated units. In addition, if necessary, to accommodate the housing needs of lower-income households, program(s) should specifically commit to rezoning pursuant to Government Code section 65583.2, subdivisions (h) and (i). • Program 1A (Streamlined Approvals for Housing Projects): This program should clarify the allowance of by-right developments for sites identified in previous cycles if the project includes at least 20 percent affordable housing pursuant to Government Code Section 65583.2. • Replacement Housing Requirements: The housing element must include a program to provide replacement housing (Gov. Code, § 65583.2, subd. (g)(3)). The replacement housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c)(3). • City-Owned Sites: Program 2B (Right of First Offer Ordinance): The program should go beyond explore and commit to establish an ordinance or some other similar mechanism. Program 2E (Affordable Housing on City-owned/Publicly-owned Land) should go beyond assessing properties and commit to steps and a schedule to facilitate development on City-owned sites. In addition, if zoning at appropriate densities is necessary, Program 2E should commit to rezoning pursuant to Government Code section 65583.2, subdivisions (h) and (i). 2. The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households. (Gov. Code, § 65583, subd. (c)(2).) Program 2F (New Affordable Housing Finance Programs): While this program commits to leveraging new sources of state, federal and philanthropic funding for special needs housing, it should go beyond exploring new financing tools and commit to pursue and assist with funding or support funding applications on a regular basis (e.g., at least annually). In addition, the program should include regular outreach (e.g., at least annually) to developers of affordable housing and explicit commitment to assist in the development of housing affordable extremely low-income (ELI) households. Program actions could include prioritizing some funding for housing developments affordable to ELI households and offering financial incentives or regulatory concessions to encourage the development of housing types, such as multifamily, single-room occupancy (SRO) units, to address the identified housing needs for ELI households. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing-needs/extremely-low-income-housing-needs.shtml. 3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) 8.B.a Packet Pg. 65 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 11 August 30, 2021 As noted in Findings A5 and A6, the element requires a complete analysis of potential governmental and non-governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition: • Program 1B (Streamline the Architectural Review): While the program commits to adopt new streamlining procedures, it should include specific commitments to address identified constraints such as approval findings as noted in Finding A5. • Program 1D (Explore Reducing or Eliminating Parking Requirements): In addition to exploring changes to parking requirements, the program should commit to actual modifications of parking requirements. 4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding A1, the element requires a complete analysis of AFFH. Depending upon the results of that analysis, the City may need to revise or add programs to affirmatively further fair housing. In addition, Program 4D (Rezoning Selected Portions of R1 Zone Neighborhoods) notes historical practices have perpetuated segregation and hinder fair access to housing. As a result, the program should go well beyond exploring options and must commit to meaningful and sufficient actions to overcome patterns of segregation and foster inclusive communities. These actions should not be limited by the regional housing needs allocation and must include metrics and milestones as noted under Finding A1. 5. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).) Program 3C: Facilitate the Conservation of Restricted and Non-Restricted At-Risk Housing: This program commits the City to annual monitoring of its affordable housing stock at-risk of conversion to market rate. The program should be revised to commit the City to noticing residents and owners of potential conversion dates, coordinating with qualified entities for potential purchase, and to seek funding assistance specifically for these type projects. 8.B.a Packet Pg. 66 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Review of the City of Santa Monica’s 6th Cycle Draft Housing Element Page 12 August 30, 2021 C. Quantified Objectives Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).) The element provides a summary of quantified objectives starting on page 95 of the policy document. These objectives include new construction and rehabilitation but must also include conservation objectives by income group. Conservation objectives may include the variety of strategies employed by the City to promote tenant stability and the preservation of units at-risk of conversion to market rate uses. In addition, the element includes rehabilitation objectives for approximately 58 units in the 8-year planning period, and HCD encourages the City to reconsider increasing these objectives. D. Public Participation Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).) The element describes the City took a two-part approach to public participation: (1) outreach meetings and (2) inter-department collaboration. Based on communications between HCD and the City, public participation was much broader to include all economic segments of the community. The element should describe these efforts, results and how comments were incorporated into the element. E. Consistency with General Plan The Housing Element shall describe the means by which consistency will be achieved with other general plan elements and community goals. (Gov. Code, § 65583, subd. (c)(7).) For your information, some General Plan element updates are triggered by housing element adoption. For example, a jurisdiction must address environmental justice in its General Plan by the adoption of an environmental justice element, or by the integration of environmental justice goals, policies, and objectives into other General Plan elements upon the adoption or next revision of two or more elements concurrently on or after January 1, 2018. (Gov. Code, § 65302, subd. (h).) In addition, the safety and conservation elements of the General Plan must include analysis and policies regarding fire and flood hazard management and be revised upon each housing element revision. (Gov. Code, § 65302, subd. (g).) Also, the land-use element must identify and analyze disadvantaged communities (unincorporated island or fringe communities within spheres of influence areas or isolated long established legacy communities) on, or before, the housing element’s adoption due date. (Gov. Code, § 65302.10, subd. (b).) HCD reminds the City to consider these timing provisions. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at: http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf and http://opr.ca.gov/docs/Final_6.26.15.pdf. 8.B.a Packet Pg. 67 Attachment: HCD Comments on Adopted 6th Cycle Housing Element February 8, 2022 (4856 : Housing Element Draft Revisions in Response to Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 1 HOUSING ELEMENT 2021-2029 SUMMARY OF RESPONSES TO HCD COMMENTS This table contains corrections, clarifications, and changes to the published text of the 6th Cycle Housing Element and represents changes in response to HCD’s comments. 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. Change No. Page Number Summary of Change Recommended Redline 1. 91 Addresses HCD Comment. Provided additional background on past development on City- Owned Sites The City has worked to overcome these barriers over the past 40 years by supporting 100% affordable housing on city-owned land resulting in the production of 770 units of affordable housing. The long-term affordability of these units has been guaranteed through recorded deed restrictions or in the case of property sale, the City has negotiated for right of first option to purchase for a low, fixed amount in the event of future sale. As such the City has a demonstrated history of continuously leveraged public land to produce affordable housing for the benefit of the community. 2. 108 Addresses HCD comment. SSI: Provide background on local data and knowledge used to develop 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 SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning, general characteristics such as historic and land use designations, and market factors. City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. 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. Based on the assessment of sites using the above factors and methodology, there are 138 parcels that have approved and pending projects for residential development and 180 non-vacant commercial/mixed use zoned parcels in the City identified to have high potential for residential redevelopment. In addition, 22 residentially zoned sites that are developed as parking lots have been identified as having high potential 8.B.b Packet Pg. 68 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 2 Change No. Page Number Summary of Change Recommended Redline to be redeveloped for housing. Approximately 332 340 sites have been identified that have the highest potential to accommodate housing. These are shown on Map 4-1. Sites may be viewed interactively on the City’s Housing Element Update webpage at: https://www.santamonica.gov/housing-element-update. The sites in the SSI are categorized according to Figure 4-2. 3. 110 Technical Revision: Updated Approved/Pending Projects The City has a significant number of housing projects in the pipeline that if constructed will count toward the City’s 6th Cycle RHNA. As of February 2021May 2022, there were approximately 1,6702,594 approved units (of which 401 637 are affordable) and 756 2,550 pending units on 108 13 parcels. The list of approved and pending projects is provided in Appendix F. A review of the past 5th Cycle Housing Element shows that 10% of approved and pending projects were withdrawn and/or have had permit approvals expire. It is not possible for City staff to predict how many and which specific approved and pending projects could be withdrawn or ultimately not developed. Doing so would be arbitrary and speculative. Therefore, a 10% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 1,5032,205 approved units and 680 2,168 pending units that are projected to count towards the 6th Cycle Housing Element. 4. 111 Technical Revision: City Owned Sites The City-owned sites in the SSI are: Public Parking lots 7, 8, and 12, Parking Structure 3, 4th & Arizona, Bergamot Arts Center, and Main Street parking lots. With consideration to existing constraints (such as lease terms, financial resources, etc.), City-owned sites have the potential for accommodating 1,884 880 units. Program 2.E commits the City to plan for a minimum of 1,884 880 affordable housing units across available City-owned sites, which may include but shall not be limited to rezoning actions. 5. 111 Technical Revision: Community Assembly Sites Community Assembly Sites (including Religious Congregations) 6. 112 Technical Revisions: SSI With the programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate at least 11,07013,600 units providing a 24 53 percent buffer above the City’s RHNA of 8,895 units. 8.B.b Packet Pg. 69 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 3 Change No. Page Number Summary of Change Recommended Redline This number is based on the application of new development standards for housing projects as established in Programs 1.F and 1.J. 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 land inventory includes capacity for 2,444 521 extremely low, 2,3982,819 very low income, 2,542,703 low income, and 1,7841,901 moderate income units. Figure 4-3 breaks down the summary of the SSI capacity based on category and income levels. Total Capacity Capacity for Affordable Units # Units # Affordable Units ELI VLI LI Moderate Category 1 Approved 2,205 1,503 637 416 127 104 177 104 185104 148 104 Category 1 Pending 2,168 680 420 165 24 42 321 42 3442 41 42 Category 4 City Sites 1,880 1,884 1,880 1,884 627 628 627 628 627 628 - - Category 11 Religious Sites 257 257 130 129 32 32 32 32 32 32 34 32 Category 12 Parking Lots 96 105 9 53 - 13 - 13 9 13 - 13 All Remaining Categories 6,6196,289 6,6196,289 1,6551,572 1,6551,572 1,6551,572 1,6551,572 ADUs 376 352 249 232 56 53 8 7 162 151 23 21 Total 13,600 11,070 9,944 9,168 2,521 2,444 2,8192,398 2,7032,542 1,9011,784 RHNA Targets 8,895 8,895 6,168 6,168 1,397 1,397 1,397 1,397 1,672 1,672 1,702 1,702 Buffer +4,705+2,175 + 3,776+3,000 +1,124+1,047 + 1,422+1,001 + 1,031+870 +199+82 2453% 7. 114 Technical Revisions: Past Permitted ADUs Building Permit Year PermitS Issued Total 2018 2354 56 8.B.b Packet Pg. 70 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 4 Change No. Page Number Summary of Change Recommended Redline 2019 6051 83 2020 4127 115 2021 2102 27 TOTAL 226134 281 Average 2018-20201 (23+60_41+102) 54+51+27)/34 = 4456.5 units per year Source: Building permit data as of June 1, 2021May 31, 2022 Each ADU building permit is only accounted for once across all years. Updated Map 4-2 to reflect updated ADU data. 8. 116 Technical Revision: Forecasted ADU Development As shown in the above table, based on ADU building permit data between 2018 and 20201, Santa Monica averagesd 4456 ADUs per year. However, given that 36 of the ADUs (approximately 16%) were located on parcels with existing multi-unit dwellings, which are less typical applicants for ADUs, the average annual production estimate has been reduced by 16% to approximately 47 ADUs per year. Therefore, Using this average production number, it can be expected that over the next eight-year Housing Element cycle, approximately 352376 ADUs will be built and can be used towards our RHNA. This estimate is conservative, as it accounts for a potential progressive decline in available land for ADU within single-unit zones. As noted, Tthis forecast also does not account for possible future interest in ADUs to be incorporated into existing multiple-unit residential and mixed-use developments, which the City has only just started seeing very recently as the new law permitting this only took effect January 1, 2020. Income Level Percent of ADUsa Projected # of ADUs Extremely Low Income 15% 5653 Very Low 2% 78 Low 43% 162151 Moderate 6% 2321 Above Moderate 34% 128120 a Based on SCAG Survey of ADU Affordability 9. 19 & 121 Program 1.A: Elaborate on Streamlined Approvals … The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. ... 8.B.b Packet Pg. 71 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 5 Change No. Page Number Summary of Change Recommended Redline The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process. March 31, 2022October 15, 2022 10. 20, 123, & E-55 Program 1.B : Evaluate ARB approval findings for impacts on housing production. …. The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. The amendments shall also be clear that design review cannot be used to reduce density or deny a housing project. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency anticipating compliance with SB35 for applicable housing projects. Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022September 30, 2022 This includes expansions to the staff-level approvals, shifting the design review process to occur before or be concurrent with entitlement review, placing time and hearing limits on projects, review and establish mechanisms to promote approval certainty, and developing objective design standards. 11. 20 & 124 Program 1.C: Timing Revision August 1, 20222023 12. 20 & 125 Program 1.D: Timing Revision. August 1, 2022October 15, 2022 13. 20 & 126 Program 1.E: Technical Revision. By June 30, 2023 14. 21 & 127 Addresses HCD comment. Program 1.F: Specific commitment to change development standards. Inserted development The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will promote housing and ensure feasibility and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR and height shown in 8.B.b Packet Pg. 72 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 6 Change No. Page Number Summary of Change Recommended Redline standards table. Timing revision. the table below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing including but not limited to development impact fees, unit mix, and designs standards… Zoning District Approx. Acres to be Rezoned Current Tier 1 FAR /Height Minimum Tier 1 FAR /Height with Rezoning Current Tier 2 FAR/Height Minimum Tier 2 FAR/Height with Rezoning Current Tier 3 FAR/Height Minimum Tier 3 FAR/Height with Rezoning LT (East) 12 1.50/ 39 ft 2.75/ 60 ft 2.25/ 50 ft 3.0/ 65 ft - - LT (West) 11 1.50/ 39 ft 2.75/ 60 ft 2.75/ 60 ft 3.0/ 65 ft - - NV 31 2.25/ 39 ft 2.75/ 60 ft 3.50/ 60 ft 3.50/ 70 ft - 4.0/ 84 ft BC (Promenade) 12 2.25/ 39 ft 2.75/ 60 ft 2.75/ 60 ft 3.0/ 65 ft - - BC (2nd/4th) 25 2.25/ 39 ft 2.75/ 60 ft 3.50/ 60 ft 3.50/ 70 ft - - TA 52 2.25/ 39 ft 2.75/60 ft 3.50/ 60 ft 3.50/ 70 ft 4.0/ 84 ft 4.0/ 84 ft OT 15 2.25/ 39 ft 2.75/60 ft 2.75/ 60 ft 3.0/ 65 ft - - WT 6 1.50/ 39 ft 2.75/60 ft 2.25/ 50 ft 3.0/ 65 ft - - March 31, 2022October 15, 2022 15. 22 & 129 Addresses HCD comment. Program 1.G : Include goals, priorities, metrics, and The City shall develop an Accessory Dwelling Unit Accelerator Program that will simplify the ADU process by providing property owners interested in constructing ADUs throughout all neighborhoods… 8.B.b Packet Pg. 73 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 7 Change No. Page Number Summary of Change Recommended Redline milestones. Timing revision. The program will further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year. December 31, 2022June 30, 2023 16. 22 & 129 Addresses HCD comment. Program 1.H: Stronger language to commit to zoning. Timing revision. As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to encourage and incentivize the adaptive reuse of existing commercial tenant spaces citywide, for permanent residential use and also allow anadaptive reuse of existing ground floor commercial space for artists and live-work use. The City shall also adopt policy and zoning changes to Changes to incentivize the conversion of existing commercial tenant space to residential use include but are limited to, such as relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements. December 31, 20232024 17. 22 & 130 Timing Revision: Program 1.I December 31, 20232024 18. 22 & 131 Addresses HCD comment. Program 1.J: Specific commitment to change development standards. Inserted development standards table. Timing revision. The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.002.75 to 3.25 with heights ranging from 55 feet to 65 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will ensure feasibility promote housing to ensure and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR and height shown in the tables below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement. Zoning District # Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Minimum FAR/Height with Rezoning MUBL – N of I-10 107 1.50/ 36 ft 1.75/ 36 ft 3.25/ 70 ft 8.B.b Packet Pg. 74 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 8 Change No. Page Number Summary of Change Recommended Redline MUBL – Pico 15 1.50/ 36 ft 1.75/ 36 ft 2.00/ 45 ft MUBL – Pico (West of Lincoln) 4 1.50/ 36 ft 1.75/ 36 ft 2.50/ 55 ft MUBL – Main St 10 1.50/ 36 ft 1.75/ 36 ft 2.50/ 55 ft MUBL - Lincoln 107 1.50/ 36 ft 1.75/ 36 ft 2.50/ 55 ft MUB 59 1.50/ 39 ft 2.25/ 50 ft 3.25/ 70 ft GC (SMB) 24 1.25/ - 1.50/ 35 ft 3.25/ 70 ft GC (Lincoln) 19 1.50/ 36 ft 2.00/ 36 ft 2.50/ 55 ft GC (Pico) 4 1.50/ 36 ft 2.00/ 36 ft 2.00/ 45 ft NC 27 1.50/ 32 ft N/A 2.25/ 50 ft NC (Main) 14 1.00/ 27 ft N/A 2.50/ 55 ft NC (Ocean Park) 15 1.00/ 32 ft N/A 2.50/ 55 ft NC (Montana) 15 1.00/ 32 ft N/A 2.50/ 55 ft IC 77 N/A N/A 3.00/ 65 ft OC 88 N/A N/A 2.75/ 60 ft HMU 39 1.50/ 45 ft 2.50/ 70 ft 2.50/ 70 ft Bergamot Area # Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Current Tier 3 FAR/Height Minimum FAR/Height with Rezoning BTV 35 1.75/ 32 ft 2.00/ 60 ft 2.50/ 75 ft 4.0/ 84 ft MUC – North of Pennsylvania Avenue parcel line between Stewart and Stanford: South of Expo Bike Path 31 1.50/ 32 ft 1.70/ 47 ft 2.20/ 57 ft 3.25/ 70 ft 8.B.b Packet Pg. 75 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 9 Change No. Page Number Summary of Change Recommended Redline MUC - remainder 31 1.50/ 32 ft 1.70/ 47 ft 2.20/ 57 ft 4.0/ 84 ft CCS 8 1.50/ 32 ft N/A N/A 2.50/ 55 ft CAC 17 1.00/ 32 ft 1.00/ 60 ft 1.00/ 75 ft 2.50/ 55 ft In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production… March 31October 15, 2022 19. 24 & 133 Addresses HCD comment. Program 1.K: Commit to adequate densities, acreage, and requirements of Gov. code 65583.2. Timing revision. To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower income units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing are allowed 100 percent residential use and require requiring residential use to occupy at least 50 percent of the floor area. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City comply with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations. August 1, 2022June 30, 2023 20. 25 & 134 Addresses HCD comment. Program 2.A: Include goals, priorities, metrics, and milestones. Timing revision. The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in targeted at least three areas of the City… August 1, 2022June 30, 2023 8.B.b Packet Pg. 76 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 10 Change No. Page Number Summary of Change Recommended Redline 21. 25 & 135 Addresses HCD comment. Program 2.B: Include goals, priorities, metrics, and milestones. Timing revision. Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, Tthe City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making non-profit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildings through this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable. December 31, 20232024 22. 26 & 135 Addresses HCD comment. Program 2.C: Include goals, priorities, metrics, and milestones. Timing revision. In order to increase the number of affordable housing units at all income levels such that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to include, but not be limited to… June 30, 2022by April 30, 2023 23. 26 & 137 Program 2.D: Timing revision. March 31October 15, 2022 24. 27 & 138 Program 2.E: Include goals, priorities, metrics, and milestones. The City shall plan for a minimum of 1,8841,880 affordable housing units across available City-owned sites, which are located throughout the city, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. 8.B.b Packet Pg. 77 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 11 Change No. Page Number Summary of Change Recommended Redline At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first An RFP for at least onea city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, . Future RFPs shall be staggered based on availability of resources.the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months. As has been done in the past, the City will use a variety of tools Tto facilitate 100% affordable housing development including but not limited to: • Facilitate appropriate zoning and process to support 100% affordable housing • Substantially reduced or free ground rent, the City will • Providing funding through local housing trust fund • Support applications for other funding sources for affordable housing (e.g. low- income-housing tax credits, grants, State funding, Federal funding) • Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Further, the City will continue to assess appropriate City-owned properties for the development of affordable housing… An RFP to redevelop Parking Structure 3 located on the Third Street Promenade as affordable housing was issued in August 15, 2019 and a developer partner was selectedis currently pending review. 8.B.b Packet Pg. 78 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 12 Change No. Page Number Summary of Change Recommended Redline Responsibility: Housing Division; City Planning Division; Economic Development Division 25. 28 & 140 Program 2.F: Include goals, priorities, metrics, and milestones. …. Local funding through the Housing Trust Fund will also help support the production of at least 1,880 affordable housing production units on City-owned/publicly owned land in accordance with Program 2E. Santa Monica has been awarded a total of $10 million from the Local Housing Trust Fund (LHTF) program for the 2020 and 2021 funding rounds and is also eligible to receive an estimated $3.285 million from the first five years of the Permanent Local Housing Allocation (PLHA) entitlement program. The awarded State grants, as well as future State grants, are essential to Santa Monica’s ability to create affordable housing on City-owned land and further the goals of the City’s Housing Element. Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing 26. 28 & 141 Program 2.G: Include goals, priorities, metrics, and milestones. The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle… 27. 29 & 143 Program 2.I: Commit to revisions to standards for Emergency Shelters in compliance with AB 139. Timing revision. The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law as needed regarding special needs housing types and residential land use classifications as needed. Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty. December 31, 2022 2023 and Annual Ongoing 28. 29 & 144 Program 3.A: Include goals, priorities, metrics, and … and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced. 8.B.b Packet Pg. 79 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 13 Change No. Page Number Summary of Change Recommended Redline milestones. Timing revision. …the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity's valid exercise of its police power (approximately 27,484 units)… SB 330 (effective 01/01/21 through 01/01/25) and SB 8 (extended SB330 through 01/01/30) enacted a program that establishes unit replacement requirements and tenant protections for new housing projects… August 1, 2022June 30, 2023 29. 30 & 145 Program 3.B: Include goals, priorities, metrics, and milestones. The City shall continue to implement programs throughout the city, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues… The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles …the City has developed an Housing Aanti-discrimination Discrimination ordinance (Santa Monica Municipal Code chapter 4.28), which prohibits various types of housing discrimination—such as refusal to rent, differential treatment, discriminatory statements-- on the basis of disability, age, source of income, parenthood, pregnancy, or the potential or actual occupancy of a minor child. In 2015, as an affordable housing measure, the City added Source of Income as a protected class and then added an extra layer of protection with a pioneering definition for Source of Income. For the first time in Santa Monica and in California, the fair housing law expressly protected recipients of rental assistance such as Section 8. and 8.B.b Packet Pg. 80 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 14 Change No. Page Number Summary of Change Recommended Redline Furthermore, City has launched a 2-year pilot Right to Counsel program… 30. 30 & 146 Program 3.C: Include goals, priorities, metrics, and milestones. … The City will continue to monitor over this Housing Element cycle the status of the approximately 770 affordable, deed-restricted at-risk projects units withinthroughout the City… … the City shall continue to report annually on research and implement strategies on conserving non-covenant residential units such as the approximately 27,000484 rent- controlled units and naturally occurring affordable units… 31. 30 & 147 Program 3.D: Technical Revision 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 for acquisition and rehabilitation throughout the city. 32. 30 & 147 Program 3.E: Technical Revision The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the city 33. 31 & 148 Program 3.F: Include goals, priorities, metrics, and milestones. The City shall continue to respond to residential building code violation complaints throughout the city. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day. In the case of a residential building code violations that do not affect habitability, the City provides up to 30-days to correct the violation. If the work necessitates a building permit, the City provides up to 180 days to correct the violation (the life of the permit). In the case of substandard housing that affects habitability, the City requires the landlord to promptly commence the work to restore the unit(s) to a habitable condition and return tenants to their units through the Habitability Determination Form and Relocation Order and provide tenant protections (temporary relocation). 34. 31 & 149 Program 3.G: Include goals, priorities, metrics, and milestones. The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle. 8.B.b Packet Pg. 81 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 15 Change No. Page Number Summary of Change Recommended Redline 35. 31 & 149 Program 3.H: Include goals, priorities, metrics, and milestones. Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties. Responsibility: Housing and Human Services Division, Rent Control Board 36. 150 Program 3.I: Included past successes in existing program. Under the City’s pilot program and Los Angeles County’s parallel program, StayHousedLA, LAFLA has already helped 40 Santa Monica tenants facing eviction obtain full-scope legal representation. Another 42 have received limited scope services. 37. 31 & 150 Program 3.J: Include goals, priorities, metrics, and milestones. The City shall continue to regulate condominium conversions pursuant to SMMC Section 9.24.040. The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory. Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data. 38. 32 & 152 Program 4.A: Include goals, priorities, metrics, and milestones. Timing revision. … Land use regulations, FAR, and height (as indicated in Program 1.IJ) will be revised to allow housing in the three areas zones that currently do not allow housing… By August 1, 2022October 15, 2022 39. 32 & 153 Program 4.B: Technical revision, timing revision. …Approximately fifteen seven parcels with religious congregations, which are classified in Santa Monica as community assembly uses,… By August 1, 2022 June 30, 2023 40. 32 & 154 Program 4.C: Technical revision, timing revision. The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with Program 4F. by August 1, 2022June 30, 2023 41. 33 & 155 Program 4.D: Include goals, priorities, The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. 8.B.b Packet Pg. 82 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 16 Change No. Page Number Summary of Change Recommended Redline metrics, and milestones. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. 42. 33 & 156 NEW Program 4.E: To Affirmatively Further Fair Housing PROGRAM 4.E: PROVIDE NEW HOUSING CHOICES AND AFFORDABILITY IN HIGH OPPORTUNITY AREAS THROUGH INCENTIVES FOR SB9 UNITS IN R1-ZONE NEIGHBORHOODS The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. This will open up the possibility for property owners to construct up to 6 units through a multi- step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F. Program Background: Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, 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. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City. SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, is a state bill that requires cities to allow one additional residential unit onto parcels zoned for single-unit dwellings. Allowing homeowners proposing SB9 projects to also construct ADUs, particularly on larger parcels, will increase new housing opportunities in high opportunity areas and also promote place-based strategies for community revitalization by increasing housing opportunities in all areas of Santa Monica. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division 8.B.b Packet Pg. 83 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 17 Change No. Page Number Summary of Change Recommended Redline • Objective: Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods 43. 33 & 157 NEW Program 4.F: To Affirmatively Further Fair Housing PROGRAM 4F: ESTABLISH TARGET TO INCREASE HOUSING PRODUCTION IN R1 ZONES AND INCLUDE MID-CYCLE MONITORING The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. • Timeframe: Assess progress by December 31, 2025 • Responsibility: City Planning Division • Objective: Increase the number of net new housing units in R1 zones 44. 34 & 158 Program 5.B: Timing revision By December 31, 20232 45. 34 & 159 Program 6.A: Included past successes in existing program. PROGRAM 6.A: ENHANCE HOUSING MOBILITY BY MAINTAINING RENTAL HOUSING VOUCHER PROGRAMS THROUGHOUT THE CITY AND EXPAND TO ASSIST ALL PERSONS WITH DISABILITIES The City shall continue to operate strong rental housing voucher programs throughout the city and advocate for funding guidelines for Section 8 that are competitive for Santa Monica… The Santa Monica Housing Authority (SMHA) administers two types of rental assistance vouchers, tenant-based and project-based, across five different federal housing programs: Housing Choice Voucher (HCV); Continuum of Care (CoC); HOME Investment Partnerships Program (HOME); Veterans Affairs Supportive Housing (VASH), and Emergency Housing Voucher (EHV) programs. Tenant-based vouchers are allocated to specific individuals, which allow participants to choose where to lease rental housing, whereas project-based vouchers are allocated to specific properties rather than participants. In FY202120-2122, the Santa 8.B.b Packet Pg. 84 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 18 Change No. Page Number Summary of Change Recommended Redline Monica Housing Authority (SMHA) administered approximately 1,600 rental housing vouchers, including Section 8, Continuum of Care vouchers, HOME vouchers, and Veterans Affairs Supportive Housing (VASH) vouchers. The HOME program targets rent-burdened households at-risk of becoming homeless and persons who have been homeless for at least a year. Of the 772 vouchers that were used, voucher households reside throughout Santa Monica’s multifamily neighborhoods, with no concentration in one zip code. Five properties in Santa Monica representing senior and supportive affordable housing with significant allocations of project-based vouchers are located in zip codes 90401 (Downtown), 90403 (Wilshire-Montana/Northeast) and 90405 (Ocean Park/Sunset Park) representing a total of 340 affordable housing opportunities. Distribution of Voucher Households 2017-2021 by Santa Monica Zip Code 90401 (Downtown) Tenant-Based Vouchers Project-Based Vouchers Total Rental Housing Vouchers Count 154 155 309 Percentage 31% 57% 40% 90402 (North of Montana) Count 2 0 2 Percentage 0% 0% 0% 90403 (Wilshire-Montana/Northeast) Count 44 102 146 Percentage 9% 37% 19% 90404 (Mid-City/Pico) Count 178 0 178 Percentage 36% 0% 23% 46. 34 & 160 Program 6.B: Include goals, priorities, metrics, and milestones. Include past successes in existing program. The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle the extent feasible. 8.B.b Packet Pg. 85 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 19 Change No. Page Number Summary of Change Recommended Redline The City monitors the availability of Federal, State, and County funding sources to support rental assistance programs on an ongoing basis. The City also undertook eviction prevention efforts to focus on keeping residents housed during the ongoing COVID-19 pandemic. The Legal Aid Foundation of Los Angeles (LAFLA) supported residents in maintaining housing through their general legal services program, which provides eviction defense services. Since April 2021, under the City’s Right to Counsel pilot program and County’s Stay Housed LA Program, LAFLA has provided 81 tenants facing eviction with legal representation. In FY2020- 21 LAFLA’s general legal services program served 590 Santa Monica households utilizing $506,149 in Human Services Grants Program funding. The City also created an enhanced communications campaign to inform renter residents and property owners about the State Rental Assistance program, Housing is Key, and to support with application completion. Educational efforts focus on multilingual outreach to the most vulnerable residents who may not have access to online information. Application support was provided by City staff who answered questions, ran a clinic, and connected residents with the State’s help center and established partner organizations. As of June 7, 2022, 2,207 Santa Monica households were served with an average assistance of $15,566 and $34,354,444 total funds paid. In addition to the State Rental Assistance program, the City implemented the COVID Emergency Rental Assistance Program (ERAP) using $2,549,979 in federal Community Development Block Grant funds (CDBG) and General Funds of $251,535 to provide three months’ rent up to $5,000 to 640 households economically impacted by COVID. A total of 1,106 applications were submitted; 104 households did not qualify for or declined assistance, and an additional 362 households were not offered assistance due to lack of funding (of these 86 received assistance through the LA County program). Funding for program administration came from CDBG and the re-purposing of a County homelessness grant through the Westside Cities Council of Governments (WSCCOG). The Los Angeles County Development Authority (LACDA) also administered a rental assistance program that opened in August 2020 to assist applicants throughout the County with a total of $133 million from the Coronavirus Aid, Relief, and Economic Security Act 8.B.b Packet Pg. 86 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 20 Change No. Page Number Summary of Change Recommended Redline (CARES) and County General Funds. At the close of the program, 435 Santa Monica residents were awarded approximately $3.81 million in assistance through the County program. 47. 35 & 162 Program 6.C: Include goals, priorities, metrics, and milestones. Include past successes in existing program. Support measures that are not housing constraints to generate and allocate tax revenue for income assistance. The City intends the POD Program to serve at least 150 participants within this Housing Element cycle. In FY2020-21, the POD program served 196 low-income senior households providing an average monthly assistance of approximately $500 per month, allowing participants to age in place. Applications for POD are accepted both online and by mail, with assistance for those seeking a reasonable accommodation. 48. 35 & 162 Program 6.D: Include goals, priorities, metrics, and milestones. The City shall prioritize additional education and outreach to tenants and landlords throughout the city… The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational events per year. 49. 35 & 164 Program 6.F: Include goals, priorities, metrics, and milestones. The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica. 50. 35 & 164 Program 6.G: Include goals, priorities, metrics, and milestones. The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated. 51. 36 & 166 Program 7.A: Include goals, priorities, metrics, and milestones. Include The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide and… 8.B.b Packet Pg. 87 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 21 Change No. Page Number Summary of Change Recommended Redline past successes in existing program. Most of the cases are resolved informally, using demand letters, calls, and meetings to either to persuade the need for a change in what the landlord is doing or to conclude that there is insufficient evidence of a fair housing violation However, if there is sufficient evidence of ongoing fair housing violations and the landlord has refused to correct the problem, then the PRD often files a lawsuit in court to enforce the fair housing laws. Since 2007, the PRD hosts a Fair Housing Workshop twice a year. The workshop covers several topics, including reasonable accommodations for tenants with disabilities, the City’s Right to Return program, pandemic-related issues in fair housing, and source-of- income discrimination laws which protect Section 8 voucher-holders and users of rental assistance. All owners, property managers, attorneys, social-service providers, and tenants are invited to attend, free of charge. Over the years, hundreds of tenants and housing providers have attended. The PRD’s workshops continued even through the pandemic, with a switch to virtual settings. The City has also made fair housing presentations to other local and regional groups. Just since April 2020, the City presented or even co-hosted housing rights events sponsored by Santa Monica Rent Control Board, the Legal Aid Foundation of Los Angeles, Western Center for Law & Poverty, Santa Monicans for Renters’ Rights, Fair Housing Council of San Diego, ACLU of Southern California, WISE & Healthy Aging, St. Joseph’s Center, and the Santa Monica Committee for Racial Justice. 52. 170 Quantified Objectives: Technical Revision Household Income Category RHNA % of Total Quantified Objective % of Total Very Low 2,794 31% 1,150116 2216% Low 1,672 19% 572654 1110% Moderate 1,702 19% 351479 7% Above Moderate 2,727 31% 3,1804,459 6167% 8.B.b Packet Pg. 88 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 22 Change No. Page Number Summary of Change Recommended Redline Total 8,895 5,2536,798 Source: City of Santa Monica Community Development Department The goal of 5,2536,798 units can be achieved based on current approved and pending projects,… The quantified objective aims for 33% almost 50% of units produced to be affordable to low and moderate er income households. 53. 1721 POD Participant Update: Technical revision The Preserving Our Diversity (POD) Program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors. It is estimated to include at least 150 participants within the next housing cycle. Income Category Rehabilitated Units Conservation Units Definition Multi-Family Rehabilitation Minor Home Repairs Acquisition & Rehabilitation POD Rental Assistance Vouchers Right to Counsel Very Low 0-50% of County MFI 19 10 40 150 1,600 0 Low 51 to 80% of County MFI 19 10 0 0 0 210 Moderate 81 to 120% of County MFI 0 0 0 0 0 0 Upper Over 120% of County MFI 0 0 0 0 0 0 Totals 38 20 40 150 1,600 210 58 2,0001,900 54. E-26, 39 Appendix E: Technical revision to definition of permitted. “P” = Permitted by right without discretionary action. 8.B.b Packet Pg. 89 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 23 Change No. Page Number Summary of Change Recommended Redline Permitted means without discretionary action. Therefore, supportive and transitional housing are both permitted uses without discretionary action within the City wherever and however single or multiple-unit dwellings are permitted… Additionally, as shown in Figure E-10, Supportive Housing on its own is a permitted use without discretionary action in all multi-unit zones and commercial zones where multi-unit housing is a permitted use. 55. E-28 Appendix E: Technical revision to update ADU building permits to current permits as of May 2022. Aligned with APR. Updated map. Since implementation of these new State laws, the City has seen an increase in ADU production and interest, averaging 56.5 ADUs per year between 2018 and 2021 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 when State law began to focus on incentivizing ADUs. Figure E-12 Santa Monica ADU Production Building Permit Issuance Year Permits Issued 2018 5423 2019 5160 2020 2741 2021 2102 TOTAL: 134226 56. E-33 Appendix E: Technical revision to clarify that emergency shelter requirements will align with AB 139. Emergency shelter capacity updated Revisions will also include, but are not limited to, updated parking requirements for Emergency Shelters pursuant to AB 139. According to the SSI, there are 11 10 parcels within the BTV and MUC zone districts of adequate size that can accommodate emergency shelters with no limitations on bed count and 178 118 parcels in the LT, NV, BC, TA, MUBL, MUB, and GC, NC, IC, and OC zone districts that limit emergency shelters to 55 bed per parcel. SFOf eExisting facilities accommodating an approximate range of 16-70 beds have oan average parcel size of 20,525 square feetXX, and of the 178128 SSI parcels, XX33 parcels would fall within this range SF, NV, BC, TA, 8.B.b Packet Pg. 90 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 24 Change No. Page Number Summary of Change Recommended Redline based on direction from HCD. MUBL, MUB, GC, BC, IC, and OC SF. Therefore, it can be concluded that the parcel sizes on the SSI can accommodate emergency shelters of at least 55 beds. In order to quantify the number of beds that can be established on sites with no bed count limit, a 160 square foot per bed size was applied based on both local analysis and County of Los Angeles standards . As shown in Figure E-13, the City has capacity of 3,013 3,83811,823 emergency shelter beds. Therefore, Santa Monica has sufficient capacity to accommodate its emergency shelter need based on the 2020 point-in-time count of 907. Figure E-13 Santa Monica Emergency Shelter Capacity Zone District Number of Parcels Total Land Area (SF) Emergency Shelter Bed Capacity LT** 214 141,68943,996 770110 NV** 181 22,651183,480 99055 BC** 4 82,478 220 TA** 5 57,5820 275 MUBL** 5113 781,058467,399 2805715 MUB** 22929 499,449740,520273,121 15951210495 GC** 383 380,72981,457 2090165 NC** 14 92,5140 770 BTV* 1 38,54838,333 240240 MUC* 104 197,327287,036 1,7931233 IC** 1 19,662 55 OC** 4 26,117 220 Total: 3348189 2,590,3421,646,5691,124,283 11,8233,013838 * No limitation on bed count (160 SF per bed applied) ** 55 bed limit per parcel 57. E-45, 55 Appendix E: Technical revision to clarify that CUPs are not required for typica Multiple- Unit Dwelling projects. Conditional Use Permits (CUPs) are not required for typical multiple-unit residential projects. CUPs are unusual for residential use classifications in the Zoning Code and a CUP for a residential use has not been requested in the past 10 years. Application fees, including CUPs, are based on cost recovery of services provided (i.e. staff time spent processing the permit), which typically requires significant analysis and development of conditions to mitigate potential impacts (e.g. noise, circulation, loading) on surrounding land uses. As shown in Figure E-10, the only kinds of residential use classifications that very few residential land uses require approval of a Conditional Use Permit (CUP) are elderly and long-term care facilities and emergency shelters. Residential use classifications that require 8.B.b Packet Pg. 91 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 25 Change No. Page Number Summary of Change Recommended Redline approval of aor Minor User Permit (MUP) in some zones are group residential, residential care general, residential care senior, and hospice general. These uses are not typical multiple-unit residential uses in that they typically consist of shared living quarters and provide care for persons in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living. 58. F36 - 46 Appendix F: Expanded AFFH analysis to include number of units by income group in the SSI to show how fair housing conditions are addressed, improved, or exacerbated Updated Step 8: Assessment of Sites to Affirmatively Furthering Fair Housing: Included new maps comparing existing total housing units compared to units proposed under SSI, by census tract. The maps show where SSI units will go, broken down by affordability, in relation to existing housing and demographic patterns such as median income, racial predominance, and environmental health, among others. 59. F19-29 Appendix F: updated to reflect the potential for SSI properties to develop with fewer affordable units than assumed in the inventory. Also accounts for the potential of 100% nonresidential uses. Updated Step 5: Realistic Capacity Analysis of Suitable Sites: The element now includes a probability factor for non-residential uses in the capacity analysis in the SSI. Specifically, capacity of sites now reflects an across the board 15% reduction in housing capacity based on past trends. Added a table showing typical densities of past housing projects. 60. F1-18 Appendix F: updated to include analysis on the extent that existing uses impede additional development Updated both Introduction and Step 4: Evaluating Suitability of Nonvacant Sites for Housing Potential Included a new column in the SSI table identifying the factors (age of building, improvements to land ratio, tenancy, etc) used to select a site. Analysis includes a new flow chart to illustrate the methodology. New table shows how factors are weighted to identify SSI sites. In addition, Attachment 1 to the report now includes a table that supports the use of the factors based on a review of past and approved projects 8.B.b Packet Pg. 92 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029 26 Change No. Page Number Summary of Change Recommended Redline 61. F30-32 Appendix F: updated to describe the trends of past development on small sites and lot consolidation. Updated Step 7: Summary of Capacity to Accommodate the RHNA: Added an explanation of Santa Monica’s past history of small site consolidation and that lot tie agreements are approved administratively. Additionally updated the Shortfall Analysis and Rezoning Capacity Analysis to account for approved and pending projects. The Rezoning Capacity Analysis has also been updated to account for revised ADU projections and proposed floor area ratios and heights. 62. F69-71 Appendix F: Updated to demonstrate existing and planned total infrastructure sewer capacity to accommodate RHNA. Updated Section 2: Infrastructure Constraints Preamble language to affirm that there is sufficient capacity to accommodate the RHNA. 63. F-74 SSI Table Revised to account for approved and pending projects and addition/removal of sites based on updated information. Total number of sites is now 344. 8.B.b Packet Pg. 93 Attachment: Attachment B - Summary of City Responses to HCD Comments (4856 : Housing Element Image 8.B.c Packet Pg. 94 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 1:Introduction 8.B.c Packet Pg. 95 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 3 City of Santa Monica | 2021 - 2029 Housing Element A. Santa Monica’s Housing Strategy Santa Monica’s 2021-2029 Housing Element represents the City’s longstanding commitment to affordable housing, tenant protection, housing and services for special needs groups, homeless services, sustainable development, and fair housing. With a renewed emphasis on equity and the mandate to Affirmatively Further Fair Housing, the housing plan augments the adopted Land Use and Circulation Element (LUCE) by enhancing housing mobility and expanding housing choice in high opportunity areas that have historically excluded diverse populations, which may be areas that are not immediately adjacent to major transportation systems. The Housing Element also reflects the City’s emergence from the COVID-19 pandemic and the socioeconomic inequities that have manifested in the lack of housing stability that disproportionately affected Black, Indigenous, and people of color (BIPOC) and lower-income households. This is an opportunity for the City to reflect and assess the City’s approach to housing and to take a leadership role in creating solutions to address affordable housing production and housing stability in line with Santa Monica’s values to secure livable and affordable housing opportunities for all. Chapter 1: Introduction This Housing Element is built around 4 key principles CorePrinciples Locate housing close to daily services and amenities like transportation, jobs, parks, and schools. Facilitate equitable housing access to all neighborhoods by expanding access to housing opportunities and overcoming patterns of segregation. Promote greater housing stability for existing residents at risk of displacement. Increase housing production for all, with an emphasis on affordable housing. 8.B.c Packet Pg. 96 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 4Chapter 1 | Introduction This Housing Plan continues to reinforce Santa Monica’s core values of supporting housing production, particularly affordable housing, but includes departures from the 2013-2021 Housing Element particularly with respect to where housing is incentivized in the City. While the LUCE established a strategy to encourage housing production around major transportation systems, it does not account for the state’s new Affirmatively Furthering Fair Housing mandate. Key LUCE policies to develop complete neighborhoods in mixed-use areas within easy access to transit opportunities and daily services remain but the updated Housing Plan is driven largely through an equity and inclusion lens. Ensuring equitable housing access and housing choice to all of Santa Monica’s neighborhoods and ensuring that affordable housing production is provided the highest levels of development and process incentives are the bedrock of this updated Housing Element. The programmatic approaches in this housing plan reflect both the City’s desire to continue to reinforce LUCE policies to develop complete neighborhoods in transit-adjacent mixed-use areas and significant changes in State of California Housing laws and events that have affected funding streams for affordable housing, including: • Changes in State housing laws (AB686) that mandate Affirmative Furthering Fair Housing, which requires that the cities…”take meaningful actions in addition to combating discrimination that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protective characteristics.” • Changes to the California Department of Housing and Community Development’s (HCD) Regional Housing Needs Allocation (RHNA) methodology that resulted in a significantly higher new housing unit allocation for Santa Monica due to accounting for existing unmet need. • The devastating economic impact from the COVID-19 pandemic which affected Santa Monica’s budget and funding that would otherwise have been allocated for affordable housing. Further, as the City continues on the road to economic recovery, the funding sources for affordable housing depend heavily on the sales tax revenue that will not recover quickly and likely will affect affordable housing production in the first half of this Housing Element cycle. LUCE Goals for Housing The 2010 LUCE set forth numerous goals and policies in support of conserving and developing appropriate housing in the City and providing services and amenities to support a walkable, accessible community for residents. For convenient reference, these goals have been gathered in Appendix C of this Housing Element. As the housing strategy has been updated to account for changes in State law, LUCE policies will be updated to support this strategy. 8.B.c Packet Pg. 97 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 5 City of Santa Monica | 2021 - 2029 Housing Element B. Community Context 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 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 the further growth of primarily single family homes.1 During the 1920s, the City 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. By the mid-1960s, most land in Santa Monica was developed. Since that time, growth has resulted principally from recycling lower-intensity land uses to higher-density uses. In recent years, the City experienced its most significant residential development in its commercial, mixed-use areas. This trend has been reinforced by the LUCE and Downtown Community Plan policies that incentivize increasing housing around the Metro E (Exposition) Light Rail transit stations. Today, the City’s existing housing stock of 52,269 units consists of a wide range of housing types, from single-unit dwellings on large lots, to small scale bungalows, courtyard apartments, condominiums and larger mixed-use apartments. This housing stock is located within distinct residential neighborhoods and commercial mixed-use districts. With its seaside location and mild, pleasant temperatures year-round, the City has become one of the most highly desirable places to live in the country. However, the opportunity to live in the City comes at a hefty cost. While it is generally recognized that Californians pay more for housing than the average American, Santa Monica’s housing costs are among the highest in the nation (see Appendix B). The lack of housing, particularly affordable housing, is consistently a top concern for many Santa Monica residents and workers. 1 Santa Monica Historic Context Statement, Architectural Resources Group and Historic Resources Group, March 2018. 8.B.c Packet Pg. 98 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 6Chapter 1 | Introduction There are a variety of negative effects caused by a lack of housing. With a greater share of household incomes spent on housing, households are left with less money available to spend on discretionary purchases, or even basic necessities. Having less money available for non-housing costs often means that low-income households will have less savings in the bank, putting those households at risk for poverty, or preventing them from rising out of it. Low-income residents also face extra pressure of displacement due to rising housing costs. With a lack of affordable housing, more and more people are crowding into existing housing units. In addition to public safety issues, there are quality of life impacts associated with overcrowding. High housing costs also impact wider economic growth and are becoming a major consideration for employers. With approximately 80,000 non-resident workers commuting into Santa Monica, employee retention for Santa Monica companies is an issue especially if workers can’t afford to live near their job and have to commute long distances to work. C. Creating an Equitable and Inclusive Community Santa Monica has a record of supporting social equity, housing affordability, and an inclusive community. For the past forty years, the City has enacted numerous policies to prevent resident displacement, including rent control, just-cause eviction, anti-tenant harassment, source of income protections, and anti-discrimination laws that afford protections beyond the federal Fair Housing Act and the California Fair Employment and Housing Act. The City has consistently prioritized the diversity of housing opportunities available to all household types and income levels. Santa Monica’s commitment to affirmatively furthering fair housing is evidenced by specific actions that the City has taken (see Chapter 2 for further discussion). In addition, for several decades, the City has implemented policies and programs to increase the supply of deed-restricted residences that are affordable to low- and moderate-income households. The strategy primarily involves three components: 1. Public financing to support the acquisition, rehabilitation, and deed restriction of existing housing; 2. Public financing to support the construction of new deed-restricted housing; 3. Deed-restricted housing developed by private, for-profit organizations pursuant to the AHPP or development agreements. These actions have resulted in a drastically expanded housing stock in the City. The City has preserved and produced a larger and more diverse supply of low- and moderate-income housing than otherwise would be possible if the City pursued a single strategy. Santa Monica has also facilitated affordable housing through the adoption of land use plans and administrative funding guidelines to support affordable housing preservation and production. In 2010, the Land Use and Circulation Element (LUCE) of the General Plan was adopted, and identifies affordable housing as a primary community benefit associated with new development. Additionally, the City has a Housing Trust Fund. These actions have resulted in a drastically expanded housing stock in the City. 8.B.c Packet Pg. 99 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 7 City of Santa Monica | 2021 - 2029 Housing Element 8.B.c Packet Pg. 100 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 8Chapter 1 | Introduction The City continues to promote and enforce programs to address its fair housing issues, including a Fair Housing Program that is implemented by the City Attorney’s Office Public Rights Division (see Chapter 2 for further discussion). To foster an inclusive and diverse community, it will be essential to continue to put greater emphasis on providing housing that meets the needs of everyone, including low-income households, seniors, BIPOC, multi-generational families, and households with children. The effects of the COVID-19 pandemic have highlighted the complex housing challenges that the City faces, including addressing barriers to housing opportunities, housing insecurity for existing residents, and homelessness. The pandemic has particularly highlighted equity issues in terms of how lack of housing affordability disproportionately affects BIPOC and the need to reexamine land use and zoning decisions to ensure that they do not perpetuate these inequities. This Housing Element presents an opportunity to reflect on, refine, and broaden the City’s approach to housing production – particularly affordable housing – to meet the needs of our most vulnerable community members. It is also an opportunity for the City to take a leadership role in creating solutions to increase affordable housing production and stability in line with Santa Monica’s values to provide secure, livable, and affordable housing opportunities for all. 8.B.c Packet Pg. 101 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 9 City of Santa Monica | 2021 - 2029 Housing Element D. Purpose and Statutory Authority The Housing Element is mandated by Sections 65580 to 65589 of the California Government Code. State Housing Element law requires that each City and County identify and analyze existing and projected housing needs within its jurisdiction every eight years. To that end, State law requires that the Housing Element: • Provide an analysis of existing and projected housing needs, including any special housing needs • Assess affordable units at risk of conversion to market rate • Analyze actual and potential constraints to housing • Assess and describe fair housing issues, including actions to affirmatively further fair housing • Identify adequately zoned sites suitable for housing • Analyze zoning for a variety of housing types • Identify goals and policies to meet housing needs • Identify a schedule of programs and actions to be undertaken to achieve the goals and policies • Identify a quantified objective that estimates the number of units likely to be constructed, rehabilitated, or conserved/preserved • Analyze performance of prior goals, policies, and programs from the last Housing Element cycle • Identify opportunities for energy conservation The 2021-2029 Housing Element updates Santa Monica’s 2013–2021 Element, adopted by the City Council on December 10, 2013 and certified by the State Department of Housing and Community Development (HCD) on January 29, 2014. In compliance with State law, the City of Santa Monica has prepared this Housing Element to be certified by HCD after adoption by the City Council by October 15, 2021. E. Relationship to Other General Plan Elements State law mandates the adoption of a general plan (Government Code Section 65300), which serves as the blueprint for how a particular city or county (e.g., the City of Santa Monica) will develop. A general plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private. Zoning ordinances, specific plans, development projects, capital improvements, and development agreements are required to conform to the general plan. Preparing, adopting, implementing, and maintaining the general plan serves to identify the community’s land use, circulation, environmental, economic, and social goals and policies as they relate to future growth and development. A general plan consists of individual sections ―or elements--that address a specific area of concern, but collectively, they make up an integrated 8.B.c Packet Pg. 102 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 10Chapter 1 | Introduction planning approach for the jurisdiction. State Law requires that general plans include seven elements: land use, transportation, conservation, noise, open space, safety, and housing. A city or county may choose to have additional elements as part of their general plan. Santa Monica’s General Plan consists of the 7 state-mandated elements: (1 & 2) Land Use and Circulation, (3) Conservation, (4) Housing, (5) Open Space, (6) Noise, (7) Safety, as well as a (8) Historic Preservation element. The City’s Land Use and Circulation Element (LUCE) was adopted in July 2010, and last amended in 2020. The LUCE provides guidance for the City’s overall development strategy, including where and how new land uses will be located in relation to the circulation system in the City through 2030. The LUCE established overarching policies and standards for new development based on land use designations for every property in the City. These policies and standards were further refined in the City’s Zoning Ordinance Update in 2015 and by the adoption of various area and specific plans, including the 2013 Bergamot Area Plan and the 2017 Downtown Community Plan. General Plan Safety OpenSpace Noise Housing Element LUCE HistoricPreservation Conservation To meet the City’s RHNA allocation of 8,895 new units over the next 8 years and to affirmatively further fair housing, the Housing Element includes actions and programs to amend adopted development standards and policies. As required by State law, elements of the General Plan should form an integrated, internally consistent plan, and inconsistencies cannot be remedied by a statement giving one element precedence over the others (Gov. Code § 65300.5; Sierra Club v. Board of Supervisors of Kern County (1981) 126 Cal.App.3d 698). Therefore, adoption of the Housing Element will require amendments to the LUCE and the City’s Zoning Ordinance, Bergamot Area Plan, and Downtown Community Plan to ensure internal consistency. 8.B.c Packet Pg. 103 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 11 City of Santa Monica | 2021 - 2029 Housing Element Adoption of this Housing Element will also trigger revision of the City’s Safety Element. The Safety Element was last updated and adopted in February 1995. Over 25 years have passed and since that time, and the State has established new requirements pertaining to Safety Element updates. Specifically, Senate Bill 1030 which was passed in 2018 establishes the following: • Requires the safety element to be revised to identify new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies applicable to the city or county that was not available during the previous revision of the safety element • Requires this revision to occur upon each revision of the housing element or Local Hazard Mitigation Plan (LHMP), but not less than every eight years. F. Housing Element Organization Santa Monica’s Housing Element is organized into the following chapters: 1. Introduction: This chapter discusses the City of Santa Monica’s housing strategy, statutory requirements of the Housing Element and relationship to other General Plan elements, changes to the Land Use and Circulation Element, and a summary of the outreach efforts. 2. Affirmatively Furthering Fair Housing: This chapter provides an assessment of fair housing including a description of segregation patterns, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, disproportionate housing needs, and a summary of actions to affirmatively further fair housing in the City. 3. Goals and Policies: This chapter provides the background for the City’s housing needs, and then establishes the goals and policies to address the housing issues identified. This section forms the framework of the programs in the Housing Element. 4. Land Available for Housing: This chapter summarizes the City’s State mandated RHNA and provides an analysis of suitable land available for residential development to meet the RHNA. 5. Programs and Schedule of Implementation: This chapter lays out the programs that the City will implement to achieve the goals and objectives. Each program includes specific actions to be undertaken by the City, a timeframe for implementation, the City departments/divisions responsible for implementation, and desired outcomes (where appropriate). 8.B.c Packet Pg. 104 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 12Chapter 1 | Introduction G. Community Engagement The City encourages and solicits the participation of the community and other local agencies in the process of identifying housing and community needs, and prioritizing expenditure of funds. Throughout the preparation of the Housing Element, the City conducted numerous outreach efforts to engage all segments of the community. Public Process Adapts to the COVID-19 Pandemic Due to the COVID-19 Pandemic and the resulting safer at home orders, the public outreach process was adapted to accommodate virtual participation. Staff held online roundtable discussions, workshops, questionnaires, and study sessions. The global pandemic not only shifted the way that public participation was performed, but also the way that Staff noticed outreach events. A project website was created and launched in August 2020 to document project progress with information on public outreach events, draft documents, the RHNA, and relevant links. (www. santamonica.gov/housing-element-update). In order to communicate upcoming engagement opportunities during a safer at home order, additional engagement strategies were needed, aside from the typical social media posts, newspaper notices, and email blasts. Two large-scale surveys were conducted at the launch of the project and when the draft concepts were released in order to gather input (see Appendix A). Non-digital communication strategies were employed, like the Rent Control Board newsletter and Seascape, a quarterly City publication mailed to every household in Santa Monica. Materials and notices were also distributed through stakeholders and community partners such as housing providers. While most materials were posted to the project website, printed versions and alternate language versions were available upon request. Community Input The two phases of public outreach conducted to get community input for the Plan included public outreach meetings and inter-department collaboration with other City divisions and departments. Outreach Meetings Figure 1-1 lists the meetings at which opportunities for public, City Council, and City commission input on the Housing Element were provided. As indicated, the City held public webinars, met with stakeholders virtually, and held numerous public hearings with the Planning Commission, City Council, Housing Commission, and Rent Control Board. City staff attended over 35 meetings and hearings throughout the course of the Housing Element preparation. 8.B.c Packet Pg. 105 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 13 City of Santa Monica | 2021 - 2029 Housing Element Figure 1-1: City Boards and Commissions Meeting Date Description Housing Element Update Public Webinar 11/12/20 (Morning) 11/12/20 (Evening) 11/14/20 Public webinars on the project launch Planning Commission 11/18/20 12/9/20 1/20/21 2/17/21 3/16/21 3/17/21 5/12/21 6/2/21 6/3/21 8/18/21 9/8/21 9/14/21 “Gathering Input for the Plan” presentations to City boards, commissions, and the City Council took place between November 2020 and April 2021. An initial study session with the City Council took place in December 2020. Presentations of the May 2021 Draft, which took place between May and June 2021, highlighted the proposed updates to the Housing Element for Commissions, Boards and neighborhood groups as requested. The meetings yielded direction on concepts to include in the draft Housing Element. City Council 12/10/19 12/15/20 3/9/21 3/30/21 6/15/21 Housing Commission 1/7/21 4/1/21 4/15/21 Rent Control Board 12/10/20 4/8/21 Housing Production Technical Working Group 12/3/20 12/17/20 1/22/21 2/19/21 Two technical working groups on Housing Production and Housing Stability were formed in November 2020. The groups were comprised of practitioners and interested community members. The two groups met four times each between December 2020 and February 2021. Housing Stability Technical Working Group 12/11/20 1/8/21 1/28/21 2/18/21 Affordable Housing Developer Round- table 2/25/21 The affordable housing stakeholders’ roundtable brought together affordable housing producers and advocates with particular knowledge and experience in housing issues. Participants included: Linc Housing, Community Corporation of Santa Monica (CCSM), Abode Communities, EAH Housing, Southern California Association of Nonprofit Housing – SCANPH, Step Up, and Amcal Multi-Housing Interfaith Council 4/28/21 Staff met with representatives of a variety of religious congregations through the Santa Monica Area Interfaith Council. The intent was to provide information regarding the possibility of in- creasing housing potential on parking lots of religious congregations. 8.B.c Packet Pg. 106 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 14Chapter 1 | Introduction The first public draft of the Housing Element was released in May 2021 and posted on the department and project website. The Planning Commission held a public hearing on June 2 and 3, 2021, followed by City Council on June 15, 2021. All City meetings are open to the public. The City provides the public with advance notice of the public hearing, on-line links and digital copies of all related materials with print and translated materials available upon request. Comments and direction provided at these meetings were incorporated into the May 2021 draft, which was posted on the website and submitted to the State of California Department of Housing and Community Development (HCD). The City also made use of its internal and external partners to maximize the noticing of hearings, events and the release of draft materials and concepts. This included working with affordable housing providers in the City, the rent control board, and the City’s communications team to reach affordable housing and rent control residents, and the City at large through the SaMo News email blast and City social media accounts. Community outreach for the Housing Element update started with three identical virtual workshops outlining the update process, objectives, and future engagement opportunities. Following the staff presentation, participants were given time to ask staff questions. A summary of each workshop, including the question and answer portion, was then posted to the project website. These workshops were held across several days and times, including the weekend, to allow for broad participation. In addition, an online survey was sent out to all neighborhood groups, stakeholders, and the City’s list of interested parties/groups. Additionally, two Technical Working Groups were established, one focused on housing production and the other on housing stability. The goal of these two groups was to bring together community members, practitioners, and experts to garner more specific feedback on the barriers to housing development and issues surrounding displacement. Attendees came from a broad range of stakeholder groups, including Abundant Housing LA, Community Corp of Santa Monica, NRDC, EAH Housing, various boards and commissions, several private architecture firms, and other various community groups. For a full list of member organization/affiliation, see the Figure 1-2 below. The working groups met four times each and discussed the past and future goals, policies, and programs of the Housing Element. The comments received were then used to develop draft concepts around housing production, location, stability, and equity. These concepts were posted to the website, in both English and Spanish, along with surveys to petition additional feedback form the community at large. 8.B.c Packet Pg. 107 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 15 City of Santa Monica | 2021 - 2029 Housing Element Figure 1-2: Technical Working Group Member Organization/Affiliation Stability TWG Production TWG NOMA KoningEizenberg Architecture Santa Monica Housing Commission RLB Architecture Pico Neighborhood Association KEA Black Agenda SREG Committee for Racial Justice Abundant Housing LA League of Women Voters L.A. Realty Partners NRDC Armbruster Goldsmith & Delvac LLP Community Corp of Santa Monica Community Corp of Santa Monica Harding Larmore Kutcher & Kozal Abundant Housing LA Disability Community Resource Center Moore Ruble Yudell Architects and Planners MAPS Realty Housing Commission PCG Santa Monicans for Renters’ Rights Cypress Equity Investments DFH Architects Morley Builders Architectural Review Board Santa Monica Architects for a Responsible Tomorrow Michael W. Folonis, Architects Housing Commission Yuguchi Architecture Planning Commission NRDC Interested Community Members Harding Larmore Kutcher & Kozal Santa Monica Housing Council Planning Commission Zinner Consultants EAH Inc. MAPS Realty Sustainable Homes of the Future, LLC Cypress Equity Investments Goldman Firth Rossi Architects Morley Builders Architect, member Building and Fire Life-Safety Commission Santa Monica Architects for a Responsible Tomorrow Housing Commission Interested Community Members 8.B.c Packet Pg. 108 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 16Chapter 1 | Introduction In an effort to gather more specific feedback around the barriers to affordable housing development, staff held a roundtable with affordable housing developers from across the Los Angeles area. Involved organizations included Linc Housing, Community Corporation of Santa Monica (CCSM), Abode Communities, EAH Housing, Southern California Association of Nonprofit Housing – SCANPH, Step Up, and Amcal Multi-Housing. Once draft concepts for the Housing Element were developed, they were posted online, in both English and Spanish, for a period of review by the community. The public were provided the opportunity to comment on the draft concepts via an on-line interactive survey. The comments received were then presented back to the Housing Commission, Rent Control Board, Planning Commission, and City Council. City Boards and Commissions Following each meeting held during the initial phase of the community outreach effort, comments were summarized and posted on the project webpage. These materials were made available in English and Spanish, upon request. Figure 1-3 summarizes comments by topics that were received from the community and indicates where issues have been addressed in this document. Individual meeting summaries can be found in Appendix D. 8.B.c Packet Pg. 109 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 17 City of Santa Monica | 2021 - 2029 Housing Element Figure 1-3: Comments Received During Phase I Community Outreach, by Topic General Comment Where Addressed Affordable Housing: There were many discussions that concurred that the cost of housing in Santa Monica is too high. To alleviate the demand for lower- cost housing, the Housing Element should encourage both 100% affordable developments and inclusionary units in market rate housing projects. Some concepts proposed to encourage additional affordable housing are: • Increasing the inclusionary requirements of the AHPP; • Building in additional flexibility for the off-site affordable housing requirement; • Changes to certain development standards to encourage housing production; • Further streamline the process for housing project approval; • Incorporate the SB1763 changes to the state density bonus law; • Increase the maximum allowable density and height to ensure housing feasibility and to support increased affordable housing production; • Right of first offer for non-profit housing developers Programs: 1.A, 1.B, 1.E, 1.F, 1.J, 2.B, 2C,2.D, 4.B Protect Existing Tenants: Concern was expressed that meeting the higher RHNA allocation would lead to the displacement of existing tenants. Community members advocated for additional protections for existing tenants to make sure that they can remain in place while also allowing additional housing units to be built. Some concepts proposed to protect existing residents are: • Expanding upon and adding to the existing programs that provide rental assistance, tenant protections, resident support services, and maintenance/ rehabilitation of housing units; • Protect existing rental units and require that protected units are replaced; • Maintain housing repair and rehabilitation programs; • Expand upon outreach and information for property owners and tenants regarding tenant rights and rehabilitation programs; • Protect low-income units at-risk of converting to market-rate units, as well as the naturally occurring affordable housing units. Programs: 2.G, 3.A, 3.B, 3.D, 3.E, 3.H, 5.A, 6.A, 6.B, 6.C, 6.D, 6.G, 6.H Additional Incentives for Accessory Dwelling Unit (ADU) Production: Ideas were proposed to explore ways to increase the development of ADUs. Since ADUs are typically additions to existing structures, the new units would help to contribute to the RHNA while maintaining neighborhood character and protecting existing residents. Some ideas proposed are: • Allow additional ADUs on single-dwelling unit parcels if they are deed restricted for affordable housing; • Develop an ADU accelerator program to simplify the ADU process and create pre-approved plan sets for ADUs. Programs: 1.G 8.B.c Packet Pg. 110 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 18Chapter 1 | Introduction Inter-Agency Review City Departments: An Interdepartmental Taskforce representing all City departments related to housing including the Community Development Department (encompassing City Planning, Housing, and Economic Development), Community Services Department, City Attorney’s Office and Rent Control Board met regularly over the past year to contribute to the development of the Housing Element, review draft documents, and keep the City’s relevant Boards and Commissions informed about the planning process and key policy issues. Water and Sewer Priority (Section 65589.7): As required by State Law, the Housing Element was shared with the City’s Water Resources Division (WRD), which has responsibility for water and sewer maintenance and development. Appendix F provides a summary of potential water and sewer infrastructure constraints for housing projects. As indicated, while increases in infrastructure capacity will be necessary to accommodate the sewer and water demands of future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The stormwater and sewer treatment facility at the Civic Center Lot, part of the City’s Sustainable Water Infrastructure Project (SWIP). 8.B.c Packet Pg. 111 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 19 City of Santa Monica | 2021 - 2029 Housing Element H. Summary Of Housing Programs For The 2021-2029 Housing Element This summary table is provided for convenient reference. More details regarding the programs, including program background can be found in Chapter 5. Program No Program Objective Timing GOAL 1 PROGRAMS 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. 1.A By-Right Approvals For Housing Projects The City shall make permanent amendments to the Zoning Ordinance that are currently interim and make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to allow, at a minimum: 1) 100% affordable housing projects; 2) non-Downtown housing projects that are code-compliant or are granted specified modifications/waivers to be established in the Zoning Ordinance; 3) Downtown housing projects that do not exceed Tier 2 maximums and are code-compliant or are granted specified modifications and waivers to be established in the Zoning Ordinance; and 4) housing projects that include at least 20% of units on-site as affordable to lower-income households [Government Code Section 65583.2(c)] , to be reviewed through a by-right process. . The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. Such by-right projects shall still be subject to design review, provided that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. The City shall extend interim zoning amendments for process thresholds pending the full implementation of this program. The City shall also develop written procedures to implement the streamlined review process for eligible projects under SB35. The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process. Provide certainty for housing providers by allowing a ministerial approval process based on objective standards for 100% affordable housing projects, housing projects that are code compliant or granted specified modifications, code- compliant Downtown housing projects that do not exceed Tier 2 maximums or are granted specified modifications, and housing projects eligible for by-right processing in accordance with State law. March 31, 2022 October 15, 2022 8.B.c Packet Pg. 112 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 20Chapter 1 | Introduction Program No Program Objective Timing 1.B Streamline The Architectural Review Process and Ensure Design Review Objectivity For Housing Projects The City shall adopt new streamlining procedures to allow staff level design review for smaller housing projects and expedited design review of larger housing projects by shifting the design review process to before or concurrently with entitlement issuance. This will reduce processing timelines and increase certainty for housing providers. These procedural changes would involve amending the Municipal Code to assure that design review cannot unreasonably delay a housing project approval by, for example, placing limits on number of hearings and maximum time limits for design review. The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. The amendments shall also be clear that design review cannot be used to reduce density or deny a housing project. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency anticipating compliance with SB35 for applicable housing projects. Streamlined housing approvals. September 30, 2022 Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022 1.C Incentivize Housing Development On Surface Parking Lots in Residential Zones In order to provide new housing choices and affordability in high opportunity areas, the City shall adopt standards that incentivize housing production on surface parking lots in residential zones associated with existing commercial uses, including, but not limited to, removing density caps and commercial parking replacement restrictions, lot consolidation, street access to the project, and restoring underlying maximum allowable density. The City shall also adopt standards that incentivize housing production on surface parking lots associated with existing residential uses as long as the existing residential use is not removed. Incentivize housing production on underutilized sites that would not displace existing tenants. August 1, 20223 1.D Reduce Minimum Parking Requirements for Housing Projects The City shall reduce minimum parking requirements for all housing projects by applying Parking Overlay 1 rates. Lower the cost of housing production August 1, 2022 June 30, 2023 1.E Revise The Design Standards In The Bergamot Area Plan (BAP) For Easier Understanding And To Support Housing Production The City shall modify the design guidelines in the BAP to establish objective standards to support housing production by increasing certainty for housing providers. The revisions to design standards will address at minimum: 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 to support housing production. The BAP should also consider the special housing needs of artists, such as live-work units, to promote artist residents in the Bergamot area. Provide clarity in the regulatory environment for housing and incentivize housing production in the Bergamot area. By June 30, 2023 8.B.c Packet Pg. 113 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 21 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 1.F Revise the Downtown Community Plan Development Standards To Support Housing Projects The City shall modify the development standards in the DCP to ensure they are set at levels that can support the minimum AHPP requirements and to support feasible housing projects. The City shall also amend the development standards and AHPP requirements to ensure Tier 2 and Tier 3 Downtown housing projects are feasible. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will promote housing and ensure feasibility and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR shown in the table below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement. The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Minimum Tier 1 FAR/Height with Rezoning Current Tier 2 FAR/Height Minimum Tier 2 FAR/Height with Rezoning Curent Tier 3 FAR/Height Minimum Tier 3 FAR/Height with Rezoning LT (East)12 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- LT (West)11 1.50/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- NV 31 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -4.0/84 ft BC (Promenade)12 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- BC (2nd/4th)25 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -- TA 52 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft 4.0/84 ft 4.0/84 ft OT 15 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- WT 6 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- Continue to encourage housing production in Downtown area. March 31, 2022October 15, 2022 8.B.c Packet Pg. 114 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 22Chapter 1 | Introduction Program No Program Objective Timing 1.G Incentivize and Facilitate the Development 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 prospective ADU developers property owners interested in constructing ADUs throughout all neighborhoods 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 further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year. Additionally, the City will review and update its locally adopted ADU Ordinance for consistency with State law. Streamline approvals and facilitate development of ADUs. December 31, 2022June 30, 2023 1.H Adaptive Reuse Of Existing Commercial Buildings For Permanent Residential Use As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to encourage and incentivize the adaptive reuse of existing commercial tenant space Citywide, for permanent residential use and also allow an adaptive reuse of existing ground floor commercial space for artists and live- work use. The City shall also adopt policy and zoning cChanges to incentivize the conversion of existing commercial tenant space to residential use include but are not limited to, such as relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements. Increase flexibility for reuse of vacant commercial space to residential use. December 31, 20234 1.I Ensure That Local Regulations Support Innovations In Construction Technology To The Extent Technically Feasible The City shall support innovative lower-cost, efficient and environmentally sustainable construction techniques for housing. Program shall implement a streamlined building permit review process for housing projects utilizing innovative construction methods and technology, and project-based outcome- oriented permitting benchmarks. Remove impediments to innovation in housing construction. December 31, 20234 1.J Rezoning by Revising Development Standards to Ensure that Housing Projects are Feasible and Incentivized Over Commercial Development The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.750 to 3.25 with heights ranging from 55 feet to 65 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will ensure feasibility and that promote housing to ensure overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR shown in the tables below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement Support the production of affordable housing and encourage the equitable production of housing across the City. March 31,Octoer 15, 2022 8.B.c Packet Pg. 115 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 23 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Minimum FAR/Height with Rezoning MUBL – N of I-10 107 1.50/36 ft 1.75/36 ft 3.25/70 ft MUBL – Pico 15 1.50/36 ft 1.75/36 ft 2.00/45 ft MUBL – Pico (West of Lincoln) 4 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL – Main St 10 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL - Lincoln 107 1.50/36 ft 1.75/36 ft 2.50/55 ft MUB 59 1.50/39 ft 2.25/50 ft 3.25/70 ft GC (SMB)24 1.25/ -1.50/35 ft 3.25/70 ft GC (Lincoln)19 1.50/36 ft 2.00/36 ft 2.50/55 ft GC (Pico)4 1.50/36 ft 2.00/36 ft 2.00/45 ft NC 27 1.50/32 ft N/A 2.25/50 ft NC (Main)14 1.00/27 ft N/A 2.50/55 ft NC (Ocean Park)15 1.00/32 ft N/A 2.50/55 ft NC (Montana)15 1.00/32 ft N/A 2.50/55 ft IC 77 N/A N/A 3.00/65 ft OC 88 N/A N/A 2.75/60 ft HMU 39 1.50/45 ft 2.50/70 ft 2.50/70 ft 8.B.c Packet Pg. 116 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 24Chapter 1 | Introduction Program No Program Objective Timing Bergamot Area # Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Current Tier 3 FAR/Height Minimum FAR/Height with Rezoning BTV 35 1.75/32 ft 2.00/60 ft 2.50/75 ft 4.0/84 ft MUC – South of Nebraska, North of Expo Bike Path 19 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft MUC - remainder 49 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft CCS 8 1.50/32 ft N/A N/A 2.50/55 ft CAC 17 1.00/32 ft 1.00/60 ft 1.00/75 ft 2.50/55 ft The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix requirements, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. 1.K Adequate Sites Program To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower incoe units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing are allowed 100 percent residential use and requiringe residential use to occupy at least 50 percent of the floor area. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City comply with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations. Create opportunity to accommodate the City’s lower-income RHNA targets August 1, 2022June 30, 2023 8.B.c Packet Pg. 117 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 25 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing GOAL 2 PROGRAMS Housing production for all income categories including for the community’s workforce and most vulnerable communities. 2.A Establish A Moderate-Income Affordable Housing Overlay The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate- income (up to 120% AMI) housing projects in targetedat leat three 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, 50% density bonus, up to four incentives and concessions, no minimum parking requirements, and flexibility in unit size/unit mix in exchange for additional common area amenities. Provide significant incentives for 100% affordable housing. August 1, 2022June 30, 2023 2.B Right Of First Offer Ordinance For Nonprofit Affordable Housing Providers Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, Tthe City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making nonprofit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildings through this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable. Support 100% affordable housing by assisting nonprofit affordable housing providers to be competitive in the land acquisition market. December 31, 20234 8.B.c Packet Pg. 118 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 26Chapter 1 | Introduction Program No Program Objective Timing 2.C Update The City’s Affordable Housing Production Program to Increase the Number of Affordable Housing Units at all Income Levels In order to increase the number of affordable housing units at all income levels such that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to maximize the contributions of the AHPP to achieving the RHNA affordable housing allocation and advancing the City’s affordable housing goals. Areas to be considered may include, but not be limited to: • Increase the threshold (to at least 6 units) at which projects are required to provide on-site or off-site affordable units; • Eliminate the current “menu” option of affordability requirements and instead establish a new base affordability percentage; • Re-evaluate the in-lieu fee option for applicants to pay a fee instead of constructing affordable units to ensure that the fee supports the funding and construction of new affordable housing throughout the City; and • Evaluate the possibility of a mixed-compliance option that would provide applicants more flexibility in meeting AHPP requirements. • Increase the minimum percentage of required off-site affordable units to be higher than the on-site option; • Allow projects to locate off-site affordable housing anywhere in the City that is not a disadvantaged area as defined by SB535, which includes socioeconomic and environmental metrics • Allow market-rate projects to comply with AHPP off-site option through acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Ensure that the AHPP provides housing developers viable options for compliance. June 30, 2022By April 30, 2023 2.D Update Density Bonus Ordinance to Ensure Consistency With State Law And Integration Into The City’s Land Use System 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 AHPP. The ordinance will clarify how to apply State density bonus law in the City’s commercial and mixed- use districts that do not have maximum density controls, including application of State density bonuses to floor area dedicated to residential uses. The amendments to the Municipal Code shall also set forth a voluntary by-right menu of incentives & concessions that do not require following the process under Government Code Section 65915(d) for approval. Requests for “off-menu” incentives and concessions may be requested pursuant to Government Code Section 65915(d). Ensure consistency with State Law. March 31October 15, 2022 8.B.c Packet Pg. 119 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 27 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 2.E Commit To The Production Of Affordable Housing On City-Owned/Publicly- Owned Land The City shall commit City-owned sites for the production of 100% affordable housing, with consideration of other community-serving purposes, including, but not limited, to green space, place making, and/or community-serving commercial and revenue generating uses. The City shall plan for a minimum of 1,8840 affordable housing units across available City-owned sites, which are located throughout the City, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first An RFP for at least one a city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months. Future RFPs shall be staggered based on availability of resources. As has been done in the past, the City will use a variety of tools Tto facilitate 100% affordable housing development, including but not limited to: • Facilitate appropriate zoning and process to support 100% affordable housing • Substantially reduced or free ground rent, the City will • Providing funding through local housing trust fund • Support applications for other funding sources for affordable housing (e.g. low-income- housing tax credits, grants, State funding, Federal funding) Further, 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. Prioritize affordable housing production on city-owned land. December 31, 2023 and Annual Ongoing 8.B.c Packet Pg. 120 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 28Chapter 1 | Introduction Program No Program Objective Timing 2.F New Affordable Housing Finance Programs To Enable Continued Provision Of Technical And Financial Assistance For Housing Production 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. The City has adopted policy on prioritizing our local funding through a Housing Trust Fund plan that includes spending commitments for affordable housing production and preservation for special needs and ELI households including exploring new funding for conversion to deed-restricted, multi-unit developments in areas of affluence. The plan outlines funding strategy for ELI households including seniors and persons living with disabilities. The City will continue to implement the policy and execute funding commitments to produce housing targeted to persons experiencing homelessness or at-risk of homelessness. Local funding through the Housing Trust Fund will also help support the production of at least 1,880 affordable housing productionunits on City-owned/publicly owned land in accordance with Program 2E. On an ongoing basis, the City will continue to communicate with local affordable housing providers on potential housing projects based on funding availability. Financial and technical assistance shall be provided when resources are available and committed to nonprofit housing providers to the greatest extent possible to support the development of affordable housing, including special needs housing and arts housing. The City will research 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. Seek innovative affordable housing financing tools to increase production. Annual ongoing 2.G Expand Housing Choice by Facilitating The Development And MaintenanceOf Special Needs Housing The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle. This includes the provision of new programs, services, infrastructure and amenities that can help seniors who choose to live independently remain in their homes as long as possible. Within legal constraints, encourage or require housing providers to assign affordable housing units designed for persons with disabilities, including physical or developmental disabilities, for use by those who require those features. The City shall encourage barrier-free construction and adaptation. Through the 5-year Consolidated Plan process, the City shall continue to identify housing and supportive service gaps for various special needs groups and propose policy and priorities based on the analysis. Housing for individuals with special needs. Annual ongoing 2.H Maintain Proposition I Monitoring The City shall monitor utilization of Proposition I authority through annual reporting of new “low rent- housing projects.” Ensure the City continues to report on compliance with Proposition I. Annual ongoing 8.B.c Packet Pg. 121 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 29 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 2.I Zoning For A Variety Of Housing Types Including Special Needs Housing And Housing Acces For Persons With Disabilities The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law as needed regarding special needs housing types and residential land use classifications as needed. Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty. Ensure the City is compliant with all State laws for special needs housing types and residential land uses. December 31, 20223 and Annual Ongoing 2.J Program 2.J Prioritize Water And Sewer Service To Housing Projects With On-Site Affordable Units The City shall establish written procedures to grant priority to developments with on-site units affordable to lower-income households if availability of service is limited. Prioritize infrastructure service to developments with lower income units to support the production of affordable housing throughout the City December 31 2022 GOAL 3 PROGRAMS Preservation of the existing supply of housing and prevent displacement of existing tenants. 3.A Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are Replaced The City shall amend the Municipal Code to adopt local requirements that make permanent and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced. As required by Government Code Section 65583.2(g)(3), the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity’s valid exercise of its police power (approximately 27,484 units), or (3) within the past five years were occupied by low or very low income households, shall be required to replace all of those units as affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth Government Code Section 65915(c)(3). Protect existing residents by preserving existing rental housing stock; no net loss of units. August 1, 2022Jine 30, 2023 8.B.c Packet Pg. 122 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 30Chapter 1 | Introduction Program No Program Objective Timing 3.B Develop Tenant and Landlord Programs To Address State And Federal Legislative Mandates Regarding Anti-Discrimination The City shall continue to implement programs throughout the City, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing in light of the loss of formerly affordable units due to vacancy de-control and Ellis withdrawals. The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles Develop programs to address State and Federal housing mandates. Annual ongoing 3.C Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing. There are approximately 770 affordable, deed-restricted units that are at-risk of conversion to market rate in the next 10 years. The City will continue to monitor over this Housing Element Cycle the status of of the approximately 770 affordable, deed-restricted at-risk projectsunits withinthroughout the City, ensure that required notice is given to tenants, and advise property owners and tenants in advance of potential conversion dates, and assist in answering questions from residents of at-risk housing. As a part of the ongoing monitoring, the City will continue to provide information on maintaining long-term affordability and assist federally-funded housing properties with seeking funding assistance in applying for allocations of housing vouchers from the federal government to maintain housing affordability. On an ongoing basis, the City will continue to communicate with local affordable housing providers on conserving housing projects. The City will exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. Additionally, the City shall continue to report annually on research and implement strategies on conserving non-covenant residential units such as the approximately 27,484 rent-controlled units and naturally occurring affordable units. The City proactively monitors units at risk of conversion due to expiring covenants and takes actions to ensure their long-term affordability. Annual ongoing 3.D Maintain An Acquisition And Rehabilitation Program 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 for acquisition and rehabilitation throughout the city. As outlined in Program 2.B, the City shall adopt a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer to acquire existing private properties as they become available for purchase. Protect existing residents by acquiring and rehabilitating existing housing. Annual ongoing 3.E Maintain A Low Income Residential Repair Program The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the City.. Rehabilitate 38 multi-unit dwellings and provide 20 minor home repairs. 2024 8.B.c Packet Pg. 123 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 31 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 3.F Enhance Code Enforcement Response To Housing-Related Violations The City shall continue to respond to residential building code violation complaints throughout the City. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day. Require property owners to respond to Building Code violations and complete routine maintenance on their residential buildings. Annual ongoing 3.G Maintain A Mandatory Seismic Retrofit Program The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle. Protect existing residents by ensuring the safety and structural integrity of existing residential buildings. Annual ongoing 3.H Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units The City shall provide additional education and outreach to multi-unit property owners on available City programs and support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties. Inform property owners regarding proper maintenance of residential units. Annual ongoing 3.I Right To Counsel Program The City shall continue to implement a Right to Counsel pilot program and evaluate its overall effectiveness, program capacity, and long-term feasibility. Prevent the displacement of tenants by providing access to legal assistance and support for tenants facing eviction. Ongoing 3.J Restrict Conversion Of Existing Rental Housing To Condominiums The City shall continue to regulate condominium conversions pursuant to SMMC Section 9.24.040. The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory. Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data. Restrict loss of rental housing units to condominium conversions Ongoing 8.B.c Packet Pg. 124 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 32Chapter 1 | Introduction Program No Program Objective Timing GOAL 4 PROGRAMS A community that provides equitable housing access to all neighborhoods. 4.A Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Non-Residential Zones Where Not Currently Permitted 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 amended to add multi-unit housing as a permitted use in areas where it is currently prohibited. Land use regulations, FAR, and Height (as indicated in Program 1.I) will be revised to allow housing in the three areas that currently do not allow housing such as the Office Campus, Industrial Conservation, and Creative Conservation Sector zones. To promote fair and equitable housing opportunities throughout the City, the City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) including in areas that have historically not permitted or accommodated housing, to allow for higher maximum allowable FAR and height in the NC, IC, and OC zoning districts. For the purposes of addressing environmental health considerations, the City shall amend the Zoning Ordinance to specify locations in the City where housing projects are required to conduct an air quality assessment and implement recommendations from the assessment. Support the production of affordable housing and encourage the equitable production of housing across the City. August 1, 2022October 15, 2023 4.B Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses 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 community assembly uses, including religious congregations including allowing not more than 50% market-rate units to support the affordable housing, unlimited density, no minimum parking requirements, an additional 33 feet of building height and allowance for the primary community assembly use and related ancillary use, for the support or expansion thereof, on or above the ground floor. Increase equitable access to all residential neighborhoods and not incentivize affordable housing in areas that have historically excluded diverse housing opportunities. August 1, 2022June 30, 2023 4.C Provide New Housing Choices and Affordability in High Opportunity Areas Through Incentives for Additional ADUs in R1-Zone Neighborhoods The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with program 4.F. This would include allowing an additional ADU to be constructed if the ADU is deed restricted as a rental unit. As ADUs are naturally more affordable by design given their size, the program would help affirmatively further fair housing by helping to provide new housing choices and affordability in high opportunity areas of the City that are largely unaffordable to many people. Increase equitable access to all neighborhoods through nominal density increases that may lower the barrier to housing access in areas that have historically excluded diverse housing opportunities. August 1, 2022June 30, 2023 8.B.c Packet Pg. 125 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 33 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 4.D Right to Return Program The City shall continue to implement a Right to Return Pilot Program and evaluate outreach strategies, applicant demand, the availability of historical documentation, verification processes, compliance with government legislation, and the administrative resources required to implement a broader long-term program. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. Address the historical displacement of Santa Monica households resulting from the development of the Civic Auditorium and I-10 freeway through the Pico neighborhood during the 1950s and 1960s that disproportionately impacted low-income communities and communities of color. Annual Ongoing 4.E Provide New Housing Choices and Affordability in High Opportunity Areas Through Incentives for SB9 Units in R1-Zone Neighborhoods The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. In addition, these SB9 units shall be required to be rented or sold. This will open up the possibility for property owners to construct up to 6 units through a multi-step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F. Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods. By June 30, 2023 4.F Establish Target to Increase Housing Production in R1 Zones and Include Mid-Cycle Monitoring The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. Increase the number of net new housing units in R1 zones Assess progress by December 31, 2025 8.B.c Packet Pg. 126 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 34Chapter 1 | Introduction Program No Program Objective Timing GOAL 5 PROGRAMS Housing for persons experiencing homelessness 5.A Reduce The Number Of Homeless Individuals Living On The Streets Of Santa Monica Through The Provision Of A Range Of Housing Options, With An Emphasis On Affordable, Permanent, Supportive Housing. The City shall continue to seek and leverage funds that contribute to the development of a range of permanent, supportive housing options, within and outside of Santa Monica. Focus case management and housing resources on the most chronic and vulnerable homeless individuals that have been identified on the City’s Homeless Service Registry. Continue to serve other priority homeless populations through City- funded programs. Continue strategies to reunite those not first-homeless in Santa Monica with family and friends in their home communities. Review City policies and practices that may contribute to homelessness. Continue to invest in and implement housing and supportive services to prevent and address the impacts of homelessness. Annual ongoing 5.B Low Barrier Navigation Centers As By-Right Use The City shall amend the Zoning Ordinance to allow Low Barrier Navigation Centers as a by-right permitted use in all non-residential zones permitting multi-unit uses. Ensure the City’s regulations and procedures are in conformance with State Law. December 31, 20223 GOAL 6 PROGRAMS 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. 6.A Enhance Housing Mobility By Maintaining Rental Housing Voucher Programs Throughout the City And Expand To Assist All Persons With Disabilities The City shall continue to operate strong rental housing voucher programs throughout the City and advocate for funding guidelines for Section 8 that are competitive for Santa Monica; and shall pursue additional funding to maintain and expand voucher programs, if possible. Review and update the Housing Authority Administrative Plan annually to ensure compliance with the latest HUD regulations and to provide flexibility to respond to tenants’ needs consistent with legal requirements. Utilize vouchers as a tool to prevent senior homelessness where eligible. When available funding opportunities are available, expand the rental housing voucher programs to fill the gap between income levels and the cost of housing for persons with permanent disabilities, including persons with Developmental Disabilities. Maintain voucher programs to ensure availability and choice of housing for households at all income levels. Annual ongoing 6.B Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance to for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle the extent feasible. Maintain housing stability for vulnerable individuals and households. Annual ongoing 8.B.c Packet Pg. 127 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 35 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 6.C Maintain And Expand The Preserving Our Diversity (POD) Program The City shall continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. The program shall ensure that POD subsidies do not result in an increase in rents. The City intends the POD Program to serve at least 150 participants within this Housing Element cycle. Assist POD beneficiaries in achieving a basic needs budget. Annual ongoing 6.D Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources The City shall prioritize additional education and outreach to tenants and landlords throughout the City 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. The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational events per year. Raise awareness of housing assistance programs and tenant and landlord rights and responsibilities. Annual ongoing subject to available staffing resources 6.E Maintain A Community Development Grant Program The City shall continue to fund supportive services that serve the priority homeless populations, striking a balance between existing programs that have demonstrated effectiveness and national best practices that are consistent with the City’s adopted Action Plan to Address Homelessness in Santa Monica. Maintain funding for programs that service priority homeless populations, lower-income households, and special needs populations. Annual ongoing 6.F Provide Tenant Relocation Assistance The City shall continue to implement the Tenant Relocation Assistance program; periodically review existing City policies and ordinances and recommend modifications if deemed necessary, including but not limited to, additional support in locating new housing for displaced residents upon relocation. The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica. Provide displaced tenants with cash- based relocation assistance. Annual ongoing 6.G Maintain A Temporary Relocation Program The City shall continue the Temporary Relocation Program, including program oversight and enforcement, and coordination in providing accommodations to minimize impacts to residents including emergency hotel vouchers for tenants who have been ordered to vacate their units by the City for code violations, safety improvements, or maintenance. The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated. Provide temporary housing for tenants displaced from their units due to required maintenance. Annual ongoing 8.B.c Packet Pg. 128 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 36Chapter 1 | Introduction Program No Program Objective Timing 6.H Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing The City shall maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws. Provide regulatory relief to enable housing access for disabled persons. Annual ongoing GOAL 7 PROGRAMS 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. 7.A Maintain Fair Housing Enforcement and Outreach ProgramThe City shall continue to implement fair housing programs. The City shall educate landlords about discrimination and educate the real estate community on the necessity of ensuring that their practices meet the objectives of the fair housing laws. The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide and tenant application assistance and support to special needs populations including seniors, persons with disabilities, and individuals transitioning from institutional settings and individuals who are at risk of institutionalization. Education of tenants and landlords of their rights and responsibilities under fair housing laws. Annual ongoing 7.B Provide Tenant/Landlord Mediation And Legal ServicesThe City shall continue to support tenant/landlord mediation and legal services assistance. Provide tenant/landlord dispute resolution services. Annual ongoing 7.C Maintain The Anti-Discrimination Tenant Protection Program The City shall continue to prevent discrimination, tenant harassment, and unlawful evictions through monitoring and enforcing of “just cause” eviction protections, and continue to provide fair housing services through the Public Rights Division of the Santa Monica City Attorney’s Office. The City shall review current laws and recommend any needed modifications to ensure protection of tenants to the maximum extent possible. Protect existing tenants from harassment and unlawful eviction. Annual ongoing 8.B.c Packet Pg. 129 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions Image 8.B.c Packet Pg. 130 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Assessment of Fair Housing in the City 8.B.c Packet Pg. 131 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 39 City of Santa Monica | 2021 - 2029 Housing Element Chapter 2: Assessment of Fair Housing in the City Housing is a human right – unfortunately though, many segments of our population do not have access to safe and affordable housing. Even when such housing is available, these units may not be located in areas that are in proximity to good jobs, easily accessible public transit, and other fundamental community features such as schools and open space. In recognition of the housing inequalities that endure to this day, the State legislature passed AB 636 (2018) to require cities and counties to advance social equity through meaningful actions that affirmatively further fair housing (AFFH). This chapter of the Housing Element provides an assessment of fair housing in the City as well as programs and policies to combat “discrimination, overcome patterns of segregation, and foster inclusive communities free from barriers that restrict access to opportunity based on protective characteristics.” The information provided in this chapter references and supplements the analysis in the City of Santa Monica’s Assessment of Fair Housing (AFH) that was prepared in accordance with U.S. Department of Housing and Urban Development requirements and adopted in April 2020. The Assessment of Fair Housing (AFH) which is attached as Appendix I is a thorough examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups protected from discrimination by the federal Fair Housing Act (FHA). Redlining The term “redlining” refers to the discriminatory policy instituted by the federal government to create color-coded maps of every metropolitan area in the country to indicate where it was safe to insure mortgage. These maps were based on racial composition, quality of housing stock, access to amenities, etc. and were color coded to identify best (green “A” grade), still desirable (blue “B” grade), definitely declining (yellow “C” grade), and hazardous (red “D” grade) neighborhoods. Areas of the City that were predominantly commercial/industrial were not color coded. 8.B.c Packet Pg. 132 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 40Chapter 2 | Assessment of Fair Housing in the City A. Historical Practices and Policies Leading to Segregation The established neighborhoods of the City today are largely the result of decades of structural racism deeply rooted in Federal, State, and local housing policies. In the early days of Santa Monica, the City had a sizeable population of Blacks/African Americans, who had moved into the City from the 1890s to the early 20th century, as part of larger westward migration patterns based in part on the prospect of new economic opportunities and community available in California. Additionally, beginning in 1904, the job opportunities at the City’s clay pit operations in the eastern portion of the City drew new Mexican immigrants. However, Blacks/African Americans, Mexicans, and other racial and ethnic groups, were met with racism from White residents in the City. In 1922, homeowners formed the Santa Monica Bay Protective League with an agenda of “eliminating all objectionable features or anything that now is or will prove a menace to the bay district ... or prove detrimental to our property values.” One of the ways that this was achieved was through racial covenants on deeds. Local government also contributed to the patterns of segregation through the adoption of exclusionary zoning. When Blacks/African Americans tried to build a Jazz Club in the Belmar area in the 1920s, City officials used zoning laws to block the project. Single-unit zoning was also seen as a way tool to economically separate the wealthier Whites from Blacks/African Americans and other racial and ethnic groups, including Italians, Japanese, Mexicans, Portuguese and, later Jews. Since many people of color could not afford or were unable to receive mortgages for owning homes, they were excluded from single-family zoned neighborhoods. Today approximately, 35% of all the land in the City is zoned for single-family homes, and very few people of color live in these zones (see Appendix B). This type of discrimination at the local level was bolstered by the federal policy of “redlining” that arose during the New Deal era (1930s). The color-coded maps were first used by the Home Owners’ Loan Corporation (HOLC) and then the Federal Housing Administration (FHA) and then adopted by the Veterans Administration (VA). This discriminatory practice of determining who could qualify for home mortgages based on race, ethnicity, religion, or immigrant status led to widespread segregated communities across the country, and prohibited Burning a derelict house on Belmar Place on July 1, 1953 Source: Santa Monica Public Library 8.B.c Packet Pg. 133 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 41 City of Santa Monica | 2021 - 2029 Housing Element people of color from buying homes. In Santa Monica, areas that were redlined included the Pico Neighborhood, portions of the Mid City neighborhood south of Santa Monica Boulevard, and Ocean Park. Areas that were color-coded green or blue generally consisted of the single- family zoned neighborhoods such as the North of Montana and Northeast neighborhoods (Map 2-1). Map 2-1: Formerly “Redlined” Areas and Single Family Zoning in the City of Santa Monica In the post-World War II era, the local and Federal government further intensified segregation through the systematic construction of government buildings and 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 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. Santa Monica government officials in the 1950s to 1960s also targeted multiethnic neighborhoods in their plans to modernize the City. The City’s Civic Center today sits atop the historic Belmar Triangle, (which encompassed the area bound by the former trolley line on the north and west [southern part of Main Street today], Fourth Street on the east, and Pico Boulevard on the south). Historically, 8.B.c Packet Pg. 134 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 42Chapter 2 | Assessment of Fair Housing in the City the Belmar Triangle was home to many African American families and other families of color who migrated to Santa Monica.1 Through eminent domain proceedings, the Belmar Triangle was razed to build the Santa Monica Civic Auditorium and part of the Los Angeles County Courthouse grounds. The City’s annual reports claimed that the Belmar area was “blighted” and that only substandard and dilapidated structures and dwellings were burned down and removed for health and safety reasons.2 Over the years, the development of lower-cost affordable housing has largely followed historic patterns of segregation. Map 2-2 shows the redlining boundaries overlaid with affordable housing that has been constructed or acquired/rehabilitated over the years. Of the affordable units that have been constructed over the years, 49% are in the City’s former redlined areas (which make up 24% of the City). Map 2-2: Affordable Housing and Formerly “Redlined” Areas in the City of Santa Monica 1 Alison Rose Jefferson, PH.D., The Erased African American Experience in Santa Monica’s History; https://alisonrosejefferson.com/wp-content/uploads/2021/02/Jefferson.ReconstructionAndReclamation.FINAL_.12.22.2020.pdf2 Ibid 8.B.c Packet Pg. 135 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 43 City of Santa Monica | 2021 - 2029 Housing Element B. Integration and Segregation Patterns and Trends 1. Race and Ethnicity The greater Los Angeles metropolitan area is a melting pot of different cultures, races, and backgrounds. Unlike the our larger, neighboring City of Los Angeles, Whites still make up the majority of the City of Santa Monica’s population. ESRI (an international supplier of geographic information system (GIS) software) tracks the shifting demographics of race and ethnicity of communities through its Diversity Index. The index shows the likelihood that two people, chosen at random from the same area, belong to different race or ethnic groups. The index ranges from 0 (no diversity) to 100 (complete diversity). For example, a diversity index of 59 means there is a 59 percent probability that two people randomly chosen would belong to different race or ethnic groups. As shown in Map 2-3, the City’s census tracts have lower diversity indices than most of the surrounding Los Angeles region. While the City is generally less diverse than the region as a whole, census data shows that the City’s racial makeup is becoming more diverse. As shown in Figure 2-1, Hispanics/Latinos make up the second largest racial group in the City, followed by Asians. In terms of the racial/ethnic makeup by census tract, there are more predominant populations of Hispanic/Latino residents in the Pico Neighborhood while the remaining areas of the City are predominantly White, Map 2-4 and Map 2-5. Defining Integration and Segregation Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area. Segregation generally means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area. 8.B.c Packet Pg. 136 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 44Chapter 2 | Assessment of Fair Housing in the City Figure 2-1: Santa Monica Population by Race and Ethnicity Category 2000 %2010 %2018 %2019 % White 60,482 71.9%62,917 70.1%59,197 64.3%59,200 64.3% Hispanic or Latino 11,304 13.4%11,716 13.1%14,613 15.9%14,097 15.3% Black or African American 3,081 3.7%3,364 3.7%3,950 4.3%3,995 4.3% Asian 6,043 7.2%7,960 8.9%9,004 9.8%9,018 9.8% Two or more races 2,584 3.1%3,174 3.5%4,782 5.2%4,571 5.0% Other 590 0.7%605 0.7%532 0.6%696 0.8% TOTAL 84,084 89,736 92,078 91,577 Map 2-3: Diversity Index 8.B.c Packet Pg. 137 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 45 City of Santa Monica | 2021 - 2029 Housing Element Map 2-4: Racial and Ethnic Majority by Census Tract Map 2-5: Population Distribution of Non-Whites 8.B.c Packet Pg. 138 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 46Chapter 2 | Assessment of Fair Housing in the City 2. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) and Affluence (RCAA) R/ECAPs R/ECAPs are geographic areas with significant concentrations of poverty and minority populations. HUD has developed a census-tract based definition of R/ECAPs. In terms of racial or ethnic concentration, R/ECAPs are areas with a non-White population of 50 percent or more. With regards to poverty, R/ECAPs are census tracts in which 40 percent or more of individuals are living at or below the poverty limit or that have a poverty rate three times the average poverty rate for the metropolitan area, whichever threshold is lower. Households within R/ECAP tracts frequently represent the most disadvantaged households within a community and often face a multitude of housing challenges. R/ ECAPs are meant to identify where residents may have historically faced discrimination and continue to be challenges by limited economic opportunity. Map 2-6: Racially or Ethnically Concentrated Areas of Poverty and Areas of High Segregation & Poverty 8.B.c Packet Pg. 139 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 47 City of Santa Monica | 2021 - 2029 Housing Element While there are no R/ECAPs within the City of Santa Monica (Map 2-6), the legacy of past racist planning and housing policies have shaped land use patterns in the City that we see today. There are census tracts in the City that have higher concentrations of non-Whites as well as higher concentrations of low income and moderate income population. In general, the patterns of non-White and lower income households continue to mirror the redline maps with more affluent Whites on the northern and southern ends of the City (Map 2-4) and non-Whites and lower income populations concentrated in the central city near the main transportation corridors (Map 2-7). Map 2-7: Low to Moderate Income Population by Census Tract This pattern of segregation is also true for renter versus ownership households. The 2020 AFH found that the location of renters and owners in Santa Monica very highly correlates with patterns of residential racial and ethnic segregation. The areas with the highest concentrations of homeownership, such as north of Montana, Ocean Park, and Sunset Park are also the areas that are predominantly White. The areas with the highest concentrations of renters, such as the Pico neighborhood and Downtown, are areas that contain high concentrations of minorities and/or those with Limited English Proficiency. The AFH also found that a major contributor to continued racial and ethnic segregation is the economics of high housing and land costs created by zoning, which particularly limits the feasibility of developing of affordable housing in certain areas of the City. 8.B.c Packet Pg. 140 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 48Chapter 2 | Assessment of Fair Housing in the City Map 2-8: Renter Households by Census Tract RCAA Racially or Ethnically Concentrated Areas of Affluence (RCAAs) are neighborhoods in which there are both high concentrations of non-Hispanic White households and high household income rates.3 Census tracts that have median income over $132,844 and have 80% of its households as non-Hispanic white are considered RCAAs. As discussed previously, non-Hispanic Whites are the predominant racial/ethnic group in the City, with more predominance in the northern and southern ends of the City. Additionally, the median household income in most census tracts throughout the City is lower than the RCAA income threshold. However, several census tracts have a median household income above $132,844 (Map 2-9). The three census tracts with median household income above $132,844 and have at least 80% of its households characterized by non-Hispanic Whites are located in Northeast area of the City, as shown in Map 2-10. 3 In response to the R/ECAPs utilized by HUD in its 2015 AFFH rule, scholars at the University of Minnesota Humphrey School of Public Affairs have created the Racially Concentrated Areas of Affluence (RCAAs) metric to more fully tell the story of segregation in the United States.64 Based on their research, RCAAs are defined as census tracts where 1) 80 percent or more of the population is white, and 2) the median household income is $125,000 or greater (slightly more than double the national the median household income in 2016). While this is a useful measure nationwide, HCD has adjusted the RCAA methodology to better reflect California’s relative diversity. 8.B.c Packet Pg. 141 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 49 City of Santa Monica | 2021 - 2029 Housing Element Map 2-9: Median Household Income Over $130,844 Map 2-10: Racially or Ethnically Concentrated Areas of Affluence 8.B.c Packet Pg. 142 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 50Chapter 2 | Assessment of Fair Housing in the City 3. Disability Status A “disability” is defined as a long-lasting physical, mental, or emotional condition. This can include those with vision, hearing, ambulatory, cognitive, self-care, and independent living disabilities. As further detailed in Appendix B, there are 8,841 Santa Monica residents with at least one disability in 2019. Map 2-11 shows the population of persons with a disability by census tract in the City. The map reveals a slightly higher concentration of residents with disabilities in Downtown and the census tracts to the north and east. This may indicate that persons with a disability have a slight preference for areas nearer to the beach – likely due to a combination of elderly housing sites, concentration of amenities including public transportation, and population density near the coast. As described in the 2020 AFH report, the primary option for affordable housing for people with disabilities is Housing Choice Vouchers, of which people with disabilities make up more than 50% of residents. In 2020, five hundred twenty-two (522) people with disabilities reside in units assisted with Housing Choice Vouchers in Santa Monica, but this does not represent a proxy for actual affordable, accessible units. Rather, Housing Choice Vouchers are a mechanism for bringing otherwise unaffordable housing, which may or may not be accessible, within reach of low-income people with disabilities. Map 2-11: Persons with a Disability 8.B.c Packet Pg. 143 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 51 City of Santa Monica | 2021 - 2029 Housing Element 4. Familial Status The Fair Housing Act (FHA) bans discrimination based on certain protected classes, including “familial status” which refers to households with at least one child under 18 years old. Appendix B indicates that in 2019, there were 7,750 family households with children under 18 years of age representing 17% of the City’s total households. Of this number, 5,716 are married couple family households, 1,381 are Female-Headed Households (no spouse), and 653 are Male-headed households (no spouse). Married couple families predominantly reside in the R-1 neighborhoods of the City as compared to single female headed families who are located in R-2 and R-3 neighborhoods. Map 2-12: Married Couple Family Households with Children Under 18 45,309 Households in the City 17% Family Households with Children Under 18 26% Family Households with Children are Single Parent (no spouse) 8.B.c Packet Pg. 144 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 52Chapter 2 | Assessment of Fair Housing in the City Map 2-13: Female Headed Households with Children Under 18 C. Disparities In Access To Opportunity Where a person lives greatly influences their life outcomes. Housing and neighborhood choice are cornerstones of measuring fair housing and resident stability. A person’s educational attainment, economic mobility, health and well-being, to name a few, are directly impacted by exposure to poverty, neighborhood condition, and access to key opportunities such as high quality schools, jobs, transportation, economic development, and a healthy physical environment. Several agencies, including HUD and HCD in coordination with the California Tax Credit Allocation Committee (TCAC), have developed methodologies to assess and measure geographic disparities in access to opportunity (including education, poverty, transportation, and employment, and environmentally healthy neighborhoods) for areas throughout California. HUD’s opportunity indices compare data indicators by race and ethnicity, for households below the poverty line, between jurisdictions and for the region overall. Figure 2-2 provides the City’s opportunity indices by census tracts or census block groups and Figure 2-3 provides indices by race. 8.B.c Packet Pg. 145 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 53 City of Santa Monica | 2021 - 2029 Housing Element Figure 2-2: Santa Monica Access to Opportunity Indices Census Tract Block Group School Proficiency Jobs Proficiency Labor Market Index Low Transportation Cost Environmental Health Low Poverty Index 701201 1 98 87 81 86 19 86 2 96 91 3 96 91 4 98 87 5 98 91 701202 1 96 92 97 74 7 7429893 701302 1 97 94 98 69 6 69 2 97 93 701304 1 99 88 97 70 0 7029891 3 99 92 4 97 93 701402 1 98 94 90 61 0 6129893 3 98 93 4 97 94 701501 1 96 94 96 77 4 7729895 3 97 94 701502 1 85 94 87 57 3 5728595 3 97 94 701601 1 66 93 95 93 8 9329693 3 96 93 4 96 93 701602 1 85 94 98 54 3 5428593 3 85 94 701701 1 85 94 73 64 3 6428594 3 85 94 8.B.c Packet Pg. 146 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 54Chapter 2 | Assessment of Fair Housing in the City Census Tract Block Group School Proficiency Jobs Proficiency Labor Market Index Low Transportation Cost Environmental Health Low Poverty Index 701702 1 85 94 91 31 3 31 2 85 95 3 97 94 701801 1 84 95 50 46 4 46 2 87 94 3 87 94 4 87 94 5 85 94 701802 1 84 94 44 40 5 4028494 3 71 94 4 73 95 701902 1 95 93 61 39 0 3929593 3 89 93 702002 1 48 93 87 55 0 5527692 3 76 93 4 76 93 702102 1 48 88 89 59 0 59 2 76 85 3 76 87 4 48 88 5 76 89 6 76 89 7 76 87 702201 1 90 92 92 71 8 7128591 3 85 93 4 71 93 5 71 91 8.B.c Packet Pg. 147 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Census Tract Block Group School Proficiency Jobs Proficiency Labor Market Index Low Transportation Cost Environmental Health Low Poverty Index 702202 1 85 87 94 70 7 70 2 90 89 3 90 86 4 90 87 5 85 89 702300 1 93 93 84 65 4 65 2 70 89 3 93 92 4 93 93 5 93 93 Figure 2-3: Summary of the Opportunity Indicators by Race (Santa Monica, CA CDBG) Jurisdiction School Proficiency Index Labor Market Index Jobs Proximity Index Transit Index Low Transportation Cost Index Low Poverty Index Environmental Health Index Total Population White, Non-Hispanic 86.33 87.43 92.18 87.66 93.17 64.91 13.74 Black, Non-Hispanic 84.72 75.22 93.11 87.29 94.69 54.14 11.93 Hispanic 84.48 76.93 92.79 87.25 94.17 58.25 11.62 Asian or Pacific Islander, Non-Hispanic 86.66 83.66 92.59 87.15 93.36 63.72 12.73 Native American, Non-Hispanic 83.10 81.09 92.34 87.47 94.50 57.87 11.69 Population below federal poverty line White, Non-Hispanic 85.69 84.64 92.66 87.88 94.52 59.57 13.05 Black, Non-Hispanic 84.21 64.98 93.53 86.65 95.30 47.35 11.71 Hispanic 82.94 65.98 93.39 86.56 94.37 52.04 10.14 Asian or Pacific Islander, Non-Hispanic 84.85 83.21 92.67 86.81 93.67 57.06 10.83 Native American, Non-Hispanic 80.85 81.52 92.92 88.49 95.84 47.65 12.84 (Los Angeles-Long Beach-Anaheim, CA) Region Total Population White, Non-Hispanic 67.87 67.43 54.59 76.59 79.87 65.19 21.35Black, Non-Hispanic 31.89 35.34 40.72 81.34 83.42 36.07 11.92 Hispanic 37.09 35.73 43.70 80.65 83.98 35.53 12.36 Asian or Pacific Islander, Non-Hispanic 62.18 57.64 51.11 78.82 82.35 55.03 13.13 Native American, Non-Hispanic 49.49 48.58 45.88 78.04 81.53 48.40 17.68 Population below federal poverty line White, Non-Hispanic 59.42 59.62 56.98 80.43 84.23 53.66 18.46 Black, Non-Hispanic 24.68 26.41 36.90 83.34 85.48 24.12 11.74 Hispanic 30.68 29.50 44.63 83.28 86.96 25.05 10.63 Asian or Pacific Islander, Non-Hispanic 57.18 51.41 52.88 82.27 86.69 45.45 11.05 Native American, Non-Hispanic 37.54 36.05 47.65 80.82 84.18 33.63 16.22 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; NATANote 2: To generate this table, index values were calculated for each census tract. These tract values were averaged and then weighted based on the distribution of people of different races and ethnicities within the CDBG jurisdiction, HOME jurisdiction, or CBSA to generate composite index values for each race and ethnicity. A similar process was applied to weight the data based on the distribution of people of different races and ethnicities who are living below the federal poverty line within the CDBG or HOME jurisdiction and CBSA. The population estimates are based on the 2010 Decennial Census at the census tract or block-group level, depending on the geographic level at which the index was originally calculated. Released June 2020 TCAC has also prepared opportunity maps to identify areas with the highest and lowest resources. The high resource areas are those areas, according to research, that offer low-income children and adults the best chance at economic advancement, high educational attainment, and good physical and mental health. As shown in Map 2-14 below, the City is generally considered a high resource, with census tract 701802 and 701801 having slightly less resource than the remaining areas of the City. Map 2-14: High Resource Areas 8.B.c Packet Pg. 148 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions 56Chapter 2 | Assessment of Fair Housing in the City White, Non-Hispanic 67.87 67.43 54.59 76.59 79.87 65.19 21.35 Black, Non-Hispanic 31.89 35.34 40.72 81.34 83.42 36.07 11.92 Hispanic 37.09 35.73 43.70 80.65 83.98 35.53 12.36 Asian or Pacific Islander, Non-Hispanic 62.18 57.64 51.11 78.82 82.35 55.03 13.13 Native American, Non-Hispanic 49.49 48.58 45.88 78.04 81.53 48.40 17.68 Population below federal poverty line White, Non-Hispanic 59.42 59.62 56.98 80.43 84.23 53.66 18.46 Black, Non-Hispanic 24.68 26.41 36.90 83.34 85.48 24.12 11.74 Hispanic 30.68 29.50 44.63 83.28 86.96 25.05 10.63 Asian or Pacific Islander, Non-Hispanic 57.18 51.41 52.88 82.27 86.69 45.45 11.05 Native American, Non-Hispanic 37.54 36.05 47.65 80.82 84.18 33.63 16.22 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; NATANote 2: To generate this table, index values were calculated for each census tract. These tract values were averaged and then weighted based on the distribution of people of different races and ethnicities within the CDBG jurisdiction, HOME jurisdiction, or CBSA to generate composite index values for each race and ethnicity. A similar process was applied to weight the data based on the distribution of people of different races and ethnicities who are living below the federal poverty line within the CDBG or HOME jurisdiction and CBSA. The population estimates are based on the 2010 Decennial Census at the census tract or block-group level, depending on the geographic level at which the index was originally calculated. Released June 2020 TCAC has also prepared opportunity maps to identify areas with the highest and lowest resources. The high resource areas are those areas, according to research, that offer low-income children and adults the best chance at economic advancement, high educational attainment, and good physical and mental health. As shown in Map 2-14 below, the City is generally considered a high resource, with census tract 701802 and 701801 having slightly less resource than the remaining areas of the City. Map 2-14: High Resource Areas 8.B.c Packet Pg. 149 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 57 City of Santa Monica | 2021 - 2029 Housing Element The City’s designation as a high resource area is largely attributed to the availability of high performing schools, numerous employment opportunities, easy access to low cost transportation, and environmentally healthy neighborhoods. The analysis of Access to Opportunity summarized below is based on the AFH: 1. Access to Schools Since there are only three middle/high schools in Santa Monica, disparities in school proficiency are most relevant to elementary school education. This is especially true because elementary school education builds the foundation for success in secondary and post-secondary education, and those without a strong foundation often struggle to catch up to their peers as they mature. As illustrated by Map 2-15, the northern half of the City has significantly higher school proficiency index numbers than the southern half, with a notable dip in proficiency in the Pico, Mid-City, and Ocean Park neighborhoods. This closely correlates with wealthier households, single-unit zoning, and concentrations of White households. Despite these internal disparities, children in the City regardless of race generally have very high access to proficient schools, with most school proficiency index numbers above the 70s. With such proficient schools, Santa Monica generally far outperforms the region as a whole. Map 2-15: School Proficiency Index Map 2. Access to Employment In the City of Santa Monica, disparities in job proximity are generally modest with Black residents 8.B.c Packet Pg. 150 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 58Chapter 2 | Assessment of Fair Housing in the City experiencing greater slightly greater job proximity followed by Hispanic and Asian American and Pacific Islander residents, with White residents having the lowest job proximity. This indicates that people of color in the City are more likely to live closer to their jobs, within the commercial areas. With respect to labor market engagement, disparities are somewhat larger. The order in which groups live in neighborhoods with high labor market engagement is, for the most part, reversed (meaning that Whites tend to live in areas with higher labor market engagement while population of color tend to live in areas with lower labor market engagement). One qualification to that overall trend is that Asian Americans and Pacific Islanders live in areas with significantly higher labor market engagement than do Hispanics. In the City of Santa Monica, disparities in labor market engagement, but not in job proximity, are driven by residential patterns. Black and Hispanic residents, including residents of Mexican national origin, are disproportionately likely to live in the Pico neighborhood while areas such as North of Montana, North of Wilshire, and Sunset Park are more heavily White. As shown in Map 2-16, two Census Tracts that include parts of the Pico neighborhood have Labor Market Indices of 44 and 50, respectively. Of the nine Block Groups in those two Census Tracts, seven are majority non-White. At the same time, the vast majority of Block Groups in Census Tracts with Labor Market Indices of 90 or above have White population concentrations of 70% or more. White residents live in areas that, by far, have the highest labor market engagement. Asian American and Pacific Islander residents live in areas with significantly lower labor market engagement, but the difference is most dramatic for Black and Hispanic residents. In the region, there are virtually no differences in job proximity by race and ethnicity. Hispanic residents have slightly lower job proximity than other groups, but the disparity is minute. With respect to labor market engagement, however, there are significant disparities. In the region, areas with high labor market engagement are areas with disproportionately high White populations including the City of Santa Monica, westside neighborhoods within Los Angeles such as West Los Angeles, and adjacent cities like West Hollywood and Beverly Hills; neighborhoods of Los Angeles within communities in the southern or western portion of the San Fernando Valley including like Sherman Oaks, Encino, Tarzana, and Woodland Hills; the cities of Pasadena; Manhattan Beach, Hermosa Beach, Redondo Beach, and Palos Verdes in southern Los Angeles County; and most of Orange County outside of the diverse communities of Anaheim, Garden Grove, Santa Ana, and Westminster. Map 2-16: Labor Market Engagement Index Map 8.B.c Packet Pg. 151 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 59 City of Santa Monica | 2021 - 2029 Housing Element 3. Access to Transportation The City of Santa Monica has very high levels of utilization of transit. Overall, as shown in Map 2-17, there is very good access to low-cost public transportation, with high transportation indices (i.e., high access to transportation) for the census tracts located along the City’s major boulevards (Wilshire Boulevard, Santa Monica Boulevard, Colorado Avenue). The areas with the lowest access to low-cost transportation (lowest transportation cost index), such as the northeast tract, also have the lowest levels of public transit utilization. Santa Monica is serviced by the Metro “E” (Expo) Light Rail Line, which directly connects Santa Monica to Downtown Los Angeles by rail, and provides for additional rail access to as well as Pasadena, the San Fernando Valley, the South Bay, Long Beach, and points in between. The City is also serviced by Big Blue Bus, which departs the LAX City Bus Center with two lines that run through Santa Monica. These connections to and the extensive LA Metro bus system and light rail network help to make the Region’s transportation system fairly integrated. Santa Monica is fairly small and compact, and well-serviced by public transport. There do not seem to be any great disparities based on residential living patterns. In the Region, however, disparities in access to transportation are far more evident, and heavily dependent on residential living patterns. Map 2-17: Low Transportation Cost Index Map 8.B.c Packet Pg. 152 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 60Chapter 2 | Assessment of Fair Housing in the City 4. Access to Low Poverty Neighborhoods In the City of Santa Monica, access to low poverty neighborhoods is closely linked to residential patterns of racial and ethnic concentration. Map 2-18 shows the low poverty indices for the City. The areas with the lowest Low Poverty Indices and thus the highest concentrations of poverty are in the Pico neighborhood and the immediate vicinity of Downtown Santa Monica. These areas have higher concentrations of Black and Hispanic households than the city as a whole. By contrast, the North of Wilshire and North of Montana neighborhoods, with higher White populations, both have higher Low Poverty Indices and thus lower concentrations of poverty In the City of Santa Monica, Black and Hispanic households have lower access to low poverty neighborhoods than do White and Asian American or Pacific Islander households. The disparities are significant but not extreme. Map 2-18: Low Poverty Index 5. Access to Environmentally Healthy Neighborhoods Map 2-19 which shows the Environmental Health Hazard indices across the City and substantiates the view that there are significant differences in environmental health between neighborhoods and that those disparities are correlated with neighborhood demographics. The eastern area of NOMA and Northeast neighborhood of the City are the most environmentally healthy than other areas in the City, and have the highest environmental health indices. The Pico neighborhood, current and former industrial areas of the Industrial Conservation zones, and Downtown Santa Monica are more heavily affected by their proximity to the I-10 freeway than are more heavily White neighborhoods 8.B.c Packet Pg. 153 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 61 City of Santa Monica | 2021 - 2029 Housing Element like North of Wilshire and North of Montana. The Pico neighborhood and Downtown Santa Monica have the lowest Environmental Health Hazard indices, indicating adverse environmental conditions, while the North of Montana neighborhood has the highest indices (Map 2-19). Map 2-19: Environmental Health Index Green spaces like Reed Park help to improve the health of a neighborhood, whereas industrial uses like the City Yards in the Pico neighborhood negatively impact the health of a neighborhood. 8.B.c Packet Pg. 154 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 62Chapter 2 | Assessment of Fair Housing in the City D. Disproportionate Housing Needs Disproportionate Housing Needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. According to the California Department of Housing and Community Development, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions. 1. Cost Burden and Overpayment The general rule is that no more than 30% of gross monthly income should be spent on housing. Households that spend more than this percentage are considered to be “housing cost burdened”. Severely cost burdened households are those households spending greater than 50% of income on housing. As further detailed in Appendix B and shown below, renter households are significantly more cost-burdened compared to homeowners, with 31.6 percent of renter households burdened by housing costs compared to 9.5 percent of owner households, as shown by Figure 2-4. The areas with the most cost burdened renter households are located in Downtown, and the areas along the I-10 freeway (Map 2-20), while the areas with the most cost burdened owner households are located in the Downtown, north of Downtown, and a couple census tracts south of the I-10 freeway (Map 2-21). Figure 2-4: Cost Burden and Overpayment for Renters and Homeowners Households Renters Owners Total Renters and Owners Cost Burdened Total Cost Burdened Total Cost Burdened % of Citywide Extremely Low Income (0-30% AMI)5,055 6,145 825 975 7,120 15.4% Very Low Income (31-50% AMI) 2,815 3,320 555 770 26,490 8.8% Low Income (51-80% AMI)2,880 4,220 725 1,180 5,400 11.6% Moderate Income (80-100% AMI)1,690 2,685 320 570 7,120 7.0% Above 100% AMI 2,220 17,135 2,020 9,355 26,490 57.1% Total 14,660 33,505 4,445 12,855 46,360 15.4% 8.B.c Packet Pg. 155 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 63 City of Santa Monica | 2021 - 2029 Housing Element % of Total Households 31.6%9.5% Map 2-20: Cost Burdened Renter Households Map 2-21: Cost Burdened Owner Households 8.B.c Packet Pg. 156 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 64Chapter 2 | Assessment of Fair Housing in the City Even after the 1968 passage of the Fair Housing Act, people of color have continued to experience housing inequalities across the nation and within the City. As described in Appendix B Housing Needs Assessment, Black/African American and Hispanic/Latino households in the City have the lowest homeownership rates at 8% and 18%, respectively, far less than the 30% home ownership rate for White households. Additionally, these households of color pay a greater share of their income towards housing costs given that they have the lowest median household incomes. In the City, Black/African American and Hispanic/Latino households have median incomes of $42,703 and $71,483 respectively, far below the citywide median of $96,570 (Figure 2-5). With the high cost of housing coupled with low wages, approximately 11.7% of Black and 8.6% of Hispanic/Latino family households in the City were cost- burdened even before the COVID19 pandemic. These cost-burdened households are at greater risk of poverty and homelessness. Figure 2-5: Median Household Income by Race Hispanic or Latino White Alone,Not Hispanic Black Asian Two or More Races Some Other Race $109,528 $71,483 $100,691 $42,703 $105,395 $64,444 2. Overcrowding Appendix B provides data on household size and overcrowding. The average household size in the City is 1.99. A housing unit that is occupied by more than one person per room (excluding kitchens, bathrooms, hallways and porches) is defined by U.S. Department of Housing and Urban Development (HUD) as being overcrowded. In 2019, 185 owner occupied households and 1,360 renter occupied households were determined to be overcrowded for a total of 1,545 households (3.2% of total City households). Map 2-22 shows the trends of overcrowded households in the City by census tract. The tract with the most overcrowded households located in Downtown. The percentages of overcrowded households for all census tracts in the City are less than the statewide average of 8.2 percent. 8.B.c Packet Pg. 157 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 65 City of Santa Monica | 2021 - 2029 Housing Element Map 2-22: Overcrowded Households Additionally, Black and Hispanic/Latino Households are more likely to be subject to overcrowding or substandard housing conditions (see Appendix B). 3. Homelessness The surge of homelessness is becoming an urgent reality for many in the City. As detailed further in Appendix B, based on the most recent point in time count, there are approximately 907 homeless individuals in Santa Monica on any given night. In the greater LA region, that number is closer to 66,000. Rising rents, stagnant wages, and a decreased supply of affordable housing means that almost 7,000 people in LA County lose their housing every month. While the last count in 2020 showed positive results including an 8% decrease in Santa Monica compared to a 13% increase countywide, COVID-19 has exacerbated Los Angeles County’s twin crises of housing and homelessness, and stymied interventions due to limited shelter capacity and an overburdened court system. Racial inequities in housing undoubtedly has worsened due to the pandemic. While the pandemic has affected employment nationwide, its effects have been disproportionate. The job loss has been particularly dire for Blacks/African American and Latinos who experienced exceptionally high levels of unemployment and slow rates of job recovery, and therefore, are most vulnerable to losing their homes. 8.B.c Packet Pg. 158 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 66Chapter 2 | Assessment of Fair Housing in the City Figure 2-6: Santa Monica Homeless Count, 2015 - 2020 200 400 600 800 1000 1200 0 2015 2016 2017 2018 2019 2020 4. Substandard Housing Conditions Most residential structures begin to show signs of deterioration as they approach 30 years, and often begin to require rehabilitation work to their major components, such as roofing, siding, plumbing, and electrical systems. As provided in greater detail in Appendix B, the 2019 ACS data show that almost 85% of housing in Santa Monica is more than 30 years old (i.e., built before 1990). This is much higher than the 68% measured in 2000, because Santa Monica experienced a major multi-unit construction boom in the 1970s. The age of a structure does not necessarily equate to substandard conditions, however. Over time, building owners may have performed improvements as necessary to keep the unit in competitive market. Furthermore, many units may have been rehabilitated following the 1994 Northridge Earthquake, which resulted in many buildings being damaged. Another tool to evaluate the condition of housing is through review of Code Enforcement cases regarding violations of the City’s as well as building and safety codes. Since 2015, the City has opened 222 Code violations related to substandard housing conditions. COVID-19 Effects on People of Color • Almost quarter of Black and Latino renters did not pay or deferred rent in May 2020, compared with 14 percent of white renters. • While a quarter of white renters expressed slight or no confidence in their ability to pay rent in June 2020, nearly half of Black and Latino renters expressed similar concern. Source: US Census Bureau weekly Household Pulse Survey 8.B.c Packet Pg. 159 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 67 City of Santa Monica | 2021 - 2029 Housing Element E. Displacement Risk The Urban Displacement Project (UDP) is a research initiative of UC Berkeley that conducts research related to potential gentrification and displacement risks in various cities, including Santa Monica and Los Angeles. Risks are based on a number of factors, such as income levels of households, diversity of neighborhoods, and changing housing costs. Map 2-23 shows the displacement assessment of census tracts in the City. As shown, Census Tract 701802 is the most vulnerable to displacement. Based on the City’s review of residential buildings that are older than 1980 (i.e. more than 40 years old) and that are underdeveloped relative to its underlying maximum allowable density, up to 274 units are considered at risk of displacement in this census tract. Map 2-23: Displacement Risk in the City F. Fair Housing Issues And Local Contributing Factors During the preparation of the AFH, the City led numerous outreach efforts with various stakeholders and conducted extensive analysis to identify factors that are barriers to fair housing. These factors were prioritized as shown in Figure 2-7. 8.B.c Packet Pg. 160 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 68Chapter 2 | Assessment of Fair Housing in the City Figure 2-7: Barriers to Fair Housing High Priority 1. Displacement of residents due to economic pressures 2. Impediments to mobility 3. Lack of access to opportunity due to high housing costs 4. Lack of affordable, accessible housing in a range of unit sizes 5. Land use and zoning laws 6. Private discrimination Medium Priority 1. Availability of affordable units in a range of sizes 2. Community Opposition 3. Lack of affordable, integrated housing for individuals who need supportive services 4. Lack of assistance for transitioning from institutional settings to integrated housing 5. Lack of local or regional cooperation 6. Lack of meaningful language access for individuals with limited English proficiency 7. Location and type of affordable housing 8. Location of proficient schools and school assignment policies 9. Loss of affordable housing 10. Siting selection policies, practices, and decisions for publicly supported housing, including discretionary aspects of Qualified Allocation Plans and other programs 11. Source of income discrimination Low Priority 8.B.c Packet Pg. 161 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 69 City of Santa Monica | 2021 - 2029 Housing Element 1. Access for persons with disabilities to proficient schools 2. Access to financial services 3. Access to publicly supported housing for persons with disabilities 4. Access to transportation for persons with disabilities 5. Admissions and occupancy policies and procedures, including preferences in publicly supported housing 6. Availability, type, frequency, and reliability of public transportation 7. Deteriorated and abandoned properties 8. Displacement of and/or lack of housing support for victims of domestic violence, dating violence, sexual assault, and stalking 9. Inaccessible public or private infrastructure 10. Inaccessible government facilities or services 11. Lack of affordable in-home or community-based supportive services 12. Lack of assistance for housing accessibility modifications 13. Lack of community revitalization strategies 14. Lack of local private fair housing outreach and enforcement 15. Lack of local public fair housing enforcement 16. Lack of public investment in specific neighborhoods, including services or amenities 17. Lack of private investment in specific neighborhoods 18. Lack of resources for fair housing agencies and organizations 19. Lack of state or local fair housing laws 20. Lending discrimination 21. Location of accessible housing 22. Location of employers 23. Location of environmental health hazards 24. Occupancy codes and restrictions 25. Quality of affordable housing information programs 26. Regulatory barriers to providing housing and supportive services for persons with disabilities The “High Priority” factors identified in the AFH are consistent with public input received during the public outreach process for the Housing Element (see Appendix A). While the City has been a leader in the production of affordable housing for the past few decades and implements a number of actions and programs to address fair housing, factors such as the high cost of housing, existing zoning, and economic pressures compounded with patterns of segregation have made it very difficult for households of color to live in the City. These factors are summarized briefly below in Figure 2-8: Figure 2-8: Summary of Fair Housing Issues and Local Conditions Fair Housing Issue Identified High Priority Significant Contributing Factors Integration and Segregation; Disproportionate Housing Needs; Publicly Supported Housing Displacement of residents due to economic pressures Santa Monica’s rent control law applies to most residential rental buildings constructed prior to 1979 and to certain single-family homes and condos. However, the Costa-Hawkins Rental Housing Act allows owners to raise the rents of rent- controlled units when tenants relocate or are evicted for non-payment. In addition, the Ellis Act gives property owners the right to exit the rental business, thereby evicting all of their tenants in one fell swoop (usually in the wake of a major remodel or transitioning to condo ownership). Rent-control evictions are on the rise in Santa Monica. 8.B.c Packet Pg. 162 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 70Chapter 2 | Assessment of Fair Housing in the City Fair Housing Issue Identified High Priority Significant Contributing Factors Integration and Segregation; Disparities in Access to Opportunity; Publicly Supported Housing Impediments to Mobility There is not a mobility counseling program for Housing Choice Voucher holders assisted by the largest public housing authorities in the Region: the Housing Authority of the City of Los Angeles and the Housing Authority of the County of Los Angeles. As a result, there are informational gaps that impede some residents of heavily Black and Hispanic neighborhoods in the Region from utilizing their assistance to move to high opportunity areas like Santa Monica, other parts of the West Side, coastal and southern Orange County, and the southwestern portions of the San Fernando Valley. Because of the small geographic footprint of the City of Santa Monica, the lack of mobility counseling is a less significant reinforcement of segregation in that local context. Additionally, although the Santa Monica Housing Authority utilizes exception payment standards to bring more apartments in Santa Monica within reach of Housing Choice Voucher holders, housing costs are so high in the city that even higher payment standards may be appropriate. Disparities in Access to Opportunity; Disproportionate Housing Needs; Publicly Supported Housing High housing costs Housing prices within the city of Santa Monica are very high as indicated in Appendix B. Despite the high costs, Santa Monica has taken steps to protect housing stock. The city charter has an inclusionary zoning provision that requires not less than 30% of all newly constructed multifamily housing to be reserved for moderate or low-income families. Santa Monica has also implemented rent control since 1979. It covers all units constructed prior to passage, some units constructed after passage, and in contrast to typical rent control provisions, also covers some single family homes. In the past few Housing Element cycles, Santa Monica has exceeded its RHNA for low income units In addition, there are approximately 1,000 LIHTC units currently in existence and earmarked for low-income households. However, these provisions largely protect those living in currently Santa Monica. Despite proximity to Los Angeles and the existence of opportunities within the city, those who don’t currently live in Santa Monica are priced out of living in the city and accessing resources or opportunity the city has to offer. Based on income and family sizes, those who are priced out will tend to be disproportionately Black, Hispanic, and with larger families. 8.B.c Packet Pg. 163 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 71 City of Santa Monica | 2021 - 2029 Housing Element Fair Housing Issue Identified High Priority Significant Contributing Factors Integration and Segregation; Disproportionate Housing Needs Lack of affordable, accessible housing in a range of unit sizes Persons with disabilities in Santa Monica disproportionately have low incomes and live in poverty, thus increasing their relative need for affordable housing. In light of the broader affordable housing shortage in the city and the Region, there is a shortage for persons with disabilities. The vast majority of LIHTC units in the area were put into service from 1991-onward, thus conforming with modern accessibility standards. Publicly supported housing is also subject to the modification requirements of Section 504 of the Rehabilitation Act. Nevertheless, new affordable, multifamily units – those that are most likely to be both affordable and accessible – are too few in number to meet the total need. Supportive housing developments often consist primarily or exclusively of one-bedroom apartments. When it comes to supportive housing for persons with disabilities, although the demand likely consists primarily of a need for one-bedroom units, there are individuals at risk of institutionalization who have dependent children and persons with disabilities who need a live-in aide with their own bedroom. Including a mix of a small number of two- and even three-bedroom units in developments with a supportive housing component would foster greater community integration. 43 Fair housing complaints responded to in 2021 200+ Hours of dedicated City staff time for fair housing outreach and enforcement 13,000 Inquiries on tenant rights handled annually 8.B.c Packet Pg. 164 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 72Chapter 2 | Assessment of Fair Housing in the City Fair Housing Issue Identified High Priority Significant Contributing Factors Segregation, R/ECAPs (in the Region), Disparities in Access to Opportunity, Disproportionate Housing Needs, Publicly Supported Housing, and Disability and Access Land use and zoning laws Santa Monica is very compact, roughly rectangular, abutting the ocean, and just 8.3 square miles. The street layout and zoning and is very efficient, with the downtown area located along the beach and down the center of the city. Single- unit zoning is located on the northern and southern ends of the City, with denser zoning toward the center of the City and the main transportation thoroughfares. Specifically, neighborhoods like North of Montana and Sunset Park that are disproportionately White are primarily zoned for single-family homes. The problem is most severe in the North of Montana neighborhood. The high housing cost of single family homes and the single family home- restricted zoning on either end of the City functionally restricts racial diversity in these neighborhoods, as shown by the disproportionately White and Asian American populations of the neighborhoods. However, Santa Monica has also had an inclusionary housing program in place for 30 years within the Santa Monica Municipal Code (Affordable Housing Production Program) that requires developers to abide by affordable housing requirements, such as designating portions of their buildings for moderate-, low-, very low-, and extremely low-income rental housing. The City also has a Housing Trust Fund to finance the development, construction, and duration of affordable housing. Segregation Private discrimination Given Santa Monica’s very progressive stance and expansive state and local anti-discrimination provisions, the majority of housing discrimination in the city occurs privately, rather than at the hands of the city or state. At Santa Monica Legal Aid, most of the complaints received detail discrimination based on a tenant’s disability, particularly complaints regarding denied request for a reasonable accommodation or modification. The second largest category is Section 8 discrimination, despite Santa Monica’s explicit prohibition against source of income discrimination. The third largest category is discrimination based on familial status. Santa Monica Legal Aid coordinates with the Santa Monica City Attorney’s office to investigate and resolve these complaints, including initiating lawsuits when necessary. G. Fair Housing Enforcement And Outreach Capacity The City of Santa Monica takes fair housing laws seriously and has enacted a number of local laws in support of fair housing including: • Chapter 4.28 of SMMC, addressing fair housing for families with children, disability, and source of income discrimination 8.B.c Packet Pg. 165 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 73 City of Santa Monica | 2021 - 2029 Housing Element • Chapter 4.40 of SMMC addressing fair housing regardless of sexual orientation or domestic partnership • Chapter 4.52 of SMMC addressing fair housing for persons living with HIV/AIDS • Chapter 9.49 of SMMC, addressing reasonable accommodations for persons with disabilities The City continues to promote fair housing and prevent housing discrimination. The Public Rights Division (PRD) of the City Attorney’s Office enforces Fair Housing Laws, and actively accepts, investigates, and resolves fair housing complaints. The PRD does this through sending demand letters to offending parties, coordinating with the Legal Aid Foundation of Los Angeles, and suing offending parties directly. As part of its investigations and enforcement in fair housing case, the City has continued to enforce local ordinance and State law outlawing housing discrimination based on source of income, such as rental housing vouchers. In 2020, the City responded to 43 fair housing complaints, and in fiscal year 2020-2021, the program resulted in ensuring several dozen landlords will accept Section 8 vouchers, in compliance with State law. The City also funds Legal Aid Foundation of Los Angeles (LAFLA) to pursue fair housing enforcement. Additionally, the City’s Code Compliance staff are available to help relocate people, if necessary. The Santa Monica Police Department is also committed to investigating and resolving hate crimes that may occur in the housing context. Unresolved fair housing violations are not a significant contributing factor to fair housing issues, as the City of Santa Monica actively pursues enforcement. The PRD also enforces the City’s Tenant Harassment Ordinance, and the City’s Rent Control Board monitors evictions and advises Santa Monica tenants of their rights. The Rent Control Board continues to engage the community about the protections under Rent Control Law through a number of events and seminars, as well as ongoing one-on-one consultations with tenants and property owners about their rights and responsibilities under the law. More than 13,000 inquiries are handled annually. The Board monitors owner-occupancy evictions to ensure that grounds for eviction is not abused and an inter-departmental task-force addresses issues related to withdrawals under the Ellis Act and the current use of those properties that have been withdrawn from the rental market. Other recent actions the City has enacted to assure that tenants are not discriminated against or harassed by building owners and address fair housing issues, particularly displacement protection, include: • In 2010, the Just Cause Eviction protections that were available only for tenants in rent- controlled units, were extended to all tenants when voters approved Measure RR. • On December 13, 2011, the City Council adopted an ordinance which extended the protections of the Tenant Anti-Harassment Ordinance to all tenants with just cause eviction protections. • In 2015, the City Council amended the City’s fair housing ordinance to include source 8.B.c Packet Pg. 166 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 74Chapter 2 | Assessment of Fair Housing in the City of income as a protected class and included a pioneering definition of “Source of Income” that included rental housing assistance such as the Section 8 Housing Voucher Program. • On May 22, 2018, the City Council adopted an ordinance which extends specific tenant protections to households with either educators or students under the age of 18 if the notice of termination falls during the school year. • In March of 2020, the City issued the first of a series of emergency orders that protected tenants from evictions during the pandemic and economic emergency. In addition to enforcement, the PRD also annually conducts a campaign to improve community awareness of fair housing laws and spends over $2,500 to undertake fair housing activities including public awareness and advertising in efforts to eliminate housing discrimination in the City. Prior to the COVID19 pandemic, the PRD hosted an annual fair housing workshop that is attended by hundreds of people. The PRD also regularly publishes articles about fair housing in the Santa Monica Daily Press and produces outreach videos on housing. In 2020-2021, the City sponsored or participated in fair housing webinars to promote community awareness and education. Approximately 200 staff hours are dedicated annually in fair housing enforcement work and community outreach. H. Summary And Actions To Affirmatively Further Fair Housing 1. Current Actions The City of Santa Monica has adopted numerous policies and actions to protect existing housing stock, prevent discrimination, protect tenants from displacement, and increase the supply of affordable housing, including rent control that has been in place for over 40 years. Santa Monica’s anti-discrimination and strong tenant protections include just-cause evictions, anti-tenant harassment laws, and notice of tenant buyouts; prohibitions on source of income discrimination; the Preserving Our Diversity (POD) program which provides cash-based assistance to low-income seniors; and anti- discrimination laws that afford protections beyond the federal Fair Housing Act and the California Fair Employment and Housing Act. A few of Santa Monica’s current actions to enhance housing mobility, provide housing choice and affordability, and prevent displacement are highlighted below: Rent Control Law Santa Monica Rent Control was adopted by the voters in April 1979 in response to a shortage of housing units, low vacancy rates and rapidly rising rents. The law was intended to alleviate the hardship of the housing shortage and to ensure that owners received no more than a fair return. The Regulations were adopted by the Rent Control Board to implement and enforce the Rent Control Law. The rent 8.B.c Packet Pg. 167 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 75 City of Santa Monica | 2021 - 2029 Housing Element control provisions cover single-family homes, duplexes, triplexes, and apartment buildings. The City’s rent control provides tenant protections and seeks to preserve existing housing stock and maintain naturally occurring affordable housing for its residents. Primary functions of the Rent Control Board include controlling rent amounts, maintaining amenities and services for tenants, provide for only “just cause” evictions, and limiting the removal of controlled units from the rental market, all in efforts to ensure tenant stability and preserving existing housing stock and its affordability. Under the City’s rent control law, tenants may only be evicted if they are at-fault or the landlord wishes to move themselves or their family into the unit. Proposition R (1990) and the Affordable Housing Production Program Proposition R was passed in 1990 by the voters, and requires that 30% of all new multifamily housing in the City be affordable to low- and moderate-income households. The Affordable Housing Production Program (AHPP) implements Proposition R, making the creation of affordable housing mandatory as part of the development of market-rate apartment and condominium buildings. Developers of new multifamily buildings are required to contribute to affordable housing in Santa Monica, including : • Constructing inclusionary affordable residences onsite in a development. • Constructing affordable residences offsite in another development. • Paying an affordable housing fee that is used by the City to subsidize affordable housing developments and are deposited into the Citywide Housing Trust Fund. The City continues to comply with the Proposition R affordable housing production mandate of 30% affordability in the long-term; between fiscal year 1996-97 through FY 2018-19, 38% of all multifamily housing constructed (5,346 total), pursuant to Proposition R, is affordable. The City has exceeded the goals of Proposition R, with 40 percent of all new housing built over the past 20 years being deed- restricted for occupancy by low- and moderate-income households. The City’s Affordable Housing Production Program has produced more than 800 units. Housing Trust Fund Additionally, the City has a Housing Trust Fund. Funds come primarily from redevelopment loan repayments and the stream of ongoing revenue provided by the voter-approved sales tax, Measures GS/GSH. The Housing Trust Funds has supported the production of over 1,200 very low and low-income affordable units over the same time period in addition to acquisition and rehabilitation of existing units and rental subsidies to help keep Santa Monicans housed. 8.B.c Packet Pg. 168 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 76Chapter 2 | Assessment of Fair Housing in the City Section 8 Housing Choice Voucher Program Santa Monica also has made considerable investments into expanding new housing choice and opportunities for low-income households. The Santa Monica Housing Authority operates the Section 8 Housing Choice Voucher program, which provides rental housing vouchers to extremely low- and very low-income households with rent subsidies to bridge the gap between what the household can afford and market rents. Further, the City has been active in preserving affordable housing for seniors through Project-Based vouchers that fund the rehab of affordable units and prevent them from becoming market rate units. Santa Monica’s Approach to Addressing Homelessness Santa Monica also has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. The City’s homeless service system has evolved significantly over 40 years and is nationally recognized as an innovative model that addresses the complex issues that contribute to long and repeated episodes of homelessness. On March 26, 2019, the City introduced the Four “Pillars” upon which the City’s homeless strategies are built: • Preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities; • Addressing the behavioral health needs of vulnerable residents; • Maintaining equitable access to safe, fun, and healthy open spaces; and • Strengthening regional capacity to address homelessness. These strategies have been implemented through interdepartmental and community partnerships that contributed to a sustained reduction in homelessness in the downtown and beach areas, as well as an overall 8% reduction in the City’s 2020 Point-In-Time homeless count. In February 2021, in response to the economic and housing challenges brought on by the COVID19 pandemic, the City reaffirmed its commitment to addressing homelessness. In addition to continuing the multi-disciplinary street teams and the Reed Park Ambassador program through June 2023, Council prioritized the following additional strategies for consideration during the forthcoming biennial budget process. • Extended Emergency Rental Assistance to prevent residents from falling into homelessness. • An alternative non-congregate shelter on City property. • A behavioral health triage center. • Low acuity crisis response unit in the Santa Monica Fire Department. Even with the City’s residential protections, programs, and incentives at addressing fair housing issues, the lack of affordable housing to meet the housing needs of low- and moderate income residents, especially for people of color, continue to remain a challenge. 8.B.c Packet Pg. 169 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 77 City of Santa Monica | 2021 - 2029 Housing Element Pilot Right to Return Program Most recently on July 13, 2021, Santa Monica City Council made changes to Santa Monica’s Affordable Housing Production Program and Housing Trust Fund to address past urban renewal policies that displaced many households of color. Specifically, the City’s affordable housing waitlist priority will be modified to include those former residents who were displaced by the creation of the Civic Auditorium in the Belmar Triangle neighborhood and I-10 freeway in the Pico neighborhood in the 1950s and 1960s. The pilot program is part of the City’s commitment to equity and inclusion. 2. Future Actions This Housing Element includes policies and programs further outlining the City’s commitment to remedying the legacy of past housing discrimination practices, breaking down the patterns of segregation , and ensuring fair housing opportunities to all. Chapter 5 of this Housing Element includes programs that provide address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization, and displacement protection These programs are described briefly below : Enhancing Housing Mobility Housing Mobility Strategies consist of removing barriers to housing in areas of opportunity and strategically enhancing access. This Housing Element sets forth the following programs that will enhance housing mobility: • Program 1.C – Incentivize Housing Development On Surface Parking Lots In Residential Zones That Are Associated With Existing Commercial Uses Under Program 1.C, the existing zoning barriers to housing on surface parking lots in the R1 and multiunit residential zones would be removed. Specifically, current zoning restricts the development of surface parking lots that are located in the residential zones. Current zoning limits where vehicular access can be taken on these parcels and also caps the number of residential units that could be developed (e..g, density cap of 4, 5, or 6 units), Program 1.C would remove these existing land use and zoning constraints to housing and adopt new standards to encourage housing projects on surface parking lots. This program would promote access to multifamily housing in the high opportunity areas of R1 and the multiunit residential (R2, R3, R4, OP2, OP3, and OP4) neighborhoods. • Program 3.B - Develop Tenant and Landlord Programs to Address State and Federal Legislation Mandated Regarding Anti-Discrimination Under program 3.B, the City shall continue to implement programs, including tenant and landlord education/outreach, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts. Currently, the City has several progressive legal protection programs, such as just-cause eviction protections and a new 2-year pilot 8.B.c Packet Pg. 170 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 78Chapter 2 | Assessment of Fair Housing in the City Right to Counsel program to assist tenants facing evictions. • Program 3.C- Facilitate the Conservation of Restricted and Non-Restricted At-Risk Housing Under Program 3.C the City will continue to provide information on maintaining long-term affordability and assist federally-funded housing properties with seeking funding assistance by applying for allocations of housing vouchers from the federal government to maintain housing affordability. • Program 6.A - Maintain Rental Housing Voucher Programs And Expand To Assist All Persons With Disabilities Under Program 6.A, the City will continue to: • Maintain and operate the Section 8, Housing Choice Voucher Program • Maintain a City-wide list of affordable rental vacancies in partnership with Community Corporation of Santa Monica • Program 6.D - Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources Under Program 6.D, the City will continue to: • Provide education and outreach to tenants and landlords to increase awareness about federal and local housing programs, including Section 8 housing voucher programs • Provide education and outreach to tenants and landlords to increase awareness about federal and local housing rights and legal obligations, including anti- discrimination regarding source of income • Enforce the Affirmative Marketing Policies that are required as part of HOME- assisted rental development Programs to enhance housing mobility also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Impediments to mobility • Lack of access to opportunity due to high housing costs • Lack of affordable, accessible housing in a range of unit sizes • Land use and zoning laws • Private Discrimination 8.B.c Packet Pg. 171 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 79 City of Santa Monica | 2021 - 2029 Housing Element Providing New Housing Choices and Affordability in High Opportunity Areas Housing choice strategies promote the housing supply, choices and affordability in areas of high opportunity and outside of areas of concentrated poverty. This Housing Element sets forth the following programs that will provide new housing choices and affordability in high opportunity areas: • Program 1.C - Incentivize Housing Development On Surface Parking Lots In Residential Zones That Are Associated With Existing Commercial Uses As discussed previously, current zoning restricts the development of surface parking lots that are located in the residential zones. Program 1.C would remove these existing land use and zoning constraints to increase housing in the high opportunity areas of R1 and the multiunit (R2, R3, R4, OP2, OP3, and OP4) neighborhoods. • Program 1.J - Revise Development Standards To Ensure Housing Projects are Feasible Incentivized Over Commercial Development. In some areas of the City, such as the Neighborhood Commercial districts of Main Street and Montana Avenue, housing is a permitted use. However, due to a number of factors including zoning code limitations on development, housing has not traditionally occurred in these areas. Furthermore, a financial analysis on residential development standards prepared for the City indicate that housing projects are unlikely to occur in the remaining mixed-use areas of the City such as the boulevards, and Bergamot Area due to land use and zoning restrictions on height and floor area ratios. To incentive housing, Program 4.B would rezone and modify the development standards in all the mixed-use and commercial zoning districts to allow housing projects to have greater density and height than commercial projects. This program would incentivize housing over commercial and create new housing choice. • Program 4.C - Provide New Housing Choices And Affordability In High Opportunity Areas Through Incentives For Additional ADUs In R1-Zone Neighborhoods 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. 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. Under State law, properties are permitted to have one ADU and one JADU. This program will further allow one more ADU on single-unit dwelling parcels with the requirement that the additional third ADU be restricted to permanent rental housing. This program will incentivize the production of ADUs thus providing new housing choice and affordability in the high opportunity areas of the R1 neighborhoods. • Program 2.A - Establish a 100% Moderate Income Housing Overlay Moderate Income housing projects currently have no dedicated funding source or incentives under local or State law. Since AB 1763 only applies to projects up to 80% AMI and the City’s 8.B.c Packet Pg. 172 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 80Chapter 2 | Assessment of Fair Housing in the City Zoning Ordinance similarly defines 100% affordable housing as only including projects up to 80% AMI, there are no incentives for moderate income housing projects (serving households up to 120% AMI). In the 5th Cycle Housing Element, Santa Monica did not meet its RHNA targets for moderate income units. Moderate-income housing units serve an important segment of Santa Monica workers and residents that do not qualify for lower-income affordable units yet cannot afford market rents. Program 2.A would create a new zoning overlay to incentivize moderate income housing projects in the targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th St station. 100% Moderate Income housing projects would be incentivized through special standards such as additional height (at least 33 feet additionally), density bonus, and reduced parking requirements. This program will incentivize the production of moderate-income housing thus providing new housing choice and affordability in the high opportunity areas around the Metro E transit stations. • Program 2.C Update the City’s Affordable Housing Production Program (AHPP) to Incentivize Housing Production at All Income Levels The City’s long established AHPP program has produced over 800 affordable units – expanding housing choice and affordability for many Santa Monica residents. Despite the success of the AHPP, there is still a significant gap between the housing needs of low-income households and the availability of affordable units. To further incentivize the production of affordable units at various income levels, Program 2.C would establish a new base affordability percentage of 15% for with the inclusionary units provided equally among very low-, low- and moderate-income levels. Program 2.C would also establish new more flexible requirements for in-lieu fees and off-site affordable housing. • Program 4.A - Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Nonresidential Zones Where Not Currently Permitted Currently, multi-unit residential is not permitted in certain commercial areas of the City; namely, the Industrial Conservation District, Office Campus, Creative Arts Center, and Conservation Creative Sector. Residential uses are not permitted in these zones, even though there may be existing residential uses that were developed in the past. Furthermore, areas within some of these zoning districts have significant housing potential with access to residential amenities, such as transit, commercial uses, parks, schools, and infrastructure. Program 4.A would add housing as a permitted use in these zones, creating new housing choices and affordability. • Program 4.B - Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses Parking lots of religious congregations are largely located in multi-unit residential zones presenting a unique opportunity to expand housing choice in these areas. During the Housing Element outreach process, the City met with a variety of religious congregations 8.B.c Packet Pg. 173 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 81 City of Santa Monica | 2021 - 2029 Housing Element through the Westside Interfaith Council. A handful of congregations have expressed strong interest in developing affordable housing on the parking lots of their sites. This program would adopt special standards in the Zoning Ordinance to support the production of affordable housing on surface parking lots owned by community assembly uses, which include religious congregations, including allowing some, but not more than 50%, market- rate units to support the affordable housing. With this program, properties associated with religious congregations and other community assembly uses in the multi-unit residential zones would be opened to new housing opportunities. • Program 6.H - Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing In the 2015 Zoning Ordinance update, Santa Monica adapted reasonable accommodation procedures (SMMC Chapter 9.49) that specify the applicability of eligible applicants and requests, application requirements, reviewing authority and procedures, findings and decisions, appeal process, and the duration limits of the accommodation. The City will maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws. Programs to enhance housing choice in high opportunity areas also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Impediments to mobility • High housing cost • Lack of access to opportunity due to high housing costs • Lack of affordable, accessible housing in a range of unit sizes • Land use and zoning laws Programs to encourage community conservation and revitalization also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Displacement of Residents due to Economic Pressures• High housing cost• Lack of affordable, accessible housing in a range of unit sizes 8.B.c Packet Pg. 174 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 82Chapter 2 | Assessment of Fair Housing in the City Place-based Strategies to Encourage Community Conservation and Revitalization: These strategies involve approaches that are focused on conserving and improving assets in areas of lower opportunity and concentrated poverty such as targeted investment in neighborhood revitalization, preserving or rehabilitating existing affordable housing, improving infrastructure, schools, employment, parks, transportation and other community amenities. As a compact city of 8.3 square miles with a costly housing market, the City doesn’t have the same level of distinct lower opportunity and concentrated poverty areas as other cities in the Region, such as the City of Los Angeles. This is evidenced by the fact that the entire City is considered to be a high opportunity area. Even so, some census tracts particularly adjacent to the I-10 freeway may have slightly less resources and opportunity than others. Therefore, this Housing Element sets forth the following programs that will provide promote community conservation and revitalization: • Program 3.C - Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing. The City monitors the status of at-risk projects within the City, advise tenants in advance of potential conversion dates, and assist in answering questions from residents of at risk housing. The City will continue these actions and exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. • Program 3.D - Maintain An Acquisition And Rehabilitation Program The City provides Housing Trust Fund loans to nonprofit housing providers to assist with the purchase and rehabilitation of existing rental properties occupied primarily by low-income households. As resources are available, the City will continue to provide loan assistance to nonprofit affordable housing providers and work with providers to identify new funding sources. • Program 3.E - Maintain A Low Income Residential Repair Program The City implements the Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants; and the Owner-Occupied Rehabilitation Program for low- and moderate-income owners. Minor home modifications improve physical access for people with disabilities and seniors that assist with independent living. The City will continue to implement this program. • Program 3.F - Enhance Code Enforcement Response To Housing-Related Violations The City’s Code Enforcement and Building and Safety Divisions respond to residential building code violation complaints. The City will continue this program and will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. • Program 3.H - Information And Outreach For Property Owners Regarding Rehabilitation 8.B.c Packet Pg. 175 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 83 City of Santa Monica | 2021 - 2029 Housing Element And Maintenance Of Housing Units The City will continue to provide additional education and outreach to multi-unit property owners on available City programs and support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. • Program 6.B - Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement The City will continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance to the extent feasible. • Program 6.C - Maintain And Expand The Preserving Our Diversity (POD) Program The City will continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. Displacement Protection As discussed previously, while the City already implements a number of programs and actions aimed at keeping residents housed, the inevitable economic pressures of the housing market have resulted in the displacement of residents. A fundamental guiding principle of the Housing Element is the preservation of existing housing stock. The primary reason why the existing multi-unit zones (R2, R3, R4, OP2, OP3, and OP4) are not being proposed for rezoning is due to the fact that most of the City’s rent control housing stock are located in these areas. Map 2-24: Zoning and Rent Control Units Programs to protect tentants from displacement also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Displacement of Residents due to Economic Pressures• High housing cost• Lack of affordable, accessible housing in a range of unit sizes 8.B.c Packet Pg. 176 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 84Chapter 2 | Assessment of Fair Housing in the City This Page Left Intentionally Blank 8.B.c Packet Pg. 177 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 8.B.c Packet Pg. 178 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Goals and Policies 8.B.c Packet Pg. 179 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 87 City of Santa Monica | 2021 - 2029 Housing Element Chapter 3: Goals and Policies The Housing Element includes seven goals that create the framework for how the City of Santa Monica will address the community’s housing needs over the next eight years. These goals were reviewed as part of the community process for this Housing Element update. The policy goals of this Housing Element focus on: Affordable Housing Production: Prioritize affordable housing on City-owned sites and remove barriers to affordable housing production in all areas of the City. Market-Rate Housing Production: Continue to support the production of new market-rate housing around major transit stops and along major corridors. Affirmatively Furthering Fair Housing: Decisions regarding distribution of new development are viewed through the lens of providing equitable housing access to all neighborhoods. Housing Assistance: Continue to prevent displacement of existing households by providing financial and technical assistance for the provision of housing for all income groups and household types including families with children, seniors, persons with disabilities, and others with special needs. Address Homelessness: Prevent housed Santa Monicans from becoming homeless and continue to address the special need to provide housing and supportive services for the homeless in the community with an emphasis on the most chronic and vulnerable individuals. Balancing Housing with Other City Goals: Incorporate other community goals related to economic sustainability and environmental objectives with the production, conservation, and protection of housing. These include encouraging a balance between housing and economic development, sustainable development, providing supportive services, and increasing walkability and non- motorized forms of transportation. Assuring Equal Housing Opportunities: Continue to assure equal access to housing for all. 8.B.c Packet Pg. 180 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 88Chapter 3 | Goals and Policies GOAL 1 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. In Santa Monica, the demand for housing greatly exceeds the supply. This has resulted in Santa Monica being one of the most expensive places to live in the country. The City is required by the State to address this housing shortage by planning for its Regional Housing Needs Allocation (RHNA). In the past eight years, the City produced 3,643 units, well exceeding its established 5th Cycle RHNA of 1,674 units. The City’s target for this 6th cycle Housing Element is 8,895 units, an average of about 1,100 housing units annually. This number is more than 5 times larger than the allocation required in the prior Housing Element cycle. Meeting this housing target will be challenging and will require the enactment of new policies and programs to bolster housing production. Since then, the City adopted the Land Use and Circulation Element in 2010, updated the Sustainable City Plan in 2014, updated the Urban Forest Master Plan in 2017, and adopted a Climate Action and Adaptation Plan in 2019. All of these plans provide the foundation for the creation of sustainable and healthy communities. New housing plays an important role in achieving the City’s goals to reduce vehicle miles traveled, reduce greenhouse gas emissions, expand the tree canopy, and promote environmental justice. 8.B.c Packet Pg. 181 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 89 City of Santa Monica | 2021 - 2029 Housing Element POLICIES Policy 1.1 Adequate Land for Housing. Provide adequately zoned sites for all types of housing, particularly multi-unit housing in locations near major transportation hubs and services that promote active living in addition to areas that have historically excluded diverse housing opportunities. Policy 1.2 Housing Production Incentives. Encourage and provide adequate development standards and incentives for the production of housing, particularly affordable housing. Policy 1.3 Adaptive Reuse. Encourage and provide incentives for adaptive reuse of existing commercial buildings for housing. Policy 1.4 Design of Housing. Ensure that the design of new housing development is responsive to the surrounding context. Policy 1.5 Innovative and Sustainable Housing Design. Ensure that local regulations support: sustainable construction techniques and materials to the extent technically feasible, environmental justice that protects public health, open space, and expansion of the tree canopy. Policy 1.6 Housing for Special Needs. Maintain development standards that promote the development of special needs housing, such as affordable senior, accessible, and family housing. Policy 1.7 Review of Housing Constraints. Periodically review City taxes, fees, and regulations to ensure that they do not constrain housing development. Policy 1.8 Streamlined Housing Process. Continue to evaluate and provide an expedited and coordinated permitting process and design review, particularly for housing projects, including those using innovative and sustainable construction techniques and materials. Policy 1.9 Partner with School District and Community College District for Housing. The City shall seek opportunities to work with the School District and Community College District to facilitate housing development. Policy 1.10 Funding for Affordable Housing on City-Owned Sites. Pursue grant funding opportunities to facilitate affordable housing on City-owned sites 8.B.c Packet Pg. 182 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 90Chapter 3 | Goals and Policies GOAL 2 Housing production for all income categories including for the community’s workforce and most vulnerable communities. While it is generally recognized that Californians pay more for housing than the average American, Santa Monica’s housing costs are among the highest in the nation. There are a variety of negative effects caused by a lack of affordable housing. With a greater share of household incomes spent on housing costs, households are left with less money available to spend on basic necessities. Having less money available for non-housing costs often means that low income households will have less savings in the bank, putting them at risk for poverty or preventing them from rising out of it. The City’s economy is supported by a diverse variety of industry sectors but 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. Additionally, 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. Affordable housing in Santa Monica has been produced from two sources: market-rate housing and public assistance such as the City’s Housing Trust Fund. Market-rate housing is required to provide affordable housing or pay an in-lieu fee through the Affordable Housing Production Program (AHPP). In the last eight years, the City has constructed 982 affordable housing units, which represents 27% of the total units produced. As part of this Housing Element update, the City of Santa Monica must 8.B.c Packet Pg. 183 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 91 City of Santa Monica | 2021 - 2029 Housing Element adequately plan for and accommodate a total of 6,168 new affordable housing units, which represents 69% of the City’s overall RHNA. While the City generally provides several process and development incentives in support of 100% affordable housing projects, the major barriers to the production of affordable housing include: • Lack of funding • Land costs • Insufficient height and density standards necessary to produce units • Commercial prevailing wage requirements for buildings 5 stories and above. • Neighborhood opposition The City has worked to overcome these barriers over the past 40 years by supporting 100% affordable housing on city-owned land resulting in the production of 770 units of affordable housing. The long-term affordability of these units has been guaranteed through recorded deed restrictions or in the case of property sale, the City has negotiated for right of first option to purchase for a low, fixed amount in the event of future sale. As such the City has a demonstrated history of continuously leveraged public land to produce affordable housing for the benefit of the community. POLICIES Policy 2.1 Affordable Housing Financing. Encourage innovative private sector and governmental programs to promote the financing and development of housing for extremely low-, very low–, and low-income persons and for moderate income families. Policy 2.2 Local Assistance for Affordable Housing. Focus available resources (including City-owned land and Housing Trust Funds) to assist for- profit and nonprofit housing providers to develop housing for extremely low–, very low–, and low-income households. Policy 2.3 Advocacy for Legislative Changes. Support the enactment of federal, state, and local legislation to provide funding and incentives for the preservation and development of housing that is affordable to very low–, low–, and moderate-income households, and to accommodate special needs. Policy 2.4 Local Incentives and Streamlining for Affordable Housing. Continue to encourage and provide development opportunities and incentives, expedited permit review, and reduced planning fees to increase the production of affordable housing including extremely low-, low-, very- low, and moderate-income households. Policy 2.5 Homeownership Opportunities. Explore ways to encourage the development of ownership housing for affordable to moderate-income households and the City’s workforce, including opportunities for employer- provided permanent housing. 8.B.c Packet Pg. 184 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 92Chapter 3 | Goals and Policies Policy 2.6 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. Policy 2.7 Support for Senior Housing. Encourage and support development of senior housing and facilities to meet the needs of seniors, particularly for the oldest senior cohort, including consideration of a preference for “aging in place” along with the need for more congregate housing and residential care facilities. Policy 2.8 Support for Special Needs Housing. Consider incentives and requirements to ensure that new residential development accommodates a mix of household types and sizes that include a person(s) with special needs. Policy 2.9 New Housing Models. Encourage proposals for new housing types, such as co-housing, and assess their feasibility and benefits on a case-by-case basis. Policy 2.6 Maintenance, Improvement and Development of Housing for Persons with Disabilities. Explore alignment with the Voluntary Compliance Agreement (VCA) between the City of Los Angeles and HUD for, Santa Monica to potentially require at least 15% of total units in all newly constructed multi-family developments receiving public funds where City funds are leveraged with Low-Income Housing Tax Credits to be accessible to persons with mobility disabilities and at least 4% of total units to be accessible for persons with hearing and/or vision disabilities. 8.B.c Packet Pg. 185 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 93 City of Santa Monica | 2021 - 2029 Housing Element GOAL 3 Preservation of the existing supply of housing and prevent displacement of existing tenants. In 2020, Santa Monica’s total housing stock consisted of approximately 52,629 total units, 11,572 of which are single-unit residences and 40,853 of which are within multi-unit residential structures. Although there are over 11,000 single-unit dwellings, there are only around 6,500 parcels zoned R1, meaning many are located within multi-unit zones. The total housing stock includes affordable housing units and rent-controlled units, which are valuable assets to the City as they provide housing opportunities to low and moderate-income households. There are currently 3,902 publicly-assisted affordable units located within the City of Santa Monica.1 An estimated 770 units are at-risk of converting to market rate by 2031. In addition, as of December 31, 2020, there were 27,429 rent-controlled units in the City.2 Rent controlled units help ensure that rental costs do not outpace existing wages, and therefore, play a crucial role in keeping existing residents housed. Figure 3-1: Age of Housing Stock 0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20% 981 2014or later 880 2010-2013 3,280 2000-2009 2,838 1990-1999 4,426 1980-1989 10,227 1970-1979 9,018 1960-1969 7,116 1950-1959 4,901 1940-1949 7,457 1939or earlier Deed-restricted affordable housing and rent- controlled units contribute significantly to the City’s housing affordability. Preserving and rehabilitating existing housing stock is a key anti-displacement tool that prevents existing households from becoming unhoused. The vast majority of the City’s housing stock was built before 1980, see Figure 3-1 above. As these units age, they will be at risk of being demolished due to deteriorating conditions if not properly maintained. Some of the City’s existing housing stock will be protected as a result of SB330, which prohibits a project that will demolish 1 These include units produced with federal funding assistance, federal/state tax credits, redevelopment tax increment, City housing trust funds, City Multi-family Earthquake Repair Loan (MERL) Program Assistance and Los Angeles County Housing Authority owned units.2 City of Santa Monica, Rent Control 2020 Annual Report 8.B.c Packet Pg. 186 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 94Chapter 3 | Goals and Policies existing residential units and would not replace, at a minimum, the same number of new residential units. This will address existing multi-unit housing properties of five units or less that are particularly vulnerable to redevelopment and replacement. Additionally, the new allowance for ADUs on existing multi-unit properties not only creates more housing opportunities but may also encourage property owners to retain their rental properties. However, there remains existing multi-unit housing properties in the City that have fewer units than maximum allowable density and as such, could be at risk for demolition and redevelopment by a housing project that proposes a higher number of new units. POLICIES Policy 3.1 Support the City’s Rent Control Law. Ameliorate the effects of the Costa- Hawkins vacancy de-control regulation on the affordable housing stock. Policy 3.2 Preservation of Naturally Occurring and Deed Restricted Affordable Rental Housing. Explore strategies to preserve naturally occurring, rent-controlled, and restricted affordable rental housing. Policy 3.3 Protection of Rental Units. The City shall continue to protect rental housing by restricting the conversion of rental units to ownership units or for uses other than permanent rental housing. Policy 3.4 Replacement of Demolished Multi-Unit Housing. The City shall ensure the reasonable replacement of multi-unit housing that is demolished. Policy 3.5 Availability of Affordable Housing. The City shall ensure the continued availability and affordability of housing for very low-, low-, and moderate-income households. Policy 3.6 Rehabilitation Assistance. Provide rehabilitation assistance to maintain, improve, and extend the use and livability of the City’s aging residential buildings. Explore expansion of existing and new rehabilitation programs that may also result in short-term and long- term deed-restricted affordable units. Policy 3.7 Public and Private Funding for Rehabilitation and Preservation. Encourage and promote the use of public and private funding to provide rehabilitation, home improvement, and maintenance loans and grants with priority given to affordable units at risk of conversion, and multi-unit rental housing. Policy 3.8 Continued Maintenance of Existing Housing. Ensure continued maintenance of existing housing and that property owners are made aware of City programs to promote capital improvements to rental housing. Consider property owner incentives to encourage continued maintenance, repairs, and upgrades to housing that addresses the health and safety needs of the residents while respecting the character of the structure. Policy 3.9 Legal Support for Residents. Continue to provide and strengthen anti-discrimination legal assistance and support for tenants facing harassment or eviction in efforts to prevent displacement of existing tenants. 8.B.c Packet Pg. 187 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 95 City of Santa Monica | 2021 - 2029 Housing Element GOAL 4 A community that provides equitable housing access to all neighborhoods. The City of Santa Monica is generally more homogenous than the County as a whole. The majority of the City’s residential population is White, followed by Hispanics and Asians, respectively. Blacks represent 4% of the population. One of the likely barriers to living in the City for non-Whites is the high cost of housing. Hispanics and Black households have the lowest median income in the City and County as a whole, and as a result, are often priced out of housing opportunities in the City. For those households of color that can afford to live in Santa Monica, many of them are concentrated in neighborhood pockets of the City along the I-10 Freeway, and within the Pico, Downtown and Mid- City neighborhoods. These patterns of segregation are largely the result of decades of structural racism deeply rooted in Federal, State, and local housing policies. This includes the adoption of exclusionary zoning, which was used primarily as a way to economically separate the wealthier Whites from Blacks/African Americans and other people of color. Since many Blacks/African Americans could not afford or were unable to receive mortgages to purchase homes, they were effectively driven out of single- family zoned neighborhoods. The federal policy of “redlining” that arose during the New Deal era (1930s) also have contributed to the patterns of segregated neighborhoods. This discriminatory practice of determining who could qualify for home mortgages based on skin color led to widespread segregated communities across the country and prevented Blacks/African Americans from buying homes. In Santa Monica, areas that were redlined included the Pico Neighborhood, portions of the Mid- City neighborhood south of Santa Monica Boulevard, and Ocean Park. The pattern of redlined areas directly correlate with the areas where the non-White population, lower income households, and renter households are concentrated. Redlining The term “redlining” refers to the discriminatory policy instituted by the federal government to create color-coded maps of every metropolitan area in the country to indicate where it was safe to insure mortgage. These maps were based on racial composition, quality of housing stock, access to amenities, etc. and were color coded to identify best (green “A” grade), still desirable (blue “B” grade), definitely declining (yellow “C” grade), and hazardous (red “D” grade) neighborhoods. Areas of the City that were predominantly commercial/industrial were not color coded. 8.B.c Packet Pg. 188 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 96Chapter 3 | Goals and Policies Figure 3-2: Santa Monica Population by Race, 2019 65%White 10%Asian 4%Black or African American 15%Hispanicor Latino 5%Two or more races 1%Other POLICIES Policy 4.1 Access to Opportunities. Promote access to environmentally healthy neighborhoods that offer transportation services, jobs, high performing schools, parks, and residential amenities – particularly in areas that have historically excluded certain segments of the population. Policy 4.2 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. Policy 4.3 Targeted Investments. Strategically target housing creation and preservation strategies (e.g., public funding, incentives, infrastructure investments, etc.) and diverse housing types in locations that will help overcome historic patterns of segregation as well as programs and measures such as a “Right to Return” program that will help support historically displaced families and individuals in Santa Monica with housing. 8.B.c Packet Pg. 189 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 97 City of Santa Monica | 2021 - 2029 Housing Element GOAL 5 Housing for persons experiencing homelessness. Even prior to the COVID- 19 pandemic, homelessness was and continues to remain a regional and local challenge. Homelessness is driven by a multitude of factors, including: inadequate housing supply at all affordability levels, rising rents that have outpaced stagnant wages, and discriminatory housing and employment policies that have kept low-income populations and people of color in poverty. These challenges are compounded by insufficient and inconsistent access to medical and behavioral healthcare, as well as other essential supportive services. Up until 2020, City staff and volunteers had conducted annual point-in-time counts to approximate the number of homeless individuals within the City borders, along with a count of shelter use that same night. The last recent count took place on the night of January 22, 2020 with a total of 907 individuals counted outside on the streets, in cars and encampments, and in shelters and institutions within the City. While this number represented a decrease from 2017, the situation is expected to worsen due to the economic recession caused by the COVID-19 Pandemic, especially once the City’s eviction protection moratoriums expire. The City’s unhoused population includes veterans, women, persons with disabilities, older adults, and other vulnerable groups. A disproportionate number of Blacks/African Americans experience homelessness in Los Angeles County while the proportion of other racial and ethnic groups are either under or equal to their prevalence in the general population, making it clear that homelessness is also a social justice issue. 8.B.c Packet Pg. 190 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 98Chapter 3 | Goals and Policies Figure 3-3: Homeless Count, 2015 - 2020 City of Santa Monica Service Planning Area 5 - Westside Los Angeles County 2015 738 4276 41174 2016 728 4659 43854 2017 921 5411 52442 2018 957 4401 49955 2019 985 5262 56257 2020 907 6009 66436 Source: Los Angeles Homeless Services Authority, https://www.lahsa.org/homeless-count/ POLICIES Policy 5.1 Regional Fair Share Approach. Encourage a regional fair share approach to providing housing opportunities and assistance to homeless, extremely low-, very low-, and low- income households, and households with special needs. Policy 5.2 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; those whose last permanent address was in Santa Monica; and vulnerable members of Santa Monica’s workforce. Policy 5.3 Removal of Barriers to Supportive Housing. Remove barriers to the provision of low barrier navigation centers, emergency shelters, and supportive/transitional housing. 8.B.c Packet Pg. 191 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 99 City of Santa Monica | 2021 - 2029 Housing Element GOAL 6 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. Certain segments of the population may have greater difficulty in finding decent, affordable housing due to special circumstances. Populations requiring housing assistance and supportive programs include low-income households, the elderly, persons with disabilities, families, persons in need of emergency shelter, and persons with developmental disabilities. In 2017, 15.4% of the City’s total households were Extremely Low Income (0% to 30% AMI), 8.8% were Very Low Income (31% to 50% AMI), 11.6% were Low Income (51% to 80% AMI), and 7.0% were Moderate Income (80% to 100% AMI). Income disparity by racial group is apparent at the City level. Households of colors are more likely to have lower income levels than White households. Many lower-income families are considered housing cost-burdened - spending more than 30 percent of their monthly income for housing costs, leaving very little left for other basic needs like healthcare, food, and transportation. Others are forced into overcrowded or substandard housing conditions or join the increasingly large population of people experiencing homelessness. The elderly population, large families, families with children, and individuals with disabilities also require support, as they may have specific housing requirements that are necessary for access and enjoyment of their residence. Figure 3-4: Household Affordability Level by Race Households Total Households Extremely Low (less than 30% AMI) Very Low Incomes (30-50% AMI) Low Income (51-80% AMI)Moderate (80-120% AM) White 33,400 .6%7.6%10.7%7.2% Hispanic 5,705 20.7%13.4%18.0%7.5% Asian 4,245 15.1%4.8%9.1%4.8% Black/African American 1,508 12.7%28.4%15.7%6.4% Other 1,495 14.9%9.9%12.6%8.6% All Households 46,353 15.4%8.8%11.6%7.0% Source: CHAS HUD Data, 2017. 8.B.c Packet Pg. 192 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 100Chapter 3 | Goals and Policies POLICIES Policy 6.1 Financial Assistance for Residents; Rental Assistance Programs. The City shall provide support in rental assistance programs for extremely low-, very low-, and low-income households and household types including seniors, families with children, persons with disabilities, and others with special needs. Explore funding strategies and identify additional funding sources to provide continued support with rental assistance programs. Policy 6.2 Technical Housing Assistance. The City shall provide information and assistance to extremely low-, very low-, and low-income households and households with special needs and landlords to educate and increase awareness of, and provide oversight on federal and local housing and supportive programs and to assist residents in locating appropriate housing. Address housing barriers and resident challenges in securing and maintaining housing. Policy 6.3 Funding for Supportive Services. Target funds to ensure a broad array of supportive services to extremely low-, very low-, and low-income persons to ensure their continued maintenance of housing once obtained. Ensure funding that supports emergency housing for the homeless. Policy 6.4 Consider Expanding the Preserving Our Diversity (POD) Program. Evaluate expansion of the POD program to other rent burdened households including but not limited to additional seniors, families, and persons with disabilities and special needs. Policy 6.5 Reasonable Accommodations. Provide regulatory relief to enable housing access designed to meet the needs for persons with disabilities to ensure equal housing opportunities, consistent with fair housing laws. Policy 6.6 Resident Protections During Rehabilitation. The City shall provide resident protections including a temporary relocation program with oversight to minimize resident disruption and ensure that rehabilitation of existing units does not negatively impact or result in permanent displacement of existing residents. Policy 6.7 Explore Programs with the County of Los Angeles. The City shall explore the possibility of entering into contracts with the County for project-based vouchers including, but not limited to, programs administered by the County of Los Angeles. 8.B.c Packet Pg. 193 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 101 City of Santa Monica | 2021 - 2029 Housing Element GOAL 7 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. Pursuant to the California Fair Employment and Housing Act [Government Code Section 12921 (a)], the opportunity to seek, obtain, and hold housing cannot be determined by an individual’s “race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, genetic information, or any other basis prohibited by Section 51 of the Civil Code.” Fair housing issues that may arise in Santa Monica (or any jurisdiction) include but are not limited to: • Failure to make reasonable accommodations or modifications to make a dwelling unit accessible to an individual with a disability; • Discrimination in the sale or rental of a dwelling unit against an individual based on race, national origin, familial status, disability, religion, sex, or other characteristic; and • Tenant harassment because of race, color, religion, sex, disability, familial status, or national origin A multi-unit housing development that provides accommodations for persons with a physical disability 8.B.c Packet Pg. 194 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 102Chapter 3 | Goals and Policies The City of Santa Monica takes fair housing laws seriously and has enacted a number of local laws in support of fair housing including: • Chapter 4.28 of SMMC, addressing fair housing for families with children, disability, and source of income discrimination • Chapter 4.40 of SMMC, addressing fair housing regardless of sexual orientation or domestic partnership • Chapter 4.52 of SMMC, addressing fair housing for persons living with HIV/AIDS • Chapter 9.49 of SMMC, addressing reasonable accommodations for persons with disabilities The Public Rights Division (PRD) of the City Attorney’s Office enforces Fair Housing Laws, including investigation of fair housing complaints and litigation if necessary. The PRD also hosts an annual fair housing workshop and regularly publishes articles about fair housing in the Santa Monica Daily Press. The COVID-19 pandemic has highlighted the importance of housing rights, as many Santa Monicans (especially families and people of color) are facing evictions. The rise in hate crimes against all protected classes has also made the issue of fair housing paramount. POLICIES Policy 7.1 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. Policy 7.2 Legal Support for Residents. Continue to provide and strengthen anti-discrimination legal assistance and support for tenants facing harassment or eviction. Policy 7.3 Fair Housing Community Outreach. Continue to work with local organizations and partners to engage in community outreach strategies that provide information on fair housing laws, including community workshops and public awareness campaigns. 8.B.c Packet Pg. 195 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.c Packet Pg. 196 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Summary of Land Available for Housing 8.B.c Packet Pg. 197 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 105 City of Santa Monica | 2021 - 2029 Housing Element A. Regional Housing Needs Allocation The Regional Housing Needs Allocation (RHNA) is a state-mandated process that determines the amount of future housing growth each city and county must plan for in its Housing Element. This “fair share” allocation concept seeks to ensure that each jurisdiction accepts responsibility for the housing needs of not only its resident population, but also for the jurisdiction’s projected share of regional housing growth across all income categories. The RHNA process begins with the California Department of Housing and Community Development’s (HCD) projection of future statewide housing growth need, and the apportionment of this need to regional councils of government throughout the state. The Southern California Association of Governments (SCAG) then determines the share to be allocated to each city and county within its region based on its approved Final RHNA methodology. On March 4, 2021, SCAG adopted the final RHNA allocation for all jurisdictions within its region. Figure 4-1 shows Santa Monica’s allocation in the Final Regional Housing Needs Allocation Plan—the planning period of October 2021 through October 2029. Approximately 69% of the units are allocated for households earning less than 120% of the Area Median Income (AMI). The RHNA represents the minimum number of housing units for which each community is required to provide “adequate sites” through zoning and is one of the primary threshold criteria necessary to achieve State approval of the Housing Element. Chapter 4: Summary of Land Available for Housing On March 4, 2020, SCAG approved the Final RHNA methodology for determining each jurisdiction’s RHNA within the SCAG region. The methodology utilized a three- step process: 1. Determine the jurisdiction’s projected housing need using regional projected household growth and calculate a future vacancy need by applying a healthy vacancy rate to owner and renter households. Assign a replacement need based on local survey results. 2. Determine the jurisdiction’s existing housing need based on a jurisdiction’s proximity to transit and jobs. 3. Add the projected and existing housing need together to get a total and apply social equity adjustment factors to determine the four RHNA 8.B.c Packet Pg. 198 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 106Chapter 4 | Summary of Land Available for Housing Figure 4-1: Santa Monica’s 2021-2029 Regional Housing Needs Assessment Income Level % of AMI*Units % of RHNA Allocation Very Low 31-50%2,794 31% Low 51-80%1,672 19% Moderate 81-120%1,702 19% Above Moderate 120%+2,727 31% Total 8,895 100% 1. Extremely Low Income Housing Needs The RHNA does not include the income level of extremely low-income units (ELI). However, state law (AB 2634) requires Housing Elements to include the projected number of extremely low income housing needs, and the City’s AHPP requires the production of ELI units. HCD indicates that local agencies may calculate the projected housing need for ELI households by applying one of the following two methodologies to the RHNA for very low-income (VLI) households: • Use available Census data to calculate the percentages of ELI and VLI households and apply these percentages; or • Assume 50 percent of the VLI units would qualify as ELI. Applying the first methodology, approximately 7,124 extremely low-income and 4,089 very low- income households were identified in Santa Monica as detailed further in Appendix B. This equates to 64 percent and 36 percent respectively, of the total ELI and VLI households (Figure 4-2). These percentages suggest that of Santa Monica’s RHNA share of 2,794 RHNA very low income units, a minimum of 1,788 units should be available for extremely low-income households and 1,008 units for very low-income households. Figure 4-2: Low Income Housing Needs Existing # of Households %RHNA Projected Need Extremely Low 71,24 64%2,794 1,788 Very Low 4,089 36%1,006 8.B.c Packet Pg. 199 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 107 City of Santa Monica | 2021 - 2029 Housing Element B. Suitable Sites Inventory The Regional Housing Needs Allocation (RHNA) is a state-mandated process that determines the amount of future housing growth each city and county must plan for in its Housing Element. This “fair share” allocation concept seeks to ensure that each jurisdiction accepts responsibility for the housing needs of not only its resident population, but also for the jurisdiction’s projected share of regional housing growth across all income categories. 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. For the 6th Cycle 2021-2029 Housing Element, the City’s RHNA is 8,895 units, of which 69% must be provided at affordable levels. The SSI for the City of Santa Monica’s 6th Cycle Housing Element was prepared in accordance with State Housing Element law and HCD’s Housing Element Sites Inventory Guidebook. Appendix F provides a report of the methodology used to prepare the SSI. Map 4-1: Suitable Sites 8.B.c Packet Pg. 200 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 108Chapter 4 | Summary of Land Available for Housing 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 SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning, general characteristics such as historic and land use designations, and market factors. City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. 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. Based on the assessment of sites using the above factors and methodology, there are 137 parcels that have approved and pending projects for residential development and 185 non-vacant commercial/mixed use zoned parcels in the City identified to have high potential for residential redevelopment. In addition, 22 residentially zoned sites that are developed as parking lots have been identified as having high potential to be redeveloped for housing. Approximately 332 344 sites have been identified that have the highest potential to accommodate housing. These are shown on Map 4-1. Sites may be viewed interactively on the City’s Housing Element Update webpage at: https://www.santamonica.gov/housing-element-update. The sites in the SSI are categorized according to Figure 4-3. Accommodating for Very Low and Low Income Housing The State uses the density allowed on a site as a “proxy” for determining whether a site can accommodate housing at lower-income levels. • Very Low and Low Income. State law establishes a “default density standard” of 30 units per acre for low-income units in the City of Santa Monica. This means that if a site’s zoning allows for a density that is greater than 30 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households. The City’s Zoning Ordinance uses FAR rather than the density factor of units/acre. Therefore, to determine how many units per acre are possible on each site in the SSI, the number of units possible was calculated based on the allowable FARs established in Programs 1.F and 1.J. The number of units was then translated into units/acre based on the parcel size of each site. These calculations indicate that with the rezoning in Programs 1.F and 1.J, all the non-vacant, commercially zoned sites in the SSI can accommodate housing at greater densities than the “default density” of 30 units/acre. Therefore, per HCD, all sites can be identified as having the capacity and density to accommodate lower-income units. • Moderate-income. Since all the identified SSI sites can accommodate lower-income units, the City has also determined that each site can accommodate moderate-income housing since units affordable to lower-income households would also be affordable to moderate-income households. 8.B.c Packet Pg. 201 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 109 City of Santa Monica | 2021 - 2029 Housing Element Figure 4-3: Suitable Sites Prioritization Categories #Category Description 1 Approved and Pending Housing Projects Santa Monica has a number of pipeline housing projects that have been approved or are pursuing entitlements. These units are expected to be constructed in the next eight years and would count toward the City’s 6th Cycle RHNA. 2 Prior SSI Sites 83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have undergone entitlements but the remaining have not. 3 DCP Buildout As part of the Downtown Community Plan that was adopted in 2017, sites in the Downtown were identified for potential redevelopment. 4 City-Owned Sites An important strategy for the City to meet its RHNA targets is the utilization of existing City-owned sites for housing, particularly affordable housing. All City-owned sites that are not currently developed with open space/parks, community centers, civic uses, utilities, etc. are categorized as Category 4 sites. 5 Parking Lots A handful of sites in the City are parking lots, or parking structures. Parking lots are very underutilized and represent the greatest opportunity for new housing without displacement of existing uses. 6 Auto Storage Lots These are parcels currently being utilized almost entirely as auto inventory surface lots for auto dealerships. Auto dealerships have indicated interest in turning over these large surface lots into redevelopment opportunities as they are rethinking their sales operations. 7 Parcels with recent/active sales Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites (such as Loopnet), a number of properties have recently sold between 2019-2021 or have active sales listing. 8 Underutilized Sites (20,000 excess sf development potential) Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to have a net new development potential of 20,000 sf or greater (based on their existing built sf compared against their currently allowable maximum floor area). 9 Large Parcels (15,000 sf+)Most parcels in the City are 7,500 sf. Large parcels that are 15,000 sf have greater potential for redevelopment. 10 Remaining Sites with less than 0.5 AVR All remaining City sites with an assessor’s value ratio (AVR) of 0.5 or less have the highest likelihood of redevelopment. 11 Religious Institutions AB 1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. A number of religious institutions with large surface parking lots are located throughout the City. 12 A-Lots and Residentially Zone Parking Lots “A-Lots” are residentially zoned (R1/R2/R3/R4) parcels with an “A” Off-Street Parking Overlay. Within the City, there are 42 A-lots. In addition, there are numerous residentially zoned parking lots that serve the parking needs of boulevard-fronting commercial uses. 8.B.c Packet Pg. 202 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 110Chapter 4 | Summary of Land Available for Housing City owned parking lot off of Main Street. 1. Approved and Pending Housing Projects The City has a significant number of housing projects in the pipeline that if constructed will count toward the City’s 6th Cycle RHNA. As of February 2021 May 2022, there were approximately 1,670 2,304 approved units (of which 401 622 are affordable) and 756 2,324 pending units on 108 137 parcels. The list of approved and pending projects is provided in Appendix F. A review of the past 5th Cycle Housing Element shows that 10% of approved and pending projects were withdrawn and/or have had permit approvals expire. It is not possible for City staff to predict how many and which specific approved and pending projects could be withdrawn or ultimately not developed. Doing so would be arbitrary and speculative. Therefore, a 10% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 1,503 2,074 approved units and 680 2,092 pending units that are projected to count towards the 6th Cycle Housing Element. 2. Prior SSI Sites The SSI identifies 24 sites that were in the last (5th) Cycle Housing Element with the capacity for approximately 1,500 units. According to Government Code Section 65583.2, if the SSI contains sites that were used in a prior housing element planning period, the City must allow by-right a development that includes at least 20% of the units as affordable. Sites where zoning already permits residential “use by right” as set forth in Government Code section 65583.2 (i), at the beginning of the planning period would be considered to meet this requirement. The City currently allows by-right housing projects through an interim zoning ordinance. In order for the reused sites identified in the SSI to qualify for inclusion, this Housing Element includes Program 1.A to amend the Zoning Ordinance to establish a permanent by-right approval process for qualifying housing projects, including housing projects providing 20% of units as lower income affordable units. 8.B.c Packet Pg. 203 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 111 City of Santa Monica | 2021 - 2029 Housing Element 3. City-Owned Sites Achieving the number of affordable housing units for the 6th Cycle RHNA will be challenging, especially given limited public funding and high land costs in the City. The City recognizes that City- owned land can play an important role in producing significant housing, particularly affordable housing, and therefore, has made a commitment to prioritizing such land for 100% affordable housing within this Housing Element. Program 2.E. commits City-owned sites for the development of affordable housing through a public process that would maximize the amount of affordable housing that could be feasibly developed. The City-owned sites in the SSI are: Public Parking lots 7, 8, and 12, Parking Structure 3, 4th & Arizona, Bergamot Arts Center, and Main Street parking lots. With consideration to existing constraints (such as lease terms, financial resources, etc.), City-owned sites have the potential for accommodating 1,884 1,880 units. Program 2.E commits the City to plan for a minimum of 1,884 1,880 affordable housing units across available City-owned sites, which may include but shall not be limited to rezoning actions. 4. Community Assebly Sites (Including Religious Congregations) A number of religious congregations with large surface parking lots are located throughout the City. State law has made it easier to develop housing on religious institutional properties by removing parking as a barrier to development. During the outreach process of the Housing Element, many of these religious congregation leaders have expressed interest in developing housing on their properties and indicated that the provision of affordable housing on these sites would be aligned with their core mission. With Program 4.B to amend the Zoning Ordinance to facilitate the development of housing on surface parking lots owned by community assembly uses, these sites could accommodate 257 units. 8.B.c Packet Pg. 204 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 112Chapter 4 | Summary of Land Available for Housing 5. All Remaining Sites The remaining sites in the inventory include parking lots, underutilized sites with low-scale buildings, recently sold/active sales sites, and large sites. Mixed-Use Zones Many of the SSI sites are located in the City’s commercial and mixed-use zones (MUBL, MUB, GC, NC). Changes in the Downtown Community Plan and Zoning Ordinance as specified in Programs 1.F and 1.J will be required to support multi-unit housing and the production of inclusionary, affordable housing units in compliance with the City’s Affordable Housing Production Program. In particular, the new increases in density and height would increase the likelihood of housing units to be developed in the NC zone (where housing has traditionally not occurred). Office Campus/Industrial Conservation/Creative Conservation Sector Sites in the OC, IC, and CCS zones are typically developed for office, business park, warehousing, light industrial, and other commercial uses. A number of sites in these zones have been determined to be compatible for residential uses. The Housing Element includes Program 4.A to amend the Zoning Ordinance to allow multi-unit residential in non-residential zones where housing is currently prohibited. 6. Capacity to Accommodate the RHNA by Income Levels 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 has the capacity to accommodate at least 11,070 13,549 units providing a 21 52 percent buffer above the City’s RHNA of 8,895 units. This number is based on the application of new development standards for housing projects as established in Programs 1.F and 1.J. 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 land inventory includes capacity for 2,444 2,560 extremely low, 2,398 2,712 very low income, 2,542 2,742 low income, and 1,784 1,933 moderate income units. Figure 4-4 breaks down the summary of the SSI capacity based on category and income levels. 8.B.c Packet Pg. 205 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 113 City of Santa Monica | 2021 - 2029 Housing Element Figure 4-4: Suitable Sites Capacity Summary Table – Base Tier 1 Housing Total Capacity Capacity for Affordable Units # Units # Affordable Units ELI VLI LI Moderate Category 1 Approved 2,074 1,503 622 416 127 104 162 104 185 104 148 104 Category 1 Pending 2,092 680 282 165 24 42 190 42 34 42 34 42 Category 4 City Sites 1,8801,884 1,8801,884 627628 627628 627628 - Category 11 Religious Sites 257 130129 32 32 32 3432 Category 12 Parking Lots 96105 953 -13 -13 113 -13 All Remaining Categories 6,775 6,289 6,775 6,289 1,694 1,572 1,694 1,572 1,694 1,572 1,694 1,572 ADUs 376352 249232 5653 87 162151 2321 Total 13,549 11,070 9,946 9,168 2,560 2,444 2,712 2,398 2,742 2,542 1,933 1,784 RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702 Buffer +4,654 2,175 +3,779 3,000 +1,163 1,047 +1,315 1,001 +1,070 870 +231 82 5224% C. Accessory Dwelling Units Accessory Dwelling 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 8.B.c Packet Pg. 206 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 114Chapter 4 | Summary of Land Available for Housing Source: Open Scope Studio calculations, providing more permissive development of ADUs. Figure 4-5 and Map 4-2 summarize ADU development and locations 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 owners take advantage of the new ability to establish sometimes multiple ADUs with existing multiple-unit residential and mixed-use developments. Figure 4-5: Santa Monica ADU Production Building Permit Year Permits Issued Total 2018 2354 56 2019 6051 83 2020 4127 115 2021 1022 27 TOTAL 226134 281 Average 2018-2020 (23+6+41+102)/4=56.5 (54+51+27)/3=44 units per year Source: Building permit data as of June 1, 2021 May 31, 2022. Each ADU building permit is only accounted for once across all years. 8.B.c Packet Pg. 207 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 115 City of Santa Monica | 2021 - 2029 Housing Element Map 4-2: ADU Locations Sources: Esri, Airbus DS, USGS, NGA, NASA, CGIAR, N Robinson, NCEAS, NLS, OS, NMA, Geodatastyrelsen, Rijkswaterstaat, GSA, Geoland, FEMA, Intermap and the GIS user community, Sources: Esri, HERE, Garmin, FAO, NOAA,USGS, © OpenStreetMap contributors, and the GIS User Community ADU Locations Zoning R1: Single-Unit Residential (188) R2: Low Density Residential (23) R3: Medium Density Residential (6) OP1: Ocean Park Single-Unit Residential (2) OP2: Ocean Park Low Density Residential (7) Per State law, a projection of the number of ADUs expected to be built within the 8-year planning period can be counted towards the RHNA. However, this projection must be based on the following factors: • The number of ADUs or JADUs developed in the prior planning period; • Community need and demand for these types of housing units; • The resources and/or incentives available that will encourage the development of ADUs; • The availability of ADUs and JADUs for occupancy; • The unit must meet the Census definition of a housing unit and be reported to the Department of Finance as part of the annual City and County Housing Unit Change Survey; and • The anticipated affordability of these units. 8.B.c Packet Pg. 208 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 116Chapter 4 | Summary of Land Available for Housing In order to project the increased potential of ADU development, HCD recommends the following options: • Use the trends in ADU construction since January 2018 to estimate new production. • Assume an average increase of five times the previous planning period construction trends prior to 2018. • Use trends from regional production of ADUs. • Include programs that aggressively promote and incentivize ADU and JADU construction. As shown in the Figure 4-5 based on ADU building permit data between 2018 and 20210, Santa Monica averageds 5644 ADUs per year. However, given that 36 of the ADUs (approximately 16%) were located on parcels with existing multi-unit dwellings, which are less typical applicants for ADUs, the average annual production estimate has been reduced by 16% to approximately 47 ADUs per year. Therefore Using this average production number, it can be expected that over the next eight-year Housing Element cycle, approximately 376352 ADUs will be built and can be used towards our RHNA. This estimate is conservative, as it accounts for a potential progressive decline in available land for ADU within single-unit zones. As noted, tThis forecast also does not account for possible future interest in ADUs to be incorporated into existing multiple-unit residential and mixed-use developments, which the City has only just started seeing very recently as the new law permitting this only took effect January 1, 2020. In order to determine assumptions of ADU affordability in the Southern California region, SCAG conducted a regional analysis of existing ADU rents. Figure 4-6 shows assumptions for ADU affordability based on the SCAG assumptions. Determining ADU Income Levels SCAG conducted a regional analysis of current market rents that can be used to obtain credit towards each income category in the RHNA. SCAG’s analysis was pre-certified by HCD and allows cities to assume that the total anticipated ADU production would be assigned to the following income categories: • Extremely Low – 15%• Very Low – 2%• Low – 43%• Moderate – 6% • Above Moderate – 34% 8.B.c Packet Pg. 209 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 117 City of Santa Monica | 2021 - 2029 Housing Element Figure 4-6: Estimated Affordability of Projected ADUs 2021-2029 Income Level Percent of ADUsa Projected # of ADUs Extremely Low Income 15%5653 Very Low 2%87 Low 43%162151 Moderate 6%2321 Above Moderate 34%128120 a Based on SCAG Survey of ADU Affordability D. Adequate Sites Alternative - Rehabilitation and Conversion of Existing Units Government Code Section 65583.1(c) allows for use of existing units to address up to 25 percent of the lower income RHNA by counting existing units made available or preserved through the provision of “committed assistance” to low- and very low-income households at affordable housing costs or affordable rents. This option is referred to as “Alternative Adequate Sites”. However, there are limited parameters under which substantial rehabilitation, conversion, or preservation of units can be counted and the Housing Element would be required to identify exactly how the city will guarantee compliance in order to grant the credit. The units must be: • Substantially rehabilitated and at imminent risk of loss to the housing stock • In a multi-unit rental or ownership housing complex of three or more units that are converted from non-affordable to affordable rental • Preserved at levels affordable to low- or very low-income households where the local government has provided those units with continued assistance The City has a history of dedicating revenues to support the rehabilitation of substandard housing units. From 2005 onward, the City provided Housing Trust Fund loans to nonprofit developers for acquisition, rehabilitation, and deed restriction. The City also provides housing assistance to existing residents through a number of programs and has a demonstrated history of working with willing property owners and tenants to grant project-based housing vouchers that might allow some units to qualify towards the RHNA. Further, the Housing Element includes Program 2.C allowing market-rate projects to comply with the AHPP through the acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Based on past performance, it is expected that the City will continue to preserve the existing at risk housing stock through the acquisition and rehabilitation of existing low-income units. However, it would be difficult to predict how many rehabilitated units could be counted towards the RHNA. 8.B.c Packet Pg. 210 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 118Chapter 4 | Summary of Land Available for Housing This Page Left Intentionally Blank 8.B.c Packet Pg. 211 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.c Packet Pg. 212 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Implementation Programs 8.B.c Packet Pg. 213 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 121 City of Santa Monica | 2021 - 2029 Housing Element The City is committed to implementing the goals and policies in Chapter 3 through the programs in this chapter. These programs have been developed through extensive community engagement and with consideration for actions necessary to achieve a compliant Housing Element. The programs reflect what realistically could be completed in the eight-year planning period. Each program includes background, a description of the program action, timeframe by which the action will be completed, and the City agencies responsible for oversight of the program. The City will be reporting on each of these programs as part of its Annual Progress Report to the California Department of Housing and Community Development. GOAL 1 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. Program 1.A By-Right Approvals For Housing Projects The City shall make permanent amendments to the Zoning Ordinance that are currently interim and make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to allow, at a minimum: 1) 100% affordable housing projects; 2) non-Downtown housing projects that are code-compliant or are granted specified modifications/waivers to be established in the Zoning Ordinance; 3) Downtown housing projects that do not exceed Tier 2 maximums and are code-compliant or are granted specified modifications and waivers to be established in the Zoning Ordinance; and 4) housing projects that include at least 20% of units on-site as affordable to lower-income households [Government Code Section 65583.2(c)], to be reviewed through a by-right process. The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. Such by-right projects shall still be subject to design review, provided that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. The City shall extend interim zoning amendments for process thresholds pending the full implementation of this program. Chapter 5: Implementation Programs 8.B.c Packet Pg. 214 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 122Chapter 5 | Implementation Programs The City shall also develop written procedures to implement the streamlined review process for eligible projects under SB35. The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process. Program Background: Based on consultation with both affordable and market-rate housing providers, the uncertainty presented by a discretionary approval process is a factor in whether to move forward with housing projects in light of other risks that are out of the City’s control including land costs, construction costs, and lender requirements. On March 10, 2020, in efforts to streamline the process for housing production, the City Council adopted changes to the LUCE, DCP and BAP as well as an emergency interim ordinance to allow 100% affordable housing projects and housing projects up to Tier 2 maximums that are subject to the protections of the HAA to be reviewed through a by-right administrative process. The emergency interim ordinance expires December 31, 2021, unless extended by the City Council. Additionally, according to Government Code Section 65583.2, if the Suitable Sites Inventory (SSI) contains sites that were used in a prior housing element planning period, the City must allow by-right a development on those sites if the project includes at least 20% of the units as affordable. Therefore, in order for the 5th Cycle Housing Element sites identified in the SSI to qualify for inclusion, the by-right process must be included in the LUCE, Zoning Ordinance, DCP and BAP, as applicable. • Timeframe: by March 31, October 15,2022 • Responsibility: City Planning Division; City Attorney Office • Objective: Allow a ministerial approval process based on objective standards for 100% affordable housing projects and housing projects that do not exceed Tier 2 maximums and are subject to the Housing Accountability Act. LUCE Tier System The LUCE created a tiered land use system based on increments of height and floor area ratio (FAR). Tier 1 establishes a base height and FAR while Tier 2 establishes additional height and FAR that can be requested if community 8.B.c Packet Pg. 215 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 123 City of Santa Monica | 2021 - 2029 Housing Element Program 1.B Streamline the Architectural Review Process and Ensure Design Review Objectivity for Housing Projects The City shall adopt new streamlining procedures to allow staff level design review for smaller housing projects and expedited design review of larger housing projects by shifting the design review process to before or concurrently with entitlement issuance. This will reduce processing timelines and increase certainty for housing providers. These procedural changes would involve amending the Municipal Code to assure that design review cannot unreasonably delay a housing project approval by, for example, placing limits on number of hearings and maximum time limits for design review. The amendments The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. also be clear that design review cannot be used to reduce density or deny a housing project. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency anticipating compliance with SB35 for applicable housing projects. Program Background: Santa Monica Municipal Code Chapter 9.55 establishes the Architectural Review Board (ARB), and, along with certain provisions of the City’s Zoning Ordinance, sets forth the City’s design review processes. For all new construction, additions or remodel of an existing building, in all zones except R1 (single-unit), the ARB must make findings in its design review of development including compatibility with surroundings and design that is expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity and individuality. While the findings, which have been in place since the 1970s, are not objective, the design review process occurs after project entitlements and focuses only on project design; as a result, the ARB’s review cannot be used to deny or reduce the density of a housing project. Additionally, while the City is currently not subject to SB 35 under the 5th Cycle Housing Element reporting period (2013-2021) because the City has regularly met its RHNA targets, it is anticipated that the City with be subject to SB 35 in the coming 6th Cycle Housing Element reporting period (2021- 2029), and will therefore be limited to use of objective design standards when reviewing housing projects eligible for SB 35’s expedited review process. • Timeframe: Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022 by September 30, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Streamlined housing approvals. 8.B.c Packet Pg. 216 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 124Chapter 5 | Implementation Programs Program 1.C Incentivize Housing Development On Surface Parking Lots In Residential Zones In order to provide new housing choices and affordability in high opportunity areas, the City shall adopt standards that incentivize housing production on surface parking lots in residential zones associated with existing commercial uses, including, but not limited to, removing density caps and commercial parking replacement restrictions, lot consolidation, street access to the project, and restoring underlying maximum allowable density. The City shall also adopt standards that incentivize housing production on surface parking lots associated with existing residential uses as long as the existing residential use is not removed. Program Background: There are approximately 108 residentially-zoned surface parking lots associated with an adjacent commercial use. Of those parking lots, 32 are identified as high or medium-high potential for housing in the SSI. The parking lots serve the adjacent boulevard-facing commercial uses. The existing multi- unit residential zones have density caps of 4-6 units regardless of the size of the property, which limits their capacity for housing potential. • Timeframe: by August 1, 2022 2023 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Incentivize housing production on underutilized sites that would not displace existing residential tenants. A typical “A-Lot” in Santa Monica. The residentially-zoned surface parking lot in the foreground with the associate commercial use in the background. 8.B.c Packet Pg. 217 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 125 City of Santa Monica | 2021 - 2029 Housing Element Program 1.D Reduce Minimum Parking Requirements For Housing Projects The City shall reduce minimum parking requirements for all housing projects by applying Parking Overlay 1 rates. Program Background: Analysis of total development costs for housing projects have shown that stringent parking requirements add significantly to the cost of housing construction. In 2017, the City eliminated parking minimums in the Downtown as part of the adoption of the Downtown Community Plan. Eliminating and/or reducing minimum parking requirements would allow a housing developer to choose the “right-size” supply of parking to meet demand as necessary, and would significantly reduce the cost of housing construction. • Timeframe: by August 1, 2022 June 30, 2023 • Responsibility: City Planning Division; Mobility Division; City Attorney’s Office • Objective: Lower the cost of housing production. The Downtown Community Plan eliminated parking minimum requirements in an effort to reduce construction costs. 8.B.c Packet Pg. 218 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 126Chapter 5 | Implementation Programs Program 1.E Revise The Design Standards In The Bergamot Area Plan (BAP) For Easier Understanding And To Support Housing Production The City shall modify the design guidelines in the BAP to establish objective standards to support housing production by increasing certainty for housing providers. The revisions to design standards will address at minimum: 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 to support housing production. The BAP should also consider the special housing needs of artists, such as live-work units, to promote artist residents in the Bergamot area. Program Background: The BAP was initiated to transition 142.5 acres of former industrial land into a walkable, sustainable, and 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. However, the design standards in the Plan are complex, unclear, onerous, and do not incentivize housing. As a result, since its adoption in 2013, only three housing projects have been proposed in the Bergamot area. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Provide clarity in the regulatory environment for housing and incentivize housing production in the Bergamot area. The Bergamot Area Plan was adopted in September of 2013, and covers 142.5 acres of former industrial land as well as the Beergamot Arts Center 8.B.c Packet Pg. 219 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 127 City of Santa Monica | 2021 - 2029 Housing Element Program 1.F Revise The Downtown Community Plan Development (DCP) Standards To Support Housing Projects The City shall modify the development standards in the DCP to ensure they are set at levels that can support the minimum AHPP requirements and to support feasible housing projects. The City shall also amend the development standards and AHPP requirements to ensure Tier 2 and Tier 3 Downtown housing projects are feasible. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will promote housing and ensure feasibility and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR shown in the table below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement. Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Minimum Tier 1 FAR/ Height with Rezoning Current Tier 2 FAR/Height Minimum Tier 2 FAR/ Height with Rezoning Curent Tier 3 FAR/Height Minimum Tier 3 FAR/ Height with Rezoning LT (East)12 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- LT (West)11 1.50/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- NV 31 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -4.0/84 ft BC (Promenade)12 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- BC (2nd/4th)25 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -- TA 52 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft 4.0/84 ft 4.0/84 ft OT 15 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- WT 6 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- 8.B.c Packet Pg. 220 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 128Chapter 5 | Implementation Programs The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. Program Background: The DCP was adopted in 2017 with a primary focus on producing thousands of new housing units at a range of sizes and affordability levels. The DCP provided both development and process incentives for housing projects through greater FARs relative to commercial development, no minimum parking requirements, and a ministerial approval process for typical mixed-use housing projects. In exchange for these strong incentives, Downtown housing projects are required to provide additional affordable housing and augmented fees for the portion of the floor area above Tier 1 maximums. Since DCP adoption, approximately 1,133 units have been approved in the Downtown with a lesser amount that have moved ahead into building permits. Of those 1,133 approved units, the vast majority were projects that pre-dated the DCP’s inclusionary housing requirements. The current FARs and heights allowed in the DCP are shown below: • Timeframe: by March 31, October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Continue to encourage housing production in Downtown area. The Downtown Community Plan was adopted in July of 2017, and covers the Downtown area between Wilshire Blvd and the I-10 from Lincoln Blvd west to Ocean Ave. 8.B.c Packet Pg. 221 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 129 City of Santa Monica | 2021 - 2029 Housing Element Program 1.G Incentivize And Facilitate The Development Of Accessory Dwelling Units (ADUs) Through An Adu Accelerator Program The City shall develop an Accessory Dwelling Unit Accelerator Program that will simplify the ADU process by providing property owners interested in constructing ADUs throughout all neighborhoods 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 further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year. Additionally, the City will review and update its locally adopted ADU Ordinance for consistency with State law. Program Background: An effective strategy to increasing the housing supply is facilitating the construction of Accessory Dwelling Units (ADUs), particularly in single-unit residential districts. Due to their smaller size and relatively lower cost of construction, ADUs can provide lower-cost housing opportunities within single-unit neighborhoods that are less accessible due to high housing costs. In 2020, the City approved an ADU Ordinance (SMMC Section 9.31.025) to incorporate State law requirements for ADUs and Junior Accessory Dwelling Units (JADUs). The ordinance further encourages the production of ADUs/JADUs by exempting them from parcel coverage or floor area calculations and provides for a ministerial approval process for all ADUs and JADUs. Since implementation of these new State laws, the City has seen an increase in ADU production and interest each year. • Timeframe: by December 31, 2022 June 30, 2023 • Responsibility: City Planning Division • Objective: Streamline approvals and facilitate development of ADUs. Program 1.H Adaptive Reuse Of Existing Commercial Buildings For Permanent Residential Use As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to encourage and incentivize the adaptive reuse of existing commercial tenant spaces citywide, for permanent residential use and also allow an adaptive reuse of existing ground floor commercial space for artists and live-work use. The City shall also adopt policy and zoning cChanges to incentivize the conversion of existing commercial tenant space to residential use include but are not limited to, such as relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements. 8.B.c Packet Pg. 222 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 130Chapter 5 | Implementation Programs Program Background: The COVID-19 pandemic has had a dramatic impact on the City’s commercial real estate market. Even prior to the pandemic, the retail industry had been struggling to compete with online retailers and the office market had started to trend downward. Empty storefronts and partially-occupied office buildings are not an uncommon sight in the City. With the downturn of retail and office real estate accelerated by the pandemic, the concept of converting commercial into residential has gained significant interest as another avenue to increase the supply of housing in the City. • Timeframe: by December 31, 2023 2024 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Increase flexibility for reuse of vacant commercial space to residential use. Program 1.I Ensure That Local Regulations Support Innovations In Construction Technology To The Extent Technically Feasible The City shall support innovative lower-cost, efficient, and environmentally sustainable construction techniques for housing. Program shall implement a streamlined building permit review process for housing projects utilizing innovative construction methods and technology, and project-based outcome-oriented permitting benchmarks. Program Background: New innovations in building and construction technology could help decrease both the time and cost of housing construction. This includes the use of modular/pre-fabricated (prefab) construction or the use of cross laminated timber. Prefab construction involves producing standardized components of a structure in an offsite factory, then assembling them onsite. When prefab construction is done at economies of scale, it can result in significant reduction in housing cost. Cross laminated timber (CLT) has recently started gaining traction in North America as a viable type of construction. In addition to being more sustainable, CLT can significantly reduce the time and labor costs for construction. • Timeframe: by December 31, 2023 2024 • Responsibility: City Planning Division; Building and Safety Division • Objective: Remove impediments to innovation in housing construction. 8.B.c Packet Pg. 223 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 131 City of Santa Monica | 2021 - 2029 Housing Element Program 1.J Rezoning By Revising Development Standards To Ensure That Housing Projects Are Feasible And Incentivized Over Commercial Development The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI inventory are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.02.75 to 3.25 with heights ranging from 55 feet to 65 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will promote housing to ensure ensure feasibility and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR shown in the tables below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement. Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Minimum FAR/Height with Rezoning MUBL – N of I-10 107 1.50/36 ft 1.75/36 ft 3.25/70 ft MUBL – Pico 15 1.50/36 ft 1.75/36 ft 2.00/45 ft MUBL – Pico (West of Lincoln) 4 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL – Main St 10 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL - Lincoln 107 1.50/36 ft 1.75/36 ft 2.50/55 ft MUB 59 1.50/39 ft 2.25/50 ft 3.25/70 ft GC (SMB)24 1.25/ -1.50/35 ft 3.25/70 ft GC (Lincoln)19 1.50/36 ft 2.00/36 ft 2.50/55 ft GC (Pico)4 1.50/36 ft 2.00/36 ft 2.00/45 ft NC 27 1.50/32 ft N/A 2.25/50 ft NC (Main)14 1.00/27 ft N/A 2.50/55 ft NC (Ocean Park)15 1.00/32 ft N/A 2.50/55 ft 8.B.c Packet Pg. 224 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 132Chapter 5 | Implementation Programs NC (Montana)15 1.00/32 ft N/A 2.50/55 ft IC 77 N/A N/A 3.00/65 ft OC 88 N/A N/A 2.75/60 ft HMU 39 1.50/45 ft 2.50/70 ft 2.50/70 ft Bergamot Area # Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Current Tier 3 FAR/Height Minimum FAR/Height with Rezoning BTV 35 1.75/32 ft 2.00/60 ft 2.50/75 ft 4.0/84 ft MUC – South of Nebraska, North of Expo Bike Path 19 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft MUC - remainder 49 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft CCS 8 1.50/32 ft N/A N/A 2.50/55 ft CAC 17 1.00/32 ft 1.00/60 ft 1.00/75 ft 2.50/55 ft The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and mofify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix requirements, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. Program Background: When the LUCE was adopted in 2010, its core strategy was to capitalize on the City’s extensive transportation system including the Metro Expo Light Rail and to protect the City’s residential neighborhoods with an emphasis on policies that discourage tenant displacement. This growth strategy has resulted in significant new housing production in the Downtown, but it has also perpetuated the historic patterns of housing segregation that remains to this day. Although all of Santa Monica is considered a high or highest resource area, there remain a handful of areas where housing would not be likely to develop due to FARs that are not high enough to support the City’s regulatory requirements. 8.B.c Packet Pg. 225 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 133 City of Santa Monica | 2021 - 2029 Housing Element The current FARs and heights allowed in the Zoning Ordinance are shown below: • Timeframe: by March 31, 2022 October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Support the production of affordable housing and encourage the equitable production of housing across the City. Program 1.K Adequate Sites Program To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower income units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing are allowed 100 percent residential use and require requiring residential use to occupy at least 50 percent of the floor area. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City complies with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations. Program Background: Government Code section 65583(f) and Government Code section 65583.2(h) states that where the inventory of sites does not identify adequate sites to accommodate the RHNA for lower income households, a program must be included to identify sites that can be developed for housing within the planning period. As the City will be accommodating more than 50 percent of the low- and very low-income regional housing shortfall on City-owned sites, the City must allow these sites in the inventory to accommodate 100 percent residential use and require residential use to occupy at least 50 percent of the floor area in a mixed-use project. • Timeframe: by August 1, 2022 June 30, 2023 • Responsibility: City Planning Division • Objective: Create opportunity to accommodate the City’s lower-income RHNA targets. 8.B.c Packet Pg. 226 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 134Chapter 5 | Implementation Programs GOAL 2 Housing production for all income categories including for the community’s workforce and most vulnerable communities. Program 2.A Establish A Moderate-Income Affordable Housing Zoning Overlay The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in at least three targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th Street/Santa Monica College Expo station. The moderate-income affordable housing overlay would allow a height increase of up to three additional stories or 33 feet, 50% density bonus, up to four incentives and concessions, no minimum parking requirements, and flexibility in unit size/unit mix in exchange for additional common area amenities. Program Background: AB 1763 amended State density bonus law (Government Code Section 65915) to allow 100% affordable housing projects unlimited density and up to 3 stories or 33 feet above maximum height limits within 1/2 mile of transit. The changes also provide relief from minimum parking requirements and allow requests for up to four incentives/concessions from local development standards. State Density Bonus law incentives for 100% affordable housing projects only applies to projects up to 80% AMI. The City’s Zoning Ordinance similarly defines 100% affordable housing as only including projects up to 80% AMI. As a result, there are no incentives for moderate income housing projects (serving households up to 120% AMI) even though the City has received a RHNA allocation for moderate income units. In the 5th Cycle Housing Element, the City did not meet its RHNA targets for moderate-income units. In addition, funding sources for 100% affordable projects generally focus on households earning up to 80% AMI and do not provide funding for moderate-income projects. Moderate-income housing units serve an important segment of Santa Monica workers and residents that do not qualify for lower-income affordable units yet cannot afford market rents. • Timeframe: by August 1, 2022 June 30, 2023• Responsibility: City Planning Division; City Attorney’s Office• Objective: Provide significant incentives for 100% affordable housing including moderate income households. 8.B.c Packet Pg. 227 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 135 City of Santa Monica | 2021 - 2029 Housing Element Program 2.B Right Of First Offer Ordinance For Nonprofit Affordable Housing Providers Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, tThe City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making non-profit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildings through this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable. Program Background: Acquisition and rehabilitation of existing housing and conversion to affordable units can preserve naturally occurring affordable housing while also providing existing residents the opportunity to maintain their housing at an affordable level and minimize overall tenant displacement. • Timeframe: by December 31, 20234• Responsibility: City Planning Division; Housing and Human Services Division; City Attorney’s Office• Objective: Support 100% affordable housing by assisting nonprofit affordable housing providers to be competitive in the land acquisition market. Program 2.C Update The City’s Affordable Housing Production Program To Increase The Number Of Affordable Housing Units At All Income Levels In order to increase the number of affordable housing units at all income levels such that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to maximize the contributions of the AHPP to achieving the RHNA affordable housing allocation and advancing the City’s affordable housing goals. Areas to be considered may include, but not be limited to: 8.B.c Packet Pg. 228 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 136Chapter 5 | Implementation Programs • Increase the threshold (to at least 6 units) at which projects are required to provide on- site or off-site affordable units. • Eliminate the current “menu” option of affordability requirements and instead establish a new base affordability percentage • Re-evaluate the in-lieu fee option for applicants to pay a fee instead of constructing affordable units to ensure that the fee supports the funding and construction of new affordable housing throughout the City; and • Evaluate the possibility of a mixed-compliance option that would provide applicants more flexibility in meeting AHPP requirements • Increase the minimum percentage of required off-site affordable units to be higher than the on-site option; • Allow projects to locate off-site affordable housing anywhere in the City that is not a disadvantaged area as defined by SB535, which includes socioeconomic and environmental metrics • Allow market-rate projects to comply with AHPP off-site option through acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Program Background: In 1990, Santa Monica voters adopted Proposition R, which requires 30% of all multi-family residential housing that is newly constructed in the City to be affordable for at least 55 years to and occupied by low- and moderate-income households. In July 1998, the City Council enacted an Affordable Housing Production Program (AHPP), requiring developers of market-rate apartment and condominium projects to contribute to affordable housing production and thereby help the City meet its affordable housing need. The current AHPP requires market-rate housing developers to select from a “menu” of options for the production of affordable housing (see table below). However, in 2013, the menu option of the AHPP was amended to add the extremely low-income option, and since that time, the menu 8.B.c Packet Pg. 229 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 137 City of Santa Monica | 2021 - 2029 Housing Element had the effect of producing many affordable units at the extremely low-income level at the cost of production of other income levels, with particular shortages happening at the 80% to 120% AMI income levels. In response, Option 1 (the extremely-low income option) was temporarily removed by adoption of Ordinance 26059(CCS) by the City Council on April 9, 2019 until November 26, 2019, which has since been extended by the City Council until February 28, 2022. This temporary elimination of the extremely low-income “menu” option had the effect of increasing the minimum inclusionary requirement to 10% of total units for Tier 1 projects, and 15% of Tier 2 and 3 projects affordable to 50% AMI households. AHPP Menu Option Tier 1 Tier 2/3 1 5% of the total units at 30% AMI 7.5% of the total units at 30% AMI 2 10% of the total units at 50% AMI 15% of the total units at 50% AMI 3 20% of the total units at 80% AMI 30% of the total units at 80% AMI 4 100% of the total units at 120% AMI Not applicable The AHPP also currently allows developers to fulfill their affordable obligation by providing units off-site or, in limited circumstances, paying an in-lieu fee. However, if a developer elects to provide affordable units off site, the units are required to be located within ¼ mile of the market-rate project, except that within the Downtown Community Plan area, developers of Tier 2 or Tier 3 housing project have the flexibility to locate the off-site housing anywhere within the Downtown. • Timeframe: by June 30, 2022 April 30, 2023 • Responsibility: Housing and Human Services Division; Economic Development Division; City Attorney’s Office • Objective: Ensure that the AHPP provides housing developers viable options for compliance. Program 2.D Update Density Bonus Ordinance To Ensure Consistency With State Law And Integration Into The City’s Land Use System 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 AHPP. The ordinance will clarify how to apply State density bonus law in the City’s commercial and mixed-use districts that do not have maximum density controls, including application of State density bonuses to floor area dedicated to residential uses. The amendments to the Municipal Code shall also set forth a voluntary by-right menu of incentives & concessions that do not require following the 8.B.c Packet Pg. 230 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 138Chapter 5 | Implementation Programs process under Government Code Section 65915(d) for approval. Requests for “off-menu” incentives and concessions may be requested pursuant to Government Code Section 65915(d). Program Background: 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 for 100% affordable housing projects. At the time of the update in 2020, the City deferred amendments that would clarify how to apply State Density Bonus Law to the City’s commercial and mixed-use districts, pending further study, which has been ongoing since December 2019. After the August 2020 update, Assembly Bill 2345 took effect on January 1, 2021, which expanded and enhanced development incentives for market rate projects that provide affordable housing. AB 2345 increases the maximum density bonus from thirty-five percent (35%) to fifty percent (50%). To be eligible for the maximum bonus of 50%, a project must set aside at least (i) fifteen percent (15%) of total units for very low-income households, (ii) twenty-four percent (24%) of total units for low-income households, or (iii) forty-four percent (44%) of for-sale units for moderate income households. Levels of bonus density between thirty-five percent (35%) and fifty percent (50%) are granted on a sliding scale • Timeframe: by March 31, 2022 October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Ensure consistency with State Law. Program 2.E Commit To The Production Of Affordable Housing On City-Owned/Publicly- Owned Land The City shall commit City-owned sites for the production of 100% affordable housing, with consideration of other community-serving purposes, including, but not limited, to green space, place making, and/ or community-serving commercial and revenue generating uses. The City shall plan for a minimum of 1,884 1,880 affordable housing units across available City- owned sites, which are located throughout the city, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first An RFP for a at least one city-owned site shall be issued by June 30, 2023. Future RFPs shall be staggered based on availability of resources. Subsequently, the City shall issue an RFP by 8.B.c Packet Pg. 231 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 139 City of Santa Monica | 2021 - 2029 Housing Element June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months. As has been done in the past, the City will use a variety of tools Tto facilitate 100% affordable housing development including but not limited to: • Facilitate appropriate zoning and process to support 100% affordable housing • Substantially reduced or free ground rent • Providing funding through local housing trust fund • Support applications for other funding sources for affordable housing (e.g. low-income- housing tax credits, grants, State funding, Federal funding) Further, 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. Program Background: As a built-out community, the City of Santa Monica has few remaining vacant sites for residential development. This shortage of vacant land necessitates the use of alternative mechanisms for providing sites for housing. In the past, the City has used such mechanisms as long-term leases of City-owned or publicly-owned land. City-owned land is subject to the same development standards as privately-owned land, but may benefit from additional flexibility in order to maximize the development potential for 100% affordable housing. An RFP to redevelop Parking Structure 3 located on the Third Street Promenade as affordable housing was issued in August 15, 2019 and a developer partner was selected is currently pending review. The Parking Structure 3 RFP required that proposals including a significant commitment to permanent supportive housing for people experiencing homelessness and established parameters for affordable housing including long-term income eligibility and affordability covenants, tenant selection from the City’s below-market-rate list, and allowance to target other populations such as working families, seniors, and artist live/work housing. 8.B.c Packet Pg. 232 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 140Chapter 5 | Implementation Programs • Timeframe: RFPs issued by June 30, 2023; June 30, 2025; June 30, 2027 by December 31, 2023 and Annual Ongoing • Responsibility: Housing Division: City Planning Division; Economic Development Division • Objective: Prioritize affordable housing production on city-owned land. Program 2.F New Affordable Housing Finance Programs To Enable Continued Provision Of Technical And Financial Assistance For Housing Production 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. The City has adopted policy on prioritizing our local funding through a Housing Trust Fund plan that includes spending commitments for affordable housing production and preservation for special needs and ELI households, including exploring new funding for conversion to deed-restricted, multi- unit developments in areas of affluence. The plan outlines a funding strategy for ELI households including seniors and persons living with disabilities. The City will continue to implement the policy and execute funding commitments to produce housing targeted to persons experiencing homelessness or at-risk of homelessness. Local funding through the Housing Trust Fund will also help support the production of at leats 1,880 affordable housing units production on City-owned/publicly owned land in accordance with Program 2E. On an ongoing basis, the City will continue to communicate with local affordable housing providers on potential housing projects based on funding availability. Financial and technical assistance shall be provided when resources are available and committed to nonprofit housing providers to the greatest extent possible to support the development of affordable housing, including special needs housing and arts housing. The City will research 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 Program Background: The City has historically provided technical and financial support to a variety of nonprofit housing providers to support affordable housing development through the local Housing Trust Fund. Since the dissolution of the City of Santa Monica’s Redevelopment Agency (RDA), the main funding source for the Housing Trust Fund comes from a 0.5% sales tax passed by the voters in 2016. Remaining funding sources, such as the affordable housing commercial linkage fee and the affordable housing in-lieu fee, and contributions from negotiated development agreements, do not provide sufficient funding to 8.B.c Packet Pg. 233 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 141 City of Santa Monica | 2021 - 2029 Housing Element fill the gap left from the loss of RDA funds. The City continues to work with nonprofit partners to seek out and apply for federal and state funding, as it has done in the past, which resulted in numerous successful funding efforts by nonprofit affordable housing providers. Santa Monica has been awarded a total of $10 million from the Local Housing Trust Fund (LHTF) program for the 2020 and 2021 funding rounds and is also eligible to receive an estimated $3.285 million from the first five years of the Permanent Local Housing Allocation (PLHA) entitlement program. The awarded State grants, as well as future State grants, are essential to Santa Monica’s ability to create affordable housing on City-owned land and further the goals of the City’s Housing Element. In the current environment, the City will need to think creatively and support efforts at the state and federal level to create new funding opportunities for affordable housing in order to maintain current productivity levels. This Housing Element commits City-owned land for 100% affordable housing. Because land acquisition is typically the largest cost driver for affordable housing, it is anticipated that use of City land will alleviate the impact of land cost on the feasibility of an affordable housing project and allow limited funding resources to be used more effectively in producing affordable housing. • Timeframe: Annual Ongoing • Responsibility: City Planning Division; Housing and Human Services Division • Objective: Seek innovative affordable housing financing tools to increase production. Program 2.G Expand Housing Choice By Facilitating The Development And Maintenance Of Special Needs Housing The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle. This includes the provision of new programs, services, infrastructure and amenities that can help seniors who choose to live independently remain in their homes as long as possible. Within legal constraints, encourage or require housing providers to assign affordable housing units designed for persons with disabilities, including physical or developmental disabilities, for use by those who require those features. The City shall encourage barrier-free construction and adaptation. Through the 5-year Consolidated Plan process, the City shall continue to identify housing and supportive service gaps for various special needs groups and propose policy and priorities based on the analysis. 8.B.c Packet Pg. 234 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 142Chapter 5 | Implementation Programs Program Background: Santa Monica has a significant residential population in classes protected by California State housing law, which include the elderly, Individuals with mental, physical, and developmental disabilities, large families, female-headed households, and homeless individuals and families without permanent housing. Finding access to resources and adequate, affordable housing is often challenging for individuals and families under such circumstances. Housing for seniors and those with disabilities should incorporate features that contribute to a barrier-free environment, ensuring that anyone who uses a wheelchair or other mobility device is able to visit a building, and accessibility to transit and services. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division; Building and Safety Division • Objective: Housing for individuals with special needs. Program 2.H Maintain Proposition I Monitoring The City shall monitor utilization of Proposition I authority through annual reporting of new “low rent- housing projects. Program Background: Article 34 of the State Constitution requires that any low rent housing project developed, constructed, or acquired by a public agency must first be approved by a majority of the voters living in that jurisdiction. 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 one- half of 1% of the total dwelling units existing in the city at the end of the prior fiscal year. This annual authorization may be carried over the three years. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Ensure the City continues to report on compliance with Proposition I. 8.B.c Packet Pg. 235 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 143 City of Santa Monica | 2021 - 2029 Housing Element Program 2.I Zoning For A Variety Of Housing Types Including Special Needs Housing And Housing Access For Persons With Disabilities The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law as needed regarding special needs housing types and residential land use classifications as needed. Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty. Program Background: Since the 2015 Zoning Ordinance update, the State has passed various laws that have removed barriers for special needs housing types, such as emergency shelters, group residential, and supportive/ transitional, as well as other residential land uses. These laws have been put into place to ensure that cities zone for a variety of housing types. • Timeframe: by December 31, 20223 and Annual Ongoing• Responsibility: City Planning Division; City Attorney’s Office; Housing and Human Services Division• Objective: Ensure the City is compliant with all State laws for special needs housing types and residential land uses. Program 2.J Prioritize Water And Sewer Service To Housing Projects With On-Site Affordable Units The City shall establish written procedures to grant priority to developments with on-site units affordable to lower-income households if availability of service is limited. Program Background: Government Code Section 65589.7 requires water and sewer service providers to establish procedures that grant priority water and sewer service to developments that include units affordable to lower- income households. • Timeframe: by December 31, 20223 • Responsibility: Public Works Department • Objective: Prioritize infrastructure service to developments with lower income units to support the production of affordable housing throughout the City. 8.B.c Packet Pg. 236 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 144Chapter 5 | Implementation Programs GOAL 3 Preservation of the existing supply of housing and prevent displacement of existing tenants. Program 3.A Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are Replaced The City shall amend the Municipal Code to adopt local requirements that make permanent and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced. As required by Government Code Section 65583.2(g)(3), the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity’s valid exercise of its police power (approximately 27,484 units), or (3) within the past five years were occupied by low or very low income households, shall be required to replace all of those units as affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth Government Code Section 65915(c)(3). Program Background: SB 330 (effective 01/01/21 through 01/01/25) and SB 8 (extended SB330 through 01/01/30) enacted a program that establishes unit replacement requirements and tenant protections for new housing projects proposing the demolition or removal of “protected units”, generally defined as units subject to any form of rent restrictions or price control. These “protected units” include rent-controlled units that must be replaced as part of a new housing project until SB330 sunsets in 2030. • Timeframe: by August 1, 2022June 30, 2023• Responsibility: City Planning Division• Objective: Protect existing residents by preserving existing rental housing stock; no net loss of units. 8.B.c Packet Pg. 237 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 145 City of Santa Monica | 2021 - 2029 Housing Element Program 3.B Develop Tenant And Landlord Programs To Address State And Federal Legislative Mandates Regarding Anti-Discrimination The City shall continue to implement programs throughout the City, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing in light of the loss of formerly affordable units due to vacancy de-control and Ellis withdrawals. The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles Program Background: Residents of Santa Monica adopted the City’s rent control law in 1979. Passage of the Costa-Hawkins Rental Housing Act in 1995 by the State Legislature gradually required vacancy de- control/re-control in apartments, and de-control of houses and most condominiums by January 1999; this enables apartment building landlords to raise the price of rent-controlled apartments to market rate when the unit is vacated and is to be rented to a new tenant, establishing a new base rent for the unit. This has allowed 74% of the rent-control housing stock to reset to market rents. Even with Santa Monica’s exception to the HUD payment standard granted in 2016, the vast majority of Santa Monica’s existing housing supply is out of reach for lower income households. With limited federal funding resources being allocated to cities, the demand for housing assistance outpaces available resources. The City’s progressive legal protections, such as the just-cause eviction protections in rent-controlled units, have contributed to keeping rent-controlled units affordable to current low- and very low– income tenants. In addition, to help reduce the impact of Costa-Hawkins, the City has developed an Housing aAnti-dDiscrimination ordinance (Santa Monica Municipal Code chapter 4.28), which prohibits various types of housing discrimination—such as refusal to rent, differential treatment, discriminatory statements--on the basis of disability, age, source of income, parenthood, pregnancy, or the potential or actual occupancy of a minor child. In 2015, as an affordable housing measure, the City added Source of Income as a protected class and then added an extra layer of protection with a pioneering definition for Source of Income. For the first time in Santa Monica and in California, the fair housing law expressly protected recipients of rental assistance such as Section 8. Furthermore, the City and has launched a 2-year pilot Right to Counsel program to assist tenants facing eviction. The City also provides one-time homeless prevention grants to households in danger of losing their housing. 8.B.c Packet Pg. 238 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 146Chapter 5 | Implementation Programs • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division (lead); Rent Control Board • Objective: Develop programs to address State and Federal housing mandates. Program 3.C Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing There are approximately 770 affordable, deed-restricted units that are at-risk of conversion to market rate in the next 10 years. The City will continue to monitor over this Housing Element cycle the status of the approximately 770 affordable deed-restricted at-risk projects units throughout within the City, ensure that required notice is given to tenants, advise property owners and tenants in advance of potential conversion dates, and assist in answering questions from residents of at- risk housing. As a part of the ongoing monitoring, the City will continue to provide information on maintaining long-term affordability and assist federally-funded housing properties with seeking funding assistance in applying for allocations of housing vouchers from the federal government to maintain housing affordability. On an ongoing basis, the City will continue to communicate with local affordable housing providers on conserving housing projects . The City will exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. Additionally, the City shall continue to report annually on research and implement strategies on conserving non-covenant residential units such as the approximately 27,484 rent-controlled units and naturally occurring affordable units. Program Background: The City has a variety of affordable housing projects, consisting of 3,902 deed-restricted residences that are currently serving the community. Publicly-assisted housing units with federal rental assistance subsidies are protected by covenants. Those units with covenants nearing expiration are considered “at-risk” of potential conversion to market-rate housing. According to the City’s local data, a total of 770 publicly-assisted housing units protected by covenants that are due to expire in the next 10 years. They are, therefore, at risk of potential conversion to market rate. These units serve seniors or persons with special needs, with one property serving families. In addition to the federal covenants, the affordability of the units in these projects is further protected through additional requirements or incentives that the City placed on their loans when they were constructed. Some units are considered to have a lowered risk of conversion to market rate because they are owned and operated by nonprofits whose mission is to create and maintain affordable housing. As the cost of conserving existing deed-restricted affordable units is far less than the cost of producing new ones, and the need for affordable units remains strong, efforts should be directed at ensuring the long-term affordability of these units for low-income households. 8.B.c Packet Pg. 239 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 147 City of Santa Monica | 2021 - 2029 Housing Element • Timeframe: Annually: staff will identify funds and work with nonprofits as necessary to secure at-risk units, where appropriate and feasible; Ongoing: Monitoring • Responsibility: Housing and Human Services Division • Objective: The City proactively monitors units at risk of conversion due to expiring covenants and takes actions to ensure their long-term affordability. Program 3.D Maintain An Acquisition And Rehabilitation Program 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 for acquisition and rehabilitation throughout the city. As outlined in Program 2.B, the City shall adopt a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer to acquire existing private properties as they become available for purchase. Program Background: The City provides Housing Trust Fund loans to nonprofit housing providers to assist with the purchase and rehabilitation of existing rental properties occupied primarily by low-income households. The acquisition and rehabilitation of existing housing and conversion to affordable rental units preserve naturally occurring affordable housing while also ensuring housing stability for existing tenants by allowing them to remain in their units at deed-restricted affordable rents. • Timeframe: Annual Ongoing• Responsibility: Housing and Human Services Division; Santa Monica Housing Authority • Objective: Protect existing residents by acquiring and rehabilitating existing housing. Program 3.E Maintain A Low-Income Residential Repair Program The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the City. Program Background: The City implements the Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants; and the Owner-Occupied Rehabilitation Program for low- and moderate-income owners. 8.B.c Packet Pg. 240 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 148Chapter 5 | Implementation Programs Minor home modifications improve physical access for people with disabilities and seniors that assist with independent living. Modifications are funded through the City’s Human Services Grants Program using Community Development Block Grant (CDBG) funds. • Timeframe: by 2024 • Responsibility: Housing and Human Services Division; Santa Monica Housing Authority • Objective: Rehabilitate 38 multi-unit dwellings and provide 20 minor home repairs. Program 3.F Enhance Code Enforcement Response To Housing-Related Violations The City shall continue to respond to residential building code violation complaints throughout the City. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day. Program Background: The Code Enforcement Division responds to complaints of violations of City building codes and in coordination with the Building and Safety Division, provides inspections and notices to property owners to bring their units into compliance. In the case of a residential building code violations that do not affect habitability, the City provides up to 30-days to correct the violation. If the work necessitates a building permit, the City provides up to 180 days to correct the violation (the life of the permit). In the case of substandard housing that affects habitability, the City requires the landlord to promptly commence the work to restore the unit(s) to a habitable condition and return tenants to their units through the Habitability Determination Form and Relocation Order and provide tenant protections (temporary relocation). • Timeframe: Annual Ongoing • Responsibility: Building and Safety Division, Code Enforcement Division, Housing and Human Services Division • Objective: Require property owners to respond to Building Code violations and complete routine maintenance on their residential buildings. 8.B.c Packet Pg. 241 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 149 City of Santa Monica | 2021 - 2029 Housing Element Program 3.G Maintain A Mandatory Seismic Retrofit Program The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle. Program Background: In March 2017, the City Council adopted a Seismic Retrofit Ordinance and the City implemented the Seismic Retrofit Program that proactively seeks to strengthen existing earthquake-vulnerable buildings and enhance the safety and security of their occupants. Nearly 2,000 commercial and residential buildings in the City were identified as potentially seismically vulnerable in need of possible structural improvement and are required to comply with the Program within established timeframes based on building types (20-year program overall). Ongoing seismic retrofit improvements to existing multi-unit residential buildings will help maintain the safety and structural integrity of the City’s aging housing stock. • Timeframe: Annual Ongoing • Responsibility: Building and Safety Division • Objective: Protect existing residents by ensuring the safety and structural integrity of existing residential buildings. Program 3.H Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units The City shall provide additional education and outreach to multi-unit property owners on available City programs to support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties. Program Background: Tenants in rent-controlled units who allege that their rental units need repairs or maintenance, or that their housing services have been reduced, may petition to have their monthly rent decreased. In 2019, eighty decrease petitions were filed. Both the City and Rent Control Board co-sponsor an annual Maintenance of Residential Rental Property seminar and coordinate regarding relocation disputes, use of withdrawn properties, and maintenance and enforcement issues. Annual tenant and landlord forums also educate both groups on their rights and responsibilities including but not limited to available programs, resident qualifications, and benefits of program participation. 8.B.c Packet Pg. 242 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 150Chapter 5 | Implementation Programs • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division; Rent Control Board • Objective: Inform property owners regarding proper maintenance of residential units. Program 3.I Right To Counsel Program The City shall continue to implement a Right to Counsel pilot program and evaluate its overall effectiveness, program capacity, and long-term feasibility. Program Background: In April 2021, the City initiated a two-year pilot Right to Counsel program, an initiative to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This pilot program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. The program includes a contract with the Legal Aid Foundation of Los Angeles (LAFLA), the nonprofit law firm for low-income residents, to provide full-scope eviction defense services in which LAFLA attorneys will represent tenants in court. This partnership seeks to provide emergency support to low-income tenants in need of legal assistance. Under the City’s pilot program and Los Angeles County’s parallel program, StayHousedLA, LAFLA has already helped 40 Santa Monica tenants facing eviction obtain full-scope legal representation. Another 42 have received limited scope services. • Timeframe: Ongoing • Responsibility: City Attorney’s Office • Objective: Prevent the displacement of tenants by providing access to legal assistance and support for tenants facing eviction. Program 3.J Restrict Conversion Of Existing Rental Housing To Condominiums The City shall continue to regulate condominium conversions pursuant to SMMC Section 9.24.040. The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory. Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data. 8.B.c Packet Pg. 243 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 151 City of Santa Monica | 2021 - 2029 Housing Element Program Background: Displacement of residents due to economic pressure is one of the main contributing factors to housing segregation. Displacement and gentrification are widespread in Santa Monica with the Ellis Act and Costa-Hawkins Rental Housing Act allowing owners to either exit the rental business and evict all tenants or raise the rents of vacated rent-controlled units. Restrictions on condominium conversions are in place to ensure that required noticing is provided to tenants and that conversions can only occur if there is a surplus of rental housing inventory in the immediate period before approval of a conversion. Condominium conversions are currently regulated by SMMC Section 9.24.040. The Condominium Conversion ordinance sets out the conditions under which a condo conversion could be approved including: 1. Rent Control Board approval to remove units from the rental market 2. Tenants have been given required notice of intent to convert and to seek alternative housing 3. Preparation of a conversion report by City staff 4. Notice of any public hearings 5. Structural, electrical, fire and life safety, and plumbing systems are in good repair and maintenance 6. Findings as required by the Planning Commission including finding that the vacancy factor of rental housing units exceeds 5 percent of the total rental housing inventory for a period of 90 days prior to the date of approval. • Timeframe: Ongoing • Responsibility: City Planning Division • Objective: Restrict loss of rental housing units to condominium conversions. Conversion restrictions will continue to protect and retain older 8.B.c Packet Pg. 244 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 152Chapter 5 | Implementation Programs GOAL 4 A community that provides equitable housing access to all neighborhoods. Program 4.A Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Non-Residential Zones Where Not Currently Permitted 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 amended to add multi-unit housing as a permitted use in areas where housing is currently prohibited. Land use regulations, FAR, and height (as indicated in Program 1.IJ) will be revised to allow housing in the three areas zones that currently do not allow housing such as the Office Campus, Industrial Conservation, and Creative Conservation Sector zones. To promote fair and equitable housing opportunities throughout the City, the City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) including in areas that have historically not permitted or accommodated housing, to allow for higher maximum allowable FAR and height in the NC, IC, and OC zoning districts. For the purposes of addressing environmental health considerations, the City shall amend the Zoning Ordinance to specify locations in the City where housing projects are required to conduct an air quality assessment and implement recommendations from the assessment. Program Background: When the LUCE was adopted in 2010, its core growth strategy was to encourage housing in close proximity to major transportation systems, such as the Metro Expo Light Rail and transit corridors, and to protect the City’s residential neighborhoods by discouraging development that would result in displacement of tenants. The housing incentives were balanced with a plan to support the City’s economic base by incentivizing retention of existing commercial and industrial space in select areas of the City to support existing and growing businesses. This growth strategy has resulted in new housing production largely in the Downtown and some limited areas on the boulevards, but it has also perpetuated the historic patterns of housing segregation that remain to this day. Although all of Santa Monica is considered a “high resource” area based on maps produced by the California Tax Credit Allocation Committee, there remain a handful of areas that provide little to no housing opportunities. 8.B.c Packet Pg. 245 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 153 City of Santa Monica | 2021 - 2029 Housing Element • Timeframe: by August 1, 2022 October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Support the production of affordable housing and encourage the equitable production of housing across the City. Program 4.B Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses 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 community assembly uses, including religious congregations, including allowing not more than 50% market-rate units to support the affordable housing, unlimited, density, no minimum parking requirements, an additional 33 feet of building height, and allowance for the primary community assembly use and related ancillary use, for the support or expansion thereof, on or above the ground floor. Program Background: AB1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. Approximately fifteenseven parcels with religious congregations, which are classified in Santa Monica as community assembly uses, have large surface parking lots, have been identified on the SSI, and are located within high or highest resource areas. During the outreach process of the Housing Element, many of these religious congregations have expressed interest in developing housing on their properties; however, the Zoning Ordinance development standards for these sites severely limits the housing potential of these sites. • Timeframe: by August 1, 2022June 30, 2023 • Responsibility: City Planning Division • Objective: Increase equitable access to all residential neighborhoods and incentivize affordable housing in areas that have historically excluded diverse housing opportunities. 8.B.c Packet Pg. 246 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 154Chapter 5 | Implementation Programs Program 4.C Provide New Housing Choices And Affordability In High Opportunity Areas Through Incentives For Additional ADUs In R1-Zone Neighborhoods The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with Program 4.F. This would include allowing an additional ADU to be constructed if the ADU is deed restricted as a rental unit. As ADUs are naturally more affordable by design given their size, the program would help affirmatively further fair housing by helping to provide new housing choices and affordability in high opportunity areas of the City that are largely unaffordable to many people. Program Background: Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, 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. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City. 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. The vast majority of new ADUs constructed or under development in the past 3 years have been in the City’s R1 (single- unit) neighborhoods, providing a valuable source of rental housing access in otherwise high cost neighborhoods. Under State law, properties are permitted to have one ADU and one JADU. This program will further allow one more ADU on single-unit dwelling parcels with the requirement that the additional third ADU be restricted to permanent rental housing. This program will incentivize the production of ADUs thus providing new housing choice and affordability in the high opportunity areas of the R1 neighborhoods. • Timeframe: by August 1, 2022June 30, 2023 • Responsibility: City Planning Division • Objective: Increase equitable access to all neighborhoods by lowering barriers to housing access in areas that have historically excluded diverse housing opportunities. 8.B.c Packet Pg. 247 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 155 City of Santa Monica | 2021 - 2029 Housing Element Program 4.D Right To Return Program The City shall continue to implement a Right to Return Pilot Program and evaluate outreach strategies, applicant demand, the availability of historical documentation, verification processes, compliance with government legislation, and the administrative resources required to implement a broader long- term program. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. Program Background: In July 2021, the City initiated a Right of Return Pilot Program that prioritizes housing for the historically displaced households in Santa Monica during the 1950s and 1960s due to urban renewal policies. The pilot program implements historical displacement policy by providing housing access to former residents or their descendants who were displaced by the creation of the Civic Auditorium in the Belmar Triangle neighborhood and the I-10 freeway in the Pico neighborhood, both of which disproportionately impacted low-income communities and communities of color. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. Qualifying households will be placed on the City of Santa Monica’s affordable housing waitlist (Below Market Housing waitlist) with Second Priority and will be referred to affordable housing providers as housing units become available. • Timeframe: Annual Ongoing• Responsibility: Housing and Human Services Division• Objective: Address the historical displacement of Santa Monica households which resulted from the development of the Civic Auditorium and I-10 freeway through the Pico neighborhood during the 1950s and 1960s that disproportionately impacted low-income communities and communities of color and displaced thousands of households living in Santa Monica. Construction of the Civic Center Auditorium in 1957Source: Santa Monica Public Library 8.B.c Packet Pg. 248 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 156Chapter 5 | Implementation Programs Program 4.E PROVIDE NEW HOUSING CHOICES AND AFFORDABILITY IN HIGH OPPORTUNITY AREAS THROUGH INCENTIVES FOR SB9 UNITS IN R1-ZONE NEIGHBORHOODS The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. In addition, these SB9 units shall be required to be rented or sold. This will open up the possibility for property owners to construct up to 6 units through a multi-step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F. Program Background: Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, 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. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City. SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, is a state bill that requires cities to allow one additional residential unit onto parcels zoned for single-unit dwellings. Allowing homeowners proposing SB9 projects to also construct ADUs, particularly on larger parcels, will increase new housing opportunities in high opportunity areas and also promote place-based strategies for community revitalization by increasing housing opportunities in all areas of Santa Monica. • Timeframe: June 30, 2023 • Responsibility: City Planning Division • Objective: Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods 8.B.c Packet Pg. 249 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 157 City of Santa Monica | 2021 - 2029 Housing Element Program 4.F ESTABLISH TARGET TO INCREASE HOUSING PRODUCTION IN R1 ZONES AND INCLUDE MID-CYCLE MONITORING The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. • Timeframe: Assess progress by December 31, 2025 • Responsibility: City Planning Division • Objective: Increase the number of net new housing units in R1 zones GOAL 5 Housing for persons experiencing homelessness. Program 5.A Reduce The Number Of Homeless Individuals Living On The Streets Of Santa Monica Through The Provision Of A Range Of Housing Options, With An Emphasis On Affordable, Permanent, Supportive Housing The City shall continue to seek and leverage funds that contribute to the development of a range of permanent, supportive housing options, within and outside of Santa Monica. Focus case management and housing resources on the most chronic and vulnerable homeless individuals that have been identified on the City’s Homeless Service Registry. Continue to serve other priority homeless populations through City- funded programs. Continue strategies to reunite those not first-homeless in Santa Monica with family and friends in their home communities. Review City policies and practices that may contribute to homelessness. Program Background: Santa Monica has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. In March 2019, the City introduced the Four “Pillars” upon which the City’s homeless strategies are based; 1) preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities; 2) addressing the behavioral health needs of vulnerable residents; 3) maintaining equitable access to safe, fun, and healthy open spaces; and 4) strengthening regional capacity to address homelessness. These strategies have been implemented 8.B.c Packet Pg. 250 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 158Chapter 5 | Implementation Programs through interdepartmental and community partnerships that contributed to a sustained reduction in homelessness in the City’s downtown and beach areas, and helped contribute to an 8% local reduction in the City of Santa Monica’s annual Homeless Count in 2019. On an annual basis, the City supports agencies that provide supportive services, emergency shelter, and transitional and permanent supportive housing beds to Santa Monica’s priority homeless populations. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Continue to invest in and implement housing and supportive services to prevent and address the impacts of homelessness. Program 5.B Low Barrier Navigation Centers As By-Right Use The City shall amend the Zoning Ordinance to allow Low Barrier Navigation Centers as a by-right permitted use in all non-residential zones permitting multi-unit uses. Program Background: Assembly Bill 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multi-unit uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a housing first, low-barrier, service- enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter and housing. • Timeframe: December 31, 20223 • Responsibility: City Planning Division • Objective: Ensure the City’s regulations and procedures are in conformance with State Law. The Ocean Park Community Center (OPCC), an example of a Low Barrier Navigation Center in Santa Monica. 8.B.c Packet Pg. 251 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 159 City of Santa Monica | 2021 - 2029 Housing Element GOAL 6 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. Program 6.A Enhance Housing Mobility By Maintaining Rental Housing Voucher Programs Throughout the City And Expand To Assist All Persons With Disabilities The City shall continue to operate strong rental housing voucher programs throughout the City and advocate for funding guidelines for Section 8 that are competitive for Santa Monica; and shall pursue additional funding to maintain and expand voucher programs, if possible. Review and update the Housing Authority Administrative Plan annually to ensure compliance with the latest HUD regulations and to provide flexibility to respond to tenants’ needs consistent with legal requirements. Utilize vouchers as a tool to prevent senior homelessness where eligible. When funding opportunities are available, expand the rental housing voucher programs to fill the gap between income levels and the cost of housing for persons with permanent disabilities, including persons with Developmental Disabilities. Program Background: The Santa Monica Housing Authority (SMHA) administers two types of rental assistance vouchers, tenant-based and project-based, across five different federal housing programs: Housing Choice Voucher (HCV); Continuum of Care (CoC); HOME Investment Partnerships Program (HOME); Veterans Affairs Supportive Housing (VASH), and Emergency Housing Voucher (EHV) programs. Tenant-based vouchers are allocated to specific individuals, which allow participants to choose where to lease rental housing, whereas project-based vouchers are allocated to specific properties rather than participants. In FY20201-211, the Santa Monica Housing Authority (SMHA) administered approximately 1,600 rental housing vouchers, including Section 8, Continuum of Care vouchers, HOME vouchers, and Veterans Affairs Supportive Housing (VASH) vouchers. The HOME program targets rent-burdened households at-risk of becoming homeless and persons who have been homeless for at least a year. Of the 772 vouchers that were used, voucher households reside throughout Santa Monica’s multifamily neighborhoods, with no concentration in one zip code. Five properties in Santa Monica representing senior and supportive affordable housing with significant allocations of project- based vouchers are located in zip codes 90401 (Downtown), 90403 (Wilshire-Montana/Northeast) and 90405 (Ocean Park/Sunset Park) representing a total of 340 affordable housing opportunities. 8.B.c Packet Pg. 252 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 160Chapter 5 | Implementation Programs Distribution of Voucher Households 2017-2021 by Santa Monica Zip Code Tenant-Based Vouchers Project-Based Vouchers Total Rental Housing Vouchers 90401 (Downtown) Count 154 155 309 Percentage 31%57%40% 90402 (North of Montana) Count 2 0 2 Percentage 0%0%0% 90403 (Wilshire-Montana/Northeast) Count 44 102 146 Percentage 9%37%19% 90404 (Mid-City/Pico) Count 178 0 178 Percentage 36%0%23% • Timeframe: Annual Ongoing • Responsibility: Santa Monica Housing Authority; Housing and Human Services Division • Objective: Maintain voucher programs to ensure availability and choice of housing for households at all income levels. Program 6.B Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle to the extent feasible. 8.B.c Packet Pg. 253 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 161 City of Santa Monica | 2021 - 2029 Housing Element Program Background: The City monitors the availability of Federal, State, and County funding sources to support rental assistance programs on an ongoing basis. The City also undertook eviction prevention efforts to focus on keeping residents housed during the ongoing COVID-19 pandemic. The Legal Aid Foundation of Los Angeles (LAFLA) supported residents in maintaining housing through their general legal services program, which provides eviction defense services. Since April 2021, under the City’s Right to Counsel pilot program and County’s Stay Housed LA Program, LAFLA has provided 81 tenants facing eviction with legal representation. In FY2020-21 LAFLA’s general legal services program served 590 Santa Monica households utilizing $506,149 in Human Services Grants Program funding. The City also created an enhanced communications campaign to inform renter residents and property owners about the State Rental Assistance program, Housing is Key, and to support with application completion. Educational efforts focus on multilingual outreach to the most vulnerable residents who may not have access to online information. Application support was provided by City staff who answered questions, ran a clinic, and connected residents with the State’s help center and established partner organizations. As of June 7, 2022, 2,207 Santa Monica households were served with an average assistance of $15,566 and $34,354,444 total funds paid. In addition to the State Rental Assistance program, the City implemented the COVID Emergency Rental Assistance Program (ERAP) using $2,549,979 in federal Community Development Block Grant funds (CDBG) and General Funds of $251,535 to provide three months’ rent up to $5,000 to 640 households economically impacted by COVID. A total of 1,106 applications were submitted; 104 households did not qualify for or declined assistance, and an additional 362 households were not offered assistance due to lack of funding (of these 86 received assistance through the LA County program). Funding for program administration came from CDBG and the re-purposing of a County homelessness grant through the Westside Cities Council of Governments (WSCCOG). The Los Angeles County Development Authority (LACDA) also administered a rental assistance program that opened in August 2020 to assist applicants throughout the County with a total of $133 million from the Coronavirus Aid, Relief, and Economic Security Act (CARES) and County General Funds. At the close of the program, 435 Santa Monica residents were awarded approximately $3.81 million in assistance through the County program. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Maintain housing stability for vulnerable individuals and households. 8.B.c Packet Pg. 254 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 162Chapter 5 | Implementation Programs Program 6.C Maintain And Expand The Preserving Our Diversity (Pod) Program The City shall continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. The program shall ensure that POD subsidies do not result in an increase in rents. The City intends the POD Program to serve at least 150 participants within this Housing Element cycle. Program Background: The City’s POD program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors to have a minimum amount of income remaining after rent is paid each month for food and medical expenses. Currently, the program is available for qualifying long-term senior residents. In FY2020-21, the POD program served 196 low-income senior households providing an average monthly assistance of approximately $500 per month, allowing participants to age in place. Applications for POD are accepted both online and by mail, with assistance for those seeking a reasonable accommodation. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Assist POD beneficiaries in achieving a basic needs budget. Program 6.D Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources The City shall prioritize additional education and outreach to tenants and landlords throughout the City 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. The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational webinars per year. Program Background: Rental housing vouchers provide extremely low- and very low-income households with rent subsidies to bridge the gap between what the household can afford and market rents, although there is a limit to the subsidy amount. The Santa Monica Housing Authority has collaborated with owners of senior housing developments to obtain hundreds of new vouchers allocated to the senior developments allowing property owners to fund rehabilitation and maintenance and ensuring long-term affordability for the existing tenants. The Municipal Code and State law require rental property owners to accept 8.B.c Packet Pg. 255 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 163 City of Santa Monica | 2021 - 2029 Housing Element Section 8 or housing vouchers and prohibit discrimination against an applicant based on source of income, including housing vouchers. Comments from tenants and landlords during the community engagement for this Housing Element update indicate that there continues to be lack of awareness of the availability of housing programs that could benefit both groups. • Timeframe: Ongoing subject to additional staffing resources • Responsibility: Housing and Human Services Division • Objective: Raise awareness of housing assistance programs and tenant and landlord rights and responsibilities. Maintain A Community Development Grant Program The City shall continue to fund supportive services that serve the priority homeless populations, striking a balance between existing programs that have demonstrated effectiveness and national best practices that are consistent with the City’s adopted Action Plan to Address Homelessness in Santa Monica. The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica. Program Background: Santa Monica currently provides funding to 19 nonprofit human service and housing development organizations supporting different programs through the Community Development Grant Program. These programs serve, in part, to assist homeless persons, very low–, and low-income households, and special need populations. Funds are provided through a broad array of funding sources including but not limited to the City’s General Fund, HOME, and Community Development Block Grant Fund. The Rent Control Department hosts several workshops and seminars for tenants and landlords throughout the year. Program 6.E 8.B.c Packet Pg. 256 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 164Chapter 5 | Implementation Programs • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Maintain a grant program to fund-programs that service priority homeless populations, lower-income households, and special needs populations. Program 6.F Provide Tenant Relocation Assistance The City shall continue to implement the Tenant Relocation Assistance program; periodically review existing City policies and ordinances and recommend modifications if deemed necessary, including but not limited to, additional support in locating new housing for displaced residents upon relocation. Program Background: The City’s Municipal Code provides several tenant relocation programs to protect tenants living in rent-controlled units, with certain exceptions. When a unit is withdrawn from the housing stock, or the landlord recovers possession of a unit, landlords are required to pay a relocation fee for each unit based upon the size of the unit. An additional fee is required if one or more of the tenants is a senior, disabled, or a minor. In lieu of providing financial relocation assistance, the landlord may provide actual physical relocation if the new unit is comparable to the original unit. • Timeframe: Annual Ongoing • Responsibility: City Attorney’s Office, Housing and Human Services Division, Rent Control Board • Objective: Provide displaced tenants with cash-based relocation assistance. Program 6.G Maintain A Temporary Relocation Program The City shall continue the Temporary Relocation Program, including program oversight and enforcement, and coordination in providing accommodations to minimize impacts to residents including emergency hotel vouchers for tenants who have been ordered to vacate their units by the City for code violations, safety improvements, or maintenance. The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated. 8.B.c Packet Pg. 257 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 165 City of Santa Monica | 2021 - 2029 Housing Element Program Background: This program is designed to provide housing for persons temporarily displaced as a result of repairs to their dwelling unit due to health and safety violations or to comply with mandatory programs such as the Seismic Retrofit Program. • Timeframe: Annual Ongoing • Responsibility: Building and Safety Division, Housing and Human Services Division • Objective: Provide housing for tenants temporary displaced from their units due to required maintenance. Program 6.H Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing The City shall maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws. Program Background: With the anticipated demographic changes resulting in an aging population and increased interest in enhancing opportunities to age in place and live independently, the Zoning Ordinance includes a reasonable accommodation procedure to enable persons with a disability to request an accommodation from land use and zoning regulations, policies and practices as needed to provide those individuals with an equal opportunity to use and enjoy a dwelling, consistent with fair housing law. • Timeframe: Ongoing • Responsibility: City Planning Division • Objective: Provide regulatory relief to enable housing access for disabled persons. 8.B.c Packet Pg. 258 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 166Chapter 5 | Implementation Programs GOAL 7 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. Program 7.A Maintain Fair Housing Enforcement And Outreach Programs The City shall continue to implement fair housing programs. The City shall educate landlords about discrimination and educate the real estate community on the necessity of ensuring that their practices meet the objectives of the fair housing laws. The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide and tenant application assistance and support to special needs populations including seniors, persons with disabilities, and individuals transitioning from institutional settings and individuals who are at risk of institutionalization. Program Background: The City Attorney’s Office, through its Public Rights Division (PRD), along with other government agencies, enforces federal, state and local fair housing laws. The PRD has an in-house attorney with expertise in fair housing law and a Spanish-speaking community liaison who works with the attorney. The PRD investigates discrimination complaints and offers education and programs to residents on their rights and responsibilities under the fair housing laws, and takes complaints involving housing discrimination based on all protected classes, but primarily on disability, family status, source of income, and race. Most of the cases are resolved informally, using demand letters, calls, and meetings to either to persuade the need for a change in what the landlord is doing or to conclude that there is insufficient evidence of a fair housing violation However, if there is sufficient evidence of ongoing fair housing violations and the landlord has refused to correct the problem, then the PRD often files a lawsuit in court to enforce the fair housing laws. Since 2007, the PRD hosts a Fair Housing Workshop twice a year. The workshop covers several topics, including reasonable accommodations for tenants with disabilities, the City’s Right to Return program, pandemic-related issues in fair housing, and source-of-income discrimination laws which protect Section 8 voucher-holders and users of rental assistance. All owners, property managers, attorneys, social-service providers, and tenants are invited to attend, free of charge. Over the years, hundreds of tenants and housing providers have attended. The PRD’s workshops continued even through the pandemic, with a switch to virtual settings. The 8.B.c Packet Pg. 259 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 167 City of Santa Monica | 2021 - 2029 Housing Element City has also made fair housing presentations to other local and regional groups. Just since April 2020, the City presented or even co-hosted housing rights events sponsored by Santa Monica Rent Control Board, the Legal Aid Foundation of Los Angeles, Western Center for Law & Poverty, Santa Monicans for Renters’ Rights, Fair Housing Council of San Diego, ACLU of Southern California, WISE & Healthy Aging, St. Joseph’s Center, and the Santa Monica Committee for Racial Justice. • Timeframe: Ongoing • Responsibility: City Attorney’s Office • Objective: Education of tenants and landlords of their rights and responsibilities under fair housing laws. Program 7.B Provide Tenant/Landlord Mediation And Legal Services The City shall continue to support tenant/landlord mediation and legal services assistance. Program Background: The Santa Monica Rent Control Board also mediates disputes between tenants and property owners that arise from rent control law. The City has also partnered with the Status Institute for Dispute Resolution at Pepperdine University School of Law to provide mediation services to help resolve landlord tenant for Santa Monica residents, free of charge. The Housing and Human Services Division funds the Los Angeles Legal Aid Foundation to provide legal services related to housing to low-income Santa Monica residents. Referrals are also made to local dispute resolutions services. • Timeframe: Ongoing • Responsibility: City Attorney’s Office; Rent Control Board; Housing and Human Services Division • Objective: Provide tenant/landlord dispute resolution services. 8.B.c Packet Pg. 260 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 168Chapter 5 | Implementation Programs Program 7.C Maintain The Anti-Discrimination And Tenant Protection Program The City shall continue to prevent discrimination, tenant harassment, and unlawful evictions through monitoring and enforcing of “just cause” eviction protections, and continue to provide fair housing services through the Public Rights Division of the Santa Monica City Attorney’s Office. The City shall review current laws and recommend any needed modifications to ensure protection of tenants to the maximum extent possible. Program Background: Santa Monica has long maintained anti-discrimination protections, which among other prohibitions, prevents a tenant from being evicted if the eviction is based on the tenant’s familial status, including tenant’s status of being married or having children. The Public Rights Division (PRD) of the Santa Monica City Attorney’s Office handles complaints, answers questions about possible violations of the Fair Housing laws in Santa Monica and investigates possible fair housing violations. • Timeframe: Ongoing • Responsibility: City Attorney’s Office; Rent Control Board; Housing and Human Services Division • Objective: Protect existing tenants from harassment and unlawful eviction. 8.B.c Packet Pg. 261 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 169 City of Santa Monica | 2021 - 2029 Housing Element A. Quantified Objectives Pursuant to Government Code Section 65583(b), the City has developed quantified objectives for housing production, housing rehabilitation, and housing assistance as required by State law. The following sets forth these objectives for the 2021–2029 planning period. 1. New Construction Objectives The City of Santa Monica was allocated 8,895 units, of which 6,168 units must be affordable, in the 2021-2029 Regional Housing Needs Assessment (RHNA) adopted by the Southern California Association of Governments (SCAG) and certified by the State Department of Housing & Community Development in March 2029. 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 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 5th 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 it unrealistic that the City will be able to achieve its 6th Cycle RHNA for affordable housing units. 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 be filled by sources other than the City. For privately-funded inclusionary units, the estimated cost to a developer is approximately $480,000. Figure 5-1 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. 8.B.c Packet Pg. 262 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 170Chapter 5 | Implementation Programs Figure 5-1: RHNA vs. Quantified Objective Household Income Category RHNA % of Total Quantified Objective % of Total Very Low 2,794 31%1,1161,150 1622% Low 1,672 19%654572 1011% Moderate 1,702 19%479351 7% Above Moderate 2,727 31%4,4593,180 6761% Total 8,895 6,7985,253 Source: City of Santa Monica Community Development Department The goal of 6,798 5,253 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 objectives reflect the lack of public financing available for affordable housing. Even with maximizing affordable housing on City-owned sites and the City’s inclusionary requirements from the AHPP and DCP, providing 69% of the future units as affordable will be difficult. The quantified objective aims for almost 5033% of units produced to be affordable to low and moderate er income households. This is in excess of the requirement set forth in the City’s Proposition R (passed in November 1990). Proposition R specifies that at least 30% of all new multifamily-residential housing constructed in the city on an annual basis be permanently affordable to low and moderate-income households with at least 50% of the newly constructed units required to be permanently affordable to low-income households. 2. Housing Rehabilitation and Conservation Objectives Housing Rehabilitation programs are important for maintaining the integrity of existing housing stock, preventing displacement of existing residents, preserving the overall quality of neighborhoods, and contributing to a higher quality of life. With respect to housing conservation, the City provides rehabilitation assistance through two main programs: • The Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants • The Owner-Occupied Rehabilitation Program for low- and moderate-income owners (typically used for mobile-home owners). 8.B.c Packet Pg. 263 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 171 City of Santa Monica | 2021 - 2029 Housing Element The City of Santa Monica’s goal for the Housing Element planning period is to support and fund the rehabilitation of 38 units of multi-family and provide 20 minor home repairs, as shown in Figure 5-2. A new program has been added for this Housing Element based on the analysis of affordable housing units with covenants that expire, putting them potentially at risk of losing their affordability. While the City has focused its efforts in recent years on new construction, acquisition and rehabilitation continues to be an important tool for conserving existing rental housing. The housing is restricted as affordable housing for a period ranging from 55-80 years. Such units were not ‘counted’ toward fair share housing production, but are consistent with the City’s policies for preserving affordable housing units. During the last Housing Element period (2014-2021), the City invested more than $33 million in the acquisition and rehabilitation of existing rental housing, creating four projects with 88 units for very-low and low-income households. Available funding continues to be a significant issue to support this program’s capacity at present levels. The Housing Plan therefore reflects a reduced quantitative objective for the acquisition and rehabilitation of 40 housing units affordable to very-low income households over the next eight years (Figure 5-2). The City will continue to seek funding sources to maintain this program and exceed the objective. The City’s housing and supportive services supports long-term residency and housing affordability. As outlined in the next section, the City has an aggressive program for funding housing and supportive services to special needs populations. These supportive programs help to conserve housing units in that rental/housing assistance, in the form of financial support and legal support for tenants against eviction, assist tenants in maintaining housing, prevent resident displacement, and preserve housing stock. Accordingly, an estimated number of housing vouchers and qualifying tenants for supportive services are reflected as “units” in Table 5-2 under the conservation objective: • The Preserving Our Diversity (POD) Program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors. It is estimated to include at least 150 participants within the next housing cycle. • Rental assistance voucher programs include Section 8, Continuum of Care, HOME Tenant-Based Rental Assistance (TBRA) vouchers, and Veterans Affairs Supportive Housing. The City will continue to provide an estimated 1,600 housing vouchers for qualified residents. 8.B.c Packet Pg. 264 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 172Chapter 5 | Implementation Programs • The City’s Right to Counsel Program is an initiative to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This pilot program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. Maintaining housing for low-income residents also contributes to the conservation of existing units. Assuming the current two-year pilot program will be renewed regularly and annual funding remains consistent over the next 8 years, the goal of the City is to provide assistance to an estimated 210 participants within the next housing cycle. Figure 5-2: 2021-2029 Housing Rehabilitation and Conservation Quantified Objective Income Category Rehabilitated Units Conservation Units Definition Multi-Family Rehabilitation Minor Home Repairs Acquisition & Rehabilitation POD Rental Assistance Vouchers Right to Counsel Very Low 0-50% of County MFI 19 10 40 150 1,600 0 Low 51 to 80% of County MFI 19 10 0 0 0 210 Moderate 81 to 120% of County MFI 0 0 0 0 0 0 Upper Over 120% of County MFI 0 0 0 0 0 0 Totals 38 20 40 150 1,600 210 58 2,0001,900 8.B.c Packet Pg. 265 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 173 City of Santa Monica | 2021 - 2029 Housing Element 3. Housing and Supportive Services The City of Santa Monica has an aggressive program for funding housing and supportive services to special needs populations. These include households with very low or extremely low incomes, persons with disabilities, large families, seniors, the homeless, and other persons in need of assistance. The City’s goals for housing assistance and supportive services during the 2021-2029 Housing Element period, contingent upon the availability of adequate funds and annual City Council approval, are: • Rental Assistance Vouchers: Continue to provide about 1600 vouchers, including Section 8, Continuum of Care, HOME Tenant-Based Rental Assistance (TBRA) vouchers, and Veterans Affairs Supportive Housing vouchers. • Homeless Services: Focus efforts on the priority populations defined in the Action Plan for Addressing Homelessness in Santa Monica: o The long-term chronic and vulnerable of the homeless population living on the streets of Santa Monica, including homeless veterans o Persons whose last permanent address is in Santa Monica o Vulnerable members of Santa Monica’s workforce o High users of local first responder services • Regional Partner: Continue to be an active partner in finding regional solutions to the problem of homelessness. • Health Care for Low Income Persons: Provide primary health care for over 2,700 low- income Santa Monica residents annually. • Legal Assistance: Provide legal advice and referrals to over 700 low-income Santa Monica residents in the areas of housing, government benefits, and family-law issues annually. • Senior and Disabled Services: Support and fund a variety of services for senior and disabled individuals, including: o Provide paratransit services for approximately 2,200 seniors and persons with disabilities annually. This includes providing approximately 1,400 one-way, escorted trips for people who need extra assistance, as well as limited after- hours taxi service. 8.B.c Packet Pg. 266 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 174Chapter 5 | Implementation Programs o Provide a range of health and mental health services, including health screenings, primary medical care, health education, peer counseling (individual, group, and family), caregiver services, and care coordination o Provide intensive care management services primarily to low-income Santa Monica seniors that include in-home assessments, purchase of services necessary to maintain the client in his/her home, benefits assistance, referrals to other agencies, and close monitoring of clients. o Provide care management and other support services in conjunction with the Santa Monica Police Department’s efforts to address elder abuse. o Through the non-profit WISE & Healthy Aging (WISE) Diner Meal Program, provide a well-rounded lunch to older adults at three City sites. Boxed meals were provided via pickup or delivery while COVID-19 restrictions were in place. o Provide home-delivered meals to approximately 300 home-bound seniors and persons with disabilities annually. With COVID-19, the need for home-delivered meals increased significantly, with about 650 individuals having accessed this service. o Provide ongoing operating support for WISE’s Adult Day Care Center serving frail seniors, including seniors with Parkinson’s and Alzheimer’s Disease. o Provide expanded healthy living and arts programming, and opportunities for socialization for older adults with linkages to supportive services, through the consolidation of services in a one-stop facility. • Housing Modifications for Individuals with a disability: Continue to provide funding to the Disability Community Resource Center, which provides home modifications to low-income households that include a person with a disability. Modifications include the installation of grab bars, nonslip bath mats, ramps, shower benches, and toilet seat hand rails, as well as larger projects such as stair lift installations. Provide assistance to approximately 15 individuals annually. 8.B.c Packet Pg. 267 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.c Packet Pg. 268 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Glossary 8.B.c Packet Pg. 269 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 177 City of Santa Monica | 2021 - 2029 Housing Element 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 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. 8.B.c Packet Pg. 270 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 178Glossary 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 A household whose gross income does not exceed 30% of the area median income. 14. VLI: Very-Low Income A household whose gross income does not exceed 50% of the area median income. 15. LI: Low-Income A household whose gross income does not exceed 80% of the area median income. 16. Moderate-Income: 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 8.B.c Packet Pg. 271 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 179 City of Santa Monica | 2021 - 2029 Housing Element 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 27. DCP: Downtown Community Plan o LT: Lincoln Transition o NV: Neighborhood Village o BC: Bayside Conservation (Promenade) o BC: Bayside Conservation (2nd & 4th Streets) o TA: Transit Adjacent o OT: Ocean Transition o WT: Wilshire Transition 28. BAP: Bergamot Area Plan o BTV: Bergamot Transit Village o MUC: Mixed-Use Creative o CAC: Conservation: Arts Center o CSC: Conservation: Creative Sector 29. NOMA: North of Montana Neighborhood 30. Wilmont: Wilshire-Montana Neighborhood 8.B.c Packet Pg. 272 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 8.B.c Packet Pg. 273 Attachment: Housing Element (Chapters 1-5) Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E: Constraints on Housing ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●● ● ● ● ● ● ●●● ● ● ● ● ● 8.B.d Packet Pg. 274 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Table of Contents A. GOVERNMENTAL CONSTRAINTS ........................................................................................................................ 4 1. Land Use Controls .................................................................................................................................................... 4 a. Land Use and Circulation Element ............................................................................................................. 5 b. Zoning Ordinance .............................................................................................................................................. 8 i. Affordable Housing ...................................................................................................................................... 14 ii. Affordable Housing Production Program ........................................................................................ 14 iii. Community Benefits ................................................................................................................................... 15 iv. Parking Requirements................................................................................................................................ 15 v. State Density Bonus ..................................................................................................................................... 17 c. Downtown Community Plan ....................................................................................................................... 18 d. Bergamot Area Plan ........................................................................................................................................ 21 e. Civic Center Specific Plan ............................................................................................................................ 23 f. Local Coastal Program ................................................................................................................................. 24 2. Zoning for a Variety of Housing Types ........................................................................................................ 24 a. Accessory Dwelling Units /Junior Accessory Dwelling Units ...................................................... 27 b. Emergency Shelters ........................................................................................................................................ 32 i. Capacity for Emergency Shelters ....................................................................................................... 33 c. Employee Housing ........................................................................................................................................... 34 d. Farmworker Housing ...................................................................................................................................... 34 e. Group Residential ............................................................................................................................................. 34 f. Low Barrier Navigation Centers ............................................................................................................... 35 g. Manufactured Homes and Mobile Home Parks ................................................................................ 36 h. Residential Facilities ........................................................................................................................................ 36 i. Single-Room Occupancy Housing .......................................................................................................... 37 j. Supportive/Transitional Housing .............................................................................................................. 38 3. Zoning Regulations and Practices for Persons with Disabilities ..................................................... 39 a. Definition of a Family ....................................................................................................................................... 39 b. Definition of Disability ..................................................................................................................................... 40 c. Reasonable Accommodation .................................................................................................................... 40 4. Building Codes and Code Compliance ....................................................................................................... 41 a. Building Code Implementations ................................................................................................................ 41 b. Local Amendments ......................................................................................................................................... 42 c. Compliance and Enforcement .................................................................................................................. 44 5. On- and Off-Site Improvements.................................................................................................................... 44 6. Entitlement and Development Impact Fees ............................................................................................ 45 7. Entitlement and Permit Processing ............................................................................................................. 50 a. Processes and Thresholds ........................................................................................................................... 50 b. Ministerial Approvals ........................................................................................................................................ 51 i. Administrative Approvals ......................................................................................................................... 51 ii. Building Permit Only Projects ................................................................................................................ 52 c. Discretionary Approval.................................................................................................................................. 52 8.B.d Packet Pg. 275 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) i. Development Review Permit ................................................................................................................. 52 d. Architectural Review Board ........................................................................................................................ 54 e. Use Permits and Other Processes............................................................................................................ 55 i. Conditional and Minor Use Permits ..................................................................................................... 55 ii. Subdivision Maps .......................................................................................................................................... 57 f. State Law .............................................................................................................................................................. 58 i. Senate Bill 330 ............................................................................................................................................... 58 ii. Senate Bill 35 .................................................................................................................................................. 59 iii. Housing Accountability Act .................................................................................................................... 59 8. Local Measures, Propositions, Rent Control Law, and Ordinances ............................................. 60 a. Santa Monica City Charter Section 615 ................................................................................................. 60 b. Rent Control ......................................................................................................................................................... 61 i. Vacancy Decontrol ..................................................................................................................................... 62 ii. Just Cause Eviction ..................................................................................................................................... 62 iii. Tenant Harassment Protections ......................................................................................................... 64 iv. Relocation Assistance ............................................................................................................................... 64 v. Rent Control Dispute Resolution .......................................................................................................... 65 c. State of California, Article 34 ...................................................................................................................... 66 d. Home Sharing (Short-Term Rental) Ordinance ............................................................................... 67 e. Residential Leasing Requirements Ordinance .................................................................................. 68 f. City Anti-Discrimination Ordinances ..................................................................................................... 68 i. Sexual Orientation or Domestic Partnership ................................................................................. 69 ii. Persons Living with AIDS ........................................................................................................................... 69 iii. Families with Children ............................................................................................................................... 69 g. Rent Control Bootleg Unit Ordinance ..................................................................................................... 70 h. Water Neutrality Ordinance ....................................................................................................................... 70 B. NON-GOVERNMENTAL CONSTRAINTS ......................................................................................................... 72 1. Construction Costs ............................................................................................................................................... 72 2. Land Costs and Availability ............................................................................................................................... 73 3. Availability of Financing ...................................................................................................................................... 73 4. Requests for Housing Development at Reduced Densities .............................................................. 74 5. Length of Time Between Project Approval and Applications for Building Permits .............. 74 8.B.d Packet Pg. 276 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-4 INTRODUCTION The City of Santa Monica has consistently placed the provision of adequate and affordable housing for all residents as one of its primary goals. However, many factors can encourage or constrain the development, maintenance, and improvement of housing including governmental, market, construction, and infrastructure constraints. Pursuant to Government Code Section 65583(a)(5-6), this appendix identifies potential governmental and nongovernmental constraints and analyzes the extent to which the City can mitigate the negative impacts of these constraints where possible. A thorough understanding of the current constraints to housing development can help to create appropriate policy responses to mitigate constraints and make it easier and more affordable to develop housing. A. GOVERNMENTAL CONSTRAINTS Governmental policies and regulations can result in both positive and negative effects on the availability and production of housing. This section, as required by Government Code Section 65583(a)(5), describes and evaluates City policies and regulations that could potentially constrain the City’s ability to achieve its housing goals. Potential constraints to housing include land use controls (through General Plan policies and zoning regulations), development standards, infrastructure requirements, development impact fees, and development approval processes. While government policies and regulations are intended to serve public objectives and further the public good, the City of Santa Monica recognizes that its actions can potentially constrain the availability and affordability of housing to meet the community’s future needs. The City has implemented several measures, and proposes additional programs, to streamline the approval process and remove barriers to all types of housing throughout Santa Monica as described in this section. 1. Land Use Controls Land use controls, such as use regulations and development standards, have the most immediate impact on the location and construction of new housing. Below is a description of the various plans, documents, and other controls that set forth the goals, policies, and standards that affect both where various types of housing can be located in the City [see Section A(2) below] as well as the development standards and requirements that shape housing developments. Pursuant to Government Code Section 65940.1(a)(1)(B), all documents and standards summarized below can be found on the City’s Community Development Department website. 8.B.d Packet Pg. 277 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-5 a. Land Use and Circulation Element Santa Monica adopted its General Plan Land Use and Circulation Element (LUCE) in 2010 (subsequently updated in 2015 with the Zoning Ordinance update, 2017 with the adoption of the Downtown Community Plan, and 2020 with the revisions to housing process thresholds) which substantially revised the City’s land use policies, goals, and standards in non-residential zones but generally maintained the status quo in the city’s traditional residential neighborhoods. The overarching goal of the LUCE is to create significant new additional housing opportunities within transit-served areas in a manner that provides more affordable options, enhances sustainability, creates complete neighborhoods, and provides easy access to local services. Additionally, the LUCE established policies to preserve the existing pattern of uses for the protection and long-term conservation of established neighborhoods. To accomplish these goals, the LUCE implemented a variety of strategies including, but not limited to the following: • Encourage the creation of new housing in selected transit-accessible areas such as Downtown, Bergamot, and along the City’s boulevards. • Established Activity Center Overlays, which would provide opportunity to promote the creation of mixed-use gathering areas at transportation crossroads on parcels of sufficient size offering goods and services for the neighborhood, convenient transit access, and unique urban spaces. Each Activity Center relied upon cooperation from multiple property owners to consolidate large parcels, an area plan, and a development agreement for each individual project. • Establish a Neighborhood Conservation Strategy to promote the protection of housing in existing neighborhoods, much of which is under rent control, strengthen standards for demolition, and redirect growth to appropriate locations along transit corridors and in the vicinity of the Metro E (formerly Expo) light rail stations. • Establish a maximum base height for ministerial project review and require projects exceeding the base height to incorporate community benefits, such as additional affordable housing. The LUCE established 17 land use designations, as shown in Map E-1, grouped into the following five broad categories: • Neighborhoods • Boulevards • Mixed Use Centers • Employment and Commerce • Community and Public Uses 8.B.d Packet Pg. 278 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-6 Map E-1 LUCE Land Use Designations The LUCE encouraged the expansion of housing opportunities into new areas of the City with residential uses permitted in all but three (Industrial Conservation, Office Campus, and Parks and Open Space) of the 17 land use designations. While the implementing Zoning Ordinance established specific development standards, the LUCE set forth standards for building height, densities (in neighborhood designations), and intensities that establish the outer parameters for zoning. The LUCE does not specify maximum densities for non-neighborhood designations. Instead, density is regulated through building intensities such as Floor Area Ratio (FAR) and height which has provided flexibility to housing developments. In most land use designations, the LUCE also established a tiered system that affords additional building height and density (through traditional means or through an increase in FAR depending on the designation) beyond the base (Tier 1) standards for projects that provide community benefits or that are 100% affordable housing. However, these established outer parameters for Tier 1 projects, which were established in 2010, currently present constraints on the City’s ability to meet its updated housing goals due to low FARs and building heights that were demonstrated to be infeasible in studies conducted in the spring of 2021. Therefore, Housing Element Programs 1.F and 1.J propose to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production citywide. Figure E-1 presents the 17 LUCE land use designations and summarizes the base (Tier 1) height and density/intensity standards and the Tier 2 and 3 standards for projects which provide identified community benefits and/or 100% affordable housing developments. 8.B.d Packet Pg. 279 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-7 Figure E-1 LUCE Land Use Designation – Height and Density/Intensity Parameters LUCE Land Use Designation Max. Building Height and Density/Intensity Tier 1 Tier 2 Tier 3 100% Affordable Housing Neighborhoods Single-Unit Housing No tiers. Height: 28’ – 35’ depending on parcel size, dimensions, and location; Density: 1 du/parcel Low Density Housing No tiers. Height: 30’ – 40’ depending on parcel location; Density: 29 du/acre Medium Density Housing 30’ / 29 du/acre 40’ / 35 du/acre - 40’ / 35 du/acre High Density Housing 30’ / 35 du/acre 45’ / 48 du/acre - 45’ / 48 du/acre Boulevards Mixed Use Boulevard Low 32’ / 1.5 FAR 36’ / 1.5 FAR* 36’ / 1.75 FAR 47’ / 2.0 FAR 47’ / 2.0 FAR Mixed Use Boulevard (100% residential above ground floor) 32’ / 1.5 FAR 39’ / 1.5 FAR* 50’ / 2.25 FAR 55’ / 2.75 FAR 55’ / 2.75 FAR DCP – East Side of Lincoln Blvd: 50’ / 2.25 FAR - DCP – East Side of Lincoln Blvd: 60’ / 2.75 FAR DCP – West Side of Lincoln Blvd: 60’ / 2.75 FAR - DCP – West Side of Lincoln Blvd: 70’ / 3.25 FAR DCP – Wilshire Blvd West of Lincoln Blvd: 50’ / 2.25 FAR - - Mixed Use Boulevard (All Other Projects) 32’ / 1.5 FAR 35’ / 1.5 FAR* 45’ / 2.25 FAR 55’ / 2.75 FAR 55’ / 2.75 FAR DCP – East Side of Lincoln Blvd: 40’ / 1.75 FAR - DCP – East Side of Lincoln Blvd: 55’ / 2.75 FAR DCP – West Side of Lincoln Blvd: 50’ / 2.25 FAR - DCP – West Side of Lincoln Blvd: 55’’ / 3.25 FAR DCP – Wilshire Blvd West of Lincoln Blvd: 40’ / 1.75 FAR - DCP – Wilshire Blvd West of Lincoln Blvd: 40’ / 1.75 FAR General Commercial (Santa Monica Blvd) 32’ / 1.25 FAR 35’ / 1.5 FAR - 35’ / 1.5 FAR General Commercial (Lincoln & Pico Blvds) 32’ / 1.5 FAR 36’ / 1.5 FAR* 36’ / 1.75 FAR 2.0 FAR*** - 40’ / 2.0 FAR Mixed Use Centers Neighborhood Commercial 32’ / 1.5 FAR 1.75 FAR** - - 32’ / 1.75 FAR 40’ / 2.0 FAR (Pico Blvd) Bergamot Transit Village 32’ / 1.75 FAR 39’ / 1.75 FAR* 60’ / 3.0 FAR 75’ / 3.5 FAR 75’ / 3.5 FAR Mixed Use Creative 32’ / 1.5 FAR 36’ / 1.5 FAR* 47’ / 2.0 FAR 57’ / 2.5 FAR 57’ / 2.5 FAR Beach and Oceanfront 32’ / 1.5 FAR 36’ / 1.5 FAR* 47’ / 2.0 FAR 2.25 FAR*** - 47’ / 2.25 FAR Downtown Core Downtown Community Plan establishes development standards 8.B.d Packet Pg. 280 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-8 LUCE Land Use Designation Max. Building Height and Density/Intensity Tier 1 Tier 2 Tier 3 100% Affordable Housing Employment and Commerce Industrial Conservation Residential uses are not permitted Office Campus Residential uses are not permitted Healthcare Mixed-Use No tiers. Hospital Area Specific Plan establishes development standards Community and Public Uses Institutional/Public Lands/ Civic Center No tiers. Civic Center Specific Plan establishes development standards Office Campus Residential uses are not permitted * Height bonus for provision of on-site affordable housing. ** FAR bonus for provision of on-site affordable housing. *** FAR bonus for provision of additional affordable housing. b. Zoning Ordinance In 2015, the City completed a comprehensive update of its Zoning Ordinance to ensure consistency with the new policies, goals, and standards set forth in the LUCE and specified implementation mechanisms for achieving these policy standards. Through the Zoning Ordinance, land use regulations regarding where types of housing can be developed within the City and various development standards such as parcel size, density (for residential zones), number of stories, building height, parcel coverage/FAR, setbacks, and open space are provided for each of the City’s 21 zone district classifications governed by the Zoning Ordinance (as shown in Map E-2). Except in the City’s residential zones where traditional means of density are prescribed, density limitations are controlled through a combination of building height and FAR limitations. The Zoning Ordinance defines a “dwelling unit” as “one or more rooms designed, occupied, or intended for occupancy as separate living quarters, with full cooking, sleeping and bathroom facilities for the exclusive use of a single household” that exceeds 375 square feet. Additionally, the Zoning Ordinance and its associated land use regulations provide additional regulations for affordable units to ensure consistency with market rate unit sizes including standards for minimum unit sizes and unit mix/bedroom counts. Typically, these unit size requirements range from 500 square feet for a studio unit to 850 square feet for a two-bedroom unit. 8.B.d Packet Pg. 281 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-9 Map E-2 Zoning Ordinance Zone District Classifications While the Zoning Ordinance also implements the tiered development concept that was established in the LUCE, between the adoption of the LUCE in 2010 and the Zoning Ordinance update in 2015, Santa Monica’s growth management strategy fluctuated based on a multitude of factors that influenced how the community’s priorities were identified and addressed. This resulted in a reduced tiered system implemented in the Zoning Ordinance that eliminated the Tier 3 option identified in the LUCE for certain land use designations. The changes also removed four of the five “Activity Centers” which were intended to incentivize mixed-use residential development around the City’s transit stations through additional height above Tier 3 limits and FAR increases. As established in the LUCE, Tier 3 projects were voluntary and required a discretionary process and negotiated community benefits, while Activity Centers required cooperation of multiple property owners of large sites, an area plan, and individual development agreements for each project. As a result of the extensive process necessary to achieve Tier 3 or an Activity Center, the City moved toward a more standardized and simplified process through creation of an objective community benefits system. 8.B.d Packet Pg. 282 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-10 Even with the removal of these concepts, the City’s development standards are generous toward housing projects especially in mixed-use and commercial zones where setbacks are minimal (if any) and density limits are not established. The tiered system, with its provision of pre-established community benefits in exchange for increased building heights and densities/intensities, has also proven to be the preferred route for many housing developers to capture some level of additional development potential. However, based on feasibility testing conducted by the City’s economic consultant, current development standards such as low FAR and building height limitations have been identified to be constraints on the City’s ability to meet its updated housing goals. Additionally, other development standards such as minimum/maximum ground floor heights, active ground floor use requirements, daylight plane, and maximum building footprint have been brought to the City’s attention as other possible constraints. In some cases, a developer may apply for a modification or waiver to provide relief from these development requirements, but this adds time and uncertainty to housing project approvals. Therefore, Housing Element Program 1.J proposes to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production citywide. The new development standards for FAR and building height will be higher than existing standards and in some cases, higher than what was initially adopted as part of the original 2010 LUCE. Within the residential zone districts (R2, R3, R4, OPD, OP2, OP3, and OP4), housing development is subject to a density limitation based on a units per acre calculation or a total maximum number of units, whichever is less. Most of the City’s rent control and more naturally occurring “affordable” housing stock is located in these residential districts, and as such, the density limits are intended to prevent the widespread displacement of tenants in existing residential units, particularly rent control units. However, there are a number of residentially zoned sites that are developed as surface parking lots for commercial uses on boulevard fronting parcels. The current density limits, as well as other development regulations (such as access requirements), are an existing barrier to development of these surface parking lot sites. Therefore, Housing Element Program 1.C proposes to remove the density limits for these parcels and revise the Zoning Ordinance to incentivize the development of surface parking lots in residential zones. Figures E-2, E-3, and E-4 present the main development standards that control housing development within the City’s residential, commercial, and other zone districts, respectively. 8.B.d Packet Pg. 283 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-2 Development Standards in Residential Zone Districts Development Standard Residential Zone Districts R1 R2 R3 R4 OP1 OPD OP2 OP3 OP4 Minimum Parcel Size 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 4,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. Maximum Parcel Area per Unit (Density) Tier 1 – Base Standard 1 unit 2,000 (or 4 total units, whichever is less) 1,500 (or 5 total units, whichever is less) 1,250 (or 6 total units, whichever is less) 1 unit 2 units 2,000 1,500 1,250 Tier 2 – With Provisions of Community Benefits - - 1,250 900 - - - - - 100% Affordable Housing Projects - 1,500 1,250 900 - - - - - Maximum Parcel Coverage (% of Parcel Area) Base Standard 45% - 55% depending on number of stories and new/existing development Ground floor: 45% Upper Stories: 90% of allowable ground floor coverage Ground floor: 50% Upper Stories: 90% of allowable ground floor coverage Ground floor: 50% Upper Stories (% of allowable ground floor coverage): 2nd Story: 80% 3rd Story: 60% 4th Story: 50% 50% 50% 50% 50% 50% 100% Affordable Housing Projects - 90% of allowable ground floor 90% of allowable ground floor 50% of allowable ground floor 60% 60% 60% 60% 60% Maximum Building Height (Stories/Feet) Tier 1 – Base Standard 2 / 28’ -32’ depending on parcel size 2 / 30’ 2 / 30’ 3 / 30’ 2 / 20’ – 27’ depending on roof type 2 / 23’ – 30’ depending on roof type 2 / 23’ – 30’ depending on roof type 2 / 23’ – 30’ depending on roof type 3 / 35’ Tier 2 – With Provisions of Community Benefits - - 3 / 40’ 4 / 45’ - - - - - 100% Affordable Housing Projects - No limit / 30’ No limit / 40’ No limit / 45’ 2 No limit / 23’ – 30’ depending on roof type No limit / 23’ – 30’ depending on roof type No limit / 23’ – 30’ depending on roof type No limit / 35’ Minimum Setbacks Front Varies by street 20’ 20’ 20’ 15’ 30’ 20’ 20’ 15’ Sides 10% or 30% aggregate Parcel 50’ or greater: 8’ Parcel less than 50’: 4’ or 16% Parcel 50’ or greater: 8’ Parcel less than 50’: 4’ or 16% Parcel 50’ or greater: 8’ Parcel less than 50’: 4’ or 16% Development/ Parcel Specific Development/ Parcel Specific Development/ Parcel Specific Development/ Parcel Specific Development/ Parcel Specific Rear 15’ 15’ 15’ 15’ 10’ 15’ 15’ 15’ 15’ Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private - 60 sq. ft. 60 sq. ft. 60 sq. ft. - 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. Total - 150 sq. ft. 150 sq. ft. 150 sq. ft. - 150 sq. ft. 150 sq. ft. 150 sq. ft. 100 sq. ft. 8.B.d Packet Pg. 284 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Figure E-3 Development Standards for Commercial Zone Districts Development Standard Commercial Zone Districts MUBL MUB GC (Santa Monica Blvd) GC (Lincoln & Pico Blvds) NC NC (Main St) NC (Ocean Park Blvd & Montana Ave) Minimum Parcel Size 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. Maximum FAR Tier 1 – Base Standard 1.25 1.25 1.0 1.25 1.25 0.75 0.75 Tier 1 – Projects Including On-site Affordable Housing in Compliance with AHPP 1.5 1.5 1.25 1.5 1.5 1.0 1.0 Tier 2 – With Provisions of Community Benefits 1.75 2.25 1.5 1.75 (2.0 if on-site affordable housing provided) - - - 100% Affordable Housing Projects 2.0 2.75 1.5 2.0 1.75; 2.0, on Pico Blvd only 1.25 1.25 Maximum Building Height (Stories/Feet) Tier 1 – Base Standard 2 / 32′ 2 / 32′ 2 / 32′ 2 / 32′ 2 / 32′ 2 / 27′ 2 / 32′ Tier 1 – Projects Including On-site Affordable Housing in Compliance with AHPP 3 / 36′ 3 / 39′ if 100% residential above ground floor, 3/35′ for all other projects - 3 / 36′ 2 / 32′ 2 / 27′ 2 / 32′ Tier 2 – With Provisions of Community Benefits 3 / 36′ 3 / 45′ 2 / 35′ 3 / 32′ (3 / 36′ if on-site affordable housing provided) - - - Tier 2 – With Provisions of Community Benefits and 100% Residential Above the Ground Floor No limit / 36′ No limit / 50′ No limit / 35′ No limit to stories / 32′ (36′ if on-site affordable housing provided) - - - 100% Affordable Housing Projects No limit / 55′ No limit / 55′ No limit / 35′ No limit / 40′ No limit / 32′; 40′ on Pico Blvd only No limit / 32′ No limit / 32′ Minimum Setbacks Interior Side and Rear if Adjacent to Residential District 10’ 10’ 10’ 10’ 10’ 10’ 10’ Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. Total 100 sq. ft. 100 sq. ft. 100 sq. ft.. 100 sq. ft. 100 sq. ft. 100 sq. ft.. 100 sq. ft. 8.B.d Packet Pg. 285 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Figure E-4 Development Standards for Other Zone Districts Development Standard Zone Districts IC OC HMU OF Minimum Parcel Size 15,000 sq. ft. 15,000 sq. ft. 7,500 sq. ft. 5,000 sq. ft. Maximum Density - - - Parcels Along PCH between Santa Monica Pier and the north City limits: Parcels 4,000 sq. ft. or more: 1 dwelling unit/1,500 sq. ft. Parcels less than 4,000 sq. ft.: 1 dwelling unit/parcel if existing, no new dwelling units Maximum FAR Tier 1 – Base Standard 1.0 1.5 1.5 1.5; 0.5 for parcels located along the PCD between the Santa Monica Pier and the north City limits Tier 2 – With Provisions of Community Benefits 1.75 1.75 2.5 2.0 100% Affordable Housing Projects 2.25 - 2.5 2.25 Maximum Parcel Coverage - - - 70; 50 on parcels along the PCH between the Santa Monica Pier and the north City limits Maximum Building Height (Stories/Feet) Tier 1 – Base Standard 2 / 32′ 2 / 32′ 3 / 45′ 2 / 32’ – 30’ depending on roof type and location Tier 1 – Projects Including On-site Affordable Housing in Compliance with AHPP - - - 3 / 36′ Tier 2 – With Provisions of Community Benefits 3 / 45′ 3 / 45′ 5 / 70′ 3/47′ Tier 2 – With Provisions of Community Benefits and 100% Residential Above the Ground Floor - - - No limit / 47′ 100% Affordable Housing Projects No limit / 45′ - No limit / 70′ No limit / 47′ Minimum Setbacks Street Frontage - - - 5’ except for 20’. on PCH between northern City limits and Santa Monica Pier Side - - - Parcel specific Rear - - - 15’ if adjacent to a residential use; 25’ for beach rear setback on parcels over 100’. in depth located along the PCH between the Santa Monica Pier and the north City limits Interior Side and Rear if Adjacent to Residential District 15’ 15’ 15’ - Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private - - 60 sq. ft. 60 sq. ft. Total - - 100 sq. ft.. 100 sq. ft. 8.B.d Packet Pg. 286 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix E | Constraints on Housing E-14 i. Affordable Housing Santa Monica has consistently tried to remove barriers and incentivize 100% affordable housing projects in all of its zone districts citywide through the following methods: • Greater FAR, density, and building height allowances • No limit to the number of stories within the maximum building height • Parking reductions • Ministerial permit processing • No City Planning application fees or development impact fees • Compliance with California Assembly Bill (AB) 1763 (addition of 3 stories or 33’ in height, four incentives/concessions, no parking requirements) Through new Housing Element programs and concepts, such as the Moderate Income Housing Overlay identified in Housing Element Program 2.A, Santa Monica will continue to provide and expand benefits for 100% affordable housing projects throughout the City. ii. Affordable Housing Production Program The City’s Affordable Housing Production Program (AHPP), implemented through Santa Monica Municipal Code (SMMC) Chapter 9.64, requires that residential and mixed-use projects of two or more units contribute to affordable housing production to assist the City in addressing its overall affordable housing needs. Figure E-5 summarizes the options for fulfilling the City’s AHPP requirements through a menu option. However, Housing Element Program 2.C proposes revisions to the City’s AHPP, including re-evaluation of the minimum required percentage of on- site or off-site units, to determine the best means of achieving the City’s housing goals, which may include increasing the threshold for providing on-site units, adding flexibility in meeting goals through an in lieu fee or hybrid option, and increases to the number of units to be produced per project. To the extent Program 2 .C proposes amendments to the AHPP to increase the number of units that must be produced per project to increase the number of affordable units throughout the City, Programs 1.F and 1.J will ensure that the new FARs and building heights for housing projects that comply with the minimum AHPP requirements will be feasible. Figure E-5 Affordable Housing Production Program Options Projects with 2-3 Ownership Units OR 2+ Rental Units Projects with 4-15 Ownership Units Projects with 16 or More Ownership Units On-site Option 5% extremely low income units (option currently unavailable until after February 28, 2022); or 10% very low income units, or 20% low income units, or 100% moderate income units 20% moderate or 20% low or 10% very low income units 25% moderate or 25% low or 15% very low income units Off-site Option Same as on-site option 25% more than required number of on-site units 25% more than required number of on-site units Affordable $36.49/SF for apartments Not Applicable Not Applicable 8.B.d Packet Pg. 287 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-15 Housing Fee (2020) $42.62/SF for condominiums Unit Development Cost: $382,795.00 iii. Community Benefits The purpose of community benefits is to implement LUCE policies that require community benefits in exchange for increased development parameters. As discussed above, for a housing project to receive Tier 2 or 3 increased building heights and/or densities/intensities, the project must provide community benefits as prescribed in SMMC Chapter 9.23 or SMMC Section 9.10.070 for projects located within the Downtown Community Plan area. Community benefits consist of the following: 1. Housing (Increased provision of Affordable Housing and Unit Mix requirements) 2. Transportation Impact Fee 3. Open Space (Additional fee or provision of publicly accessible open space) 4. Transportation Demand Management (Preparation of a Developer TDM trip reduction plan, Transportation Allowance equivalent to 75% the cost of a monthly transit pass, and on-site shared bicycles) While some community benefits require on-site features such as increased affordable units and unit mix requirements (prescribed percentages and ratios of studio, two, and three bedroom units) , others only require increases to development impact fees (an additional 14% applied only to the increase above Tier 1) . While community benefits can add additional requirements and fees to housing projects, they are an elective process (i.e., voluntary Tier 2 or Tier 3 projects) and are offset by increased development potential. Furthermore, Housing Element Program 1.J will be reevaluating and increasing development standards (FAR and building height) in mixed-use and commercial zones to support housing production. The new FARs and building heights for housing projects will be based on feasibility analysis that takes into account development costs inclusive of the requirements for community benefits, local fees, local building code requirements, as well as affordable housing requirements in the City’s AHPP. Additionally, 100% affordable housing projects are deemed to have satisfied the housing community benefit requirement and are not required to provide additional community benefits. iv. Parking Requirements Figure E-6 summarizes Santa Monica’s parking requirements for residential uses throughout the City except for those areas governed by the Bergamot Area Plan (BAP). Single-unit dwellings are required to provide a flat rate of two parking spaces, whereas for other residential uses parking is calculated on a per-bedroom basis and in some cases per bed for certain housing types. 8.B.d Packet Pg. 288 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-6 Parking Requirements for Residential Uses, Excluding the Bergamot Plan Area Residential Use/Facility Citywide (Excluding Parking Overlay Area 1, Downtown Community Plan Area, and Bergamot Area Plan Area) Parking Overlay Area 1 Downtown Community Plan Area (Maximum Parking Allowed) Single-Unit Dwelling 2 spaces per dwelling unit 2 spaces per dwelling unit, which may be tandem 2 spaces per dwelling unit Accessory Dwelling Unit 1 space per dwelling unit 1 space per dwelling unit N/A Junior Accessory Dwelling Unit N/A N/A N/A Multiple-Unit Dwelling Market Rate Units: Guest = 1 space per 5 units Studio, no bedroom = 1 space per unit 1 bedroom = 1.5 spaces per unit 2 or more bedrooms = 2 spaces per unit Deed Restricted Affordable Units: Studio, no bedroom = 0.5 space per unit 1 bedroom = 0.75 spaces per unit 2 or more bedrooms = 1 spaces per unit Market Rate Units: Guest = 1 space per 10 units Studio, no bedroom = 1 space per unit 1 bedroom = 1 space per unit 2 or more bedrooms = 1.5 spaces per unit Deed Restricted Affordable Units: Studio, no bedroom = 0.5 space per unit 1 bedroom = 0.5 spaces per unit 2 or more bedrooms = 1 spaces per unit Market Rate Units: Guest = 1 space per 15 units Studio, no bedroom = 0.5 space per unit 1 bedroom = 0.5 space per unit 2 or more bedrooms = 1 space per unit Deed Restricted Affordable Units: Guest = 1 space per 30 units Studio, no bedroom = 0.25 space per unit 1 bedroom = 0.25 spaces per unit 2 or more bedrooms = 0.5 spaces per unit Senior Citizen Multiple-Unit Dwelling 0.5 space per unit Guest = 1 space per 5 units Low and moderate income units = 0.25 space per unit 0.5 space per unit Guest = 1 space per 6 units Low and moderate income units = 0.25 space per unit 0.5 space per unit Guest = 1 space per 6 units Low and moderate income units = 0.25 space per unit Single-Room Occupancy See Multiple-Unit Dwelling See Multiple-Unit Dwelling See Multiple-Unit Dwelling Group Residential 0.5 space per bed 0.5 space per bed 0.5 space per bed Congregate Housing 1 space per 5 beds 1 space per 5 beds 1 space per 5 beds Senior Group Residential 0.5 space per unit Guest = 1 space per 5 units Deed restricted affordable = .025 space per unit 0.5 space per unit Guest = none required Deed restricted affordable = .025 space per unit 0.5 space per unit Guest = none required Deed restricted affordable = .025 space per unit Elderly and Long-Term Care 0.5 space per bed plus one visitor space per 5 beds 0.2 space per bed 0.2 space per bed Residential Care, General If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds Residential Care, Limited None required other than what is required for existing residence None required other than what is required for existing residence None required other than what is required for existing residence Residential Care, Senior If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence Hospice, General If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence Hospice, Limited None required other than what is required for the existing residence None required other than what is required for the existing residence None required other than what is required for the existing residence Supportive Housing If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence Transitional Housing None other than what is required for residential type None other than what is required for residential type None other than what is required for residential type Live-Work 1 space per unit plus 1 guest space per unit 1 space per unit plus 1 guest space per unit 1 space per 500 sq.ft. 8.B.d Packet Pg. 289 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element E-17 Realizing the constraint parking can have on housing projects, the City provides the following alternatives to relieve and/or lessen parking requirements for new development: • Reduced parking requirements for deed-restricted affordable housing units • No minimum parking requirements for 100% affordable housing projects located within 1/2 mile of a major transit stop consistent with State density bonus law (AB 1763) • Reduced parking requirements for projects located in close proximity to transit, identified as Parking Overlay Area 1 • Reduced parking requirements for the provisions of car-sharing parking spaces. Parking is reduced by two spaces for every one car-sharing space provided, up to a maximum of 25% of the required parking spaces, not exceed 10 spaces • Allowance for shared parking in nonresidential zone districts for projects within close proximity to each other • Elimination of parking requirements and the need to replace displaced existing parking in conjunction with the construction/establishment of Accessory Dwelling Units and Junior Accessory Dwelling Units • No minimum parking requirements in the Downtown area Additionally, Housing Element Program 1.D proposes to revise minimum parking requirements for housing projects. As for the Downtown area, instead of minimum parking requirements, the numbers provided in Figure E-6 stipulate parking maximums. This regulatory shift from parking minimums to parking maximums has allowed housing providers to right-size their parking needs including the option to provide no parking at all in the City’s Downtown area. Unlike the majority of the City where residential parking requirements are based on bedroom count, residential parking in the BAP is based on unit count. Additionally, the BAP provides both minimum and maximum parking requirements which gives developers the ability to provide the appropriate amount of parking to serve each development. Also unique to the BAP is the concept of requiring less parking per unit when the plan area reaches 5,000 new parking spaces after the plan was adopted, which was in 2013. This eventual reduction will further lessen the constraint parking places on housing projects within the plan area. Figure E-7 summarizes the parking requirements for residential uses in the BAP. Figure E-7 Parking Requirements for Residential Uses in the Bergamot Plan Area Stage of Plan Development Minimum Space Required per Unit Maximum Spaces Permitted per Unit Tier 1 & 2 Tier 3 Tier 1 & 2 Tier 3 At Plan Adoption 1.5, of which at least 1.0 must be reserved 1.5, of which at least 1.0 must be reserved and 0.5 must be shared 2.0, of which no more than 1.5 may be reserved (With voluntary shared parking) 2.0, of which no more than 1.5 may be reserved At 5,000 Net New Spaces 1.0, which may be reserved or shared 1.0, which must be shared 1.5, of which no more than 1.0 may be reserved (With voluntary shared parking) 1.5, of which no more than 0.5 may be reserved v. State Density Bonus State law (California Government Code Section 65915-65918) requires cities and counties to approve density bonuses for housing developments that contain specified percentages of affordable housing units or units restricted to occupancy by seniors. A density bonus is the allocation of development rights that allows a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned. Projects that qualify for a density bonus are also eligible for reduced parking standards and additional concessions or incentives and waivers of development standards. The legislature has 8.B.d Packet Pg. 290 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-18 made frequent changes to State density bonus law over the years, including AB 1763 which significantly increased density bonus provisions for 100% affordable projects and AB 2345 which increased density bonus provisions for housing development projects that are not 100% affordable but qualify for a density bonus. The City’s density bonus law is outlined in SMMC Chapter 9.22, was last updated in 2020, but does not reflect certain recent changes in State law that became effective in 2021. As currently written, Chapter 9.22, applies to projects in the City’s residential districts, and to 100% affordable housing projects located anywhere in the City. When Chapter 9.22 was updated in 2020, the City deferred including provisions for application of the State Density Bonus Law for projects other than 100% affordable projects in the City’s nonresidential districts, which do not implement a maximum density control, pending further study. Nevertheless, in accordance with State law and City Council direction given on June 15, 2021, the City is implementing State density bonus law in all districts for all housing projects. As described in Housing Element Program 2.D, the City will update its density bonus ordinance to be consistent with State law requirements. c. Downtown Community Plan The Downtown Community Plan (DCP), adopted in July 2017, is a specific plan to implement the LUCE goals and policies for the City’s Downtown core. The DCP addresses important issues in the Downtown including, but not limited to, historic preservation, high quality architecture, sensitive urban design, diverse housing opportunities, sustainability, expansion of cultural arts offerings, additional open spaces that support quality of life, walkability, additional office space to meet the needs of creative businesses, and integration with the Metro E light rail stations. Map E-3 Downtown Community Plan Zone District Classifications 8.B.d Packet Pg. 291 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-19 The DCP established six zone district classifications as shown in Map E-3. Similar to the LUCE and Zoning Ordinance, the DCP specifies land use regulations regarding where various types of housing can be developed and various development standards such as parcel size, FAR, building height, setbacks, and open space for the zone districts it governs. The DCP also established a tiered system for developments with housing and community benefits specific to the DCP. These community benefits, as described in SMMC Section 9.10.070, include increased affordable housing, unit mix requirements, Transportation Demand Management plans, and increased fees for transportation impacts, open space, and affordable housing commercial linkage. As with other commercial zone districts within the City, the DCP does not impose density limits, but rather density is controlled through a combination of maximum building heights, FAR limitations, and other massing/siting development standards, which has provided flexibility for housing projects. Additionally, similar to the Zoning Ordinance, minimum dwelling unit sizes and unit mix/bedroom counts are prescribed for affordable units to ensure their consistency with market rate units. Overall, the DCP standards largely allow for the greatest amount of flexibility and incentives for housing developments within the City. Housing projects in the Downtown are given additional FAR and building height as compared to commercial projects. However, development standards such as low FAR and building height limitations have been identified to be constraints on the City’s ability to meet its housing goals. Additionally, development standards such a minimum/maximum ground floor heights, active ground floor commercial use requirements, daylight plane, and maximum building footprint have been brought to the City’s attention as other possible constraints. In general, while these standards can be perceived as onerous for housing developers, they have not precluded the development of housing in the Downtown, as demonstrated by the 20 applications for housing projects in the Downtown over the past 5 years, However, Housing Element Program 1.F proposes to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production in the Downtown area Increases to FAR and building heights for housing projects through Program 1.F will be based on feasibility analysis which has taken into account development costs inclusive of the requirements for community benefits, local fees, local building code requirements, as well as affordable housing requirements in the City’s AHPP. Figure E-8 presents the main developments standards that control residential development within the DCP zone districts. 8.B.d Packet Pg. 292 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-8 Development Standards for Downtown Community Plan Zone Districts Development Standard Downtown Community Plan Zone Districts LT (East) LT (West) NV BC (Promenade) BC (2nd & 4th Streets) TA OT WT Minimum Parcel Size 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. Maximum FAR Tier 1 – Base Standard 1.25 1.25 1.75 1.75 1.75 1.75 1.75 1.5 Tier 1 – With Housing 1.5 1.5 2.25 2.25 2.25 2.25 2.25 1.5 Tier 2 – With Provisions of Community Benefits 1.75 2.25 2.75 2.75 3.0 3.0 2.25 1.75 Tier 2 – With Housing and Provisions of Community Benefits 2.25 2.75 3.5 2.75 3.5 3.5 2.75 2.25 Tier 2 – With Housing for parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core - - - - - - - 2.75 Tier 3 – With Provisions of Community Benefits - - - - - 3.5 - - Tier 3 – With Housing and Provisions of Community Benefits - - - - - 4.0 - - 100% Affordable Housing Projects 2.75 3.25 4.0 3.25 4.0 4.0 3.25 2.75 100% Affordable Housing Projects – Parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core - - - - - - - 3.25 Maximum Building Height Tier 1 – Base Standard 32’ 32’ 32’ 32’ 32’ 32’ 32’ 32’ Tier 1 – Projects Including On-Site Affordable Housing In Compliance with AHPP 39’ 39’ 39’ 39’ 39’ 39’ 39’ 39’ Tier 2 – With Provisions of Community Benefits 40’ 50’ 60’ 60’ 60’ 60’ 50’ 40' Tier 2 – With Housing and Provisions of Community Benefits 50’ 60’ 60’ 60’ 60’ 60’ 50’ 50’ Tier 2 – With Housing for parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core - - - - - - - 60’ Tier 3 – With Provisions of Community Benefits - - - - - 84’ - - Tier 3 – With Housing and Provisions of Community Benefits - - - - - 84’ - - 100% Affordable Housing Projects 60’ 70’ 70’ 70’ 70’ 84’ 60’ 60' Minimum Setbacks Interior Side and Rear if Adjacent to Residential District 10’ 10’ - - - - - 10’ Minimum Open Space (% of Buildable Area) Lot Width of 50’ or Less - - - - - - - - Lot Width between 52- and 150’ 20% 20% 20% - 20% 20% 20% 20% Lot Width greater than 150’ 25% 25% 25% - 25% 25% 25% 25% 8.B.d Packet Pg. 293 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element E-21 d. Bergamot Area Plan The Bergamot Area Plan (BAP), adopted in September 2013, is a specific plan that provides guidance on transitioning former industrial lands of the Bergamot Area into an arts-focused, mixed-use, pedestrian-oriented neighborhood. As shown on Map E-4, the BAP established two main zone district classifications, Bergamot Transit Village (BTV) and Mixed Use Creative (MUC), with two conservation districts, Conservation Arts Center (CAC) and Conservation Creative Sector(CCS). Similar to the LUCE and Zoning Ordinance, the BAP specifies land use regulations regarding where types of housing can be developed and development standards such as FAR, building height, and open space for the zone districts it governs. The BAP also requires a minimum mix of uses for developments within the MUC zone district. As with the DCP and other commercial zone districts, the BAP institutes a tiered system for developments that provide community benefits and controls density through maximum building heights and FAR limitations. Additionally, similar to the Zoning Ordinance, minimum dwelling unit sizes and unit mix/bedroom counts are prescribed for affordable units to ensure their consistency with market rate units. Map E-4 Bergamot Area Plan Zone District Classifications 8.B.d Packet Pg. 294 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-22 However, unique to the BAP, is the concept of flexible standards. While some development standards are mandatory, others are flexible if it is determined that the project promotes design creativity, architectural innovation, and the vitality of the street and sidewalk environment and setting. Mandatory standards include FAR and building height, while flexible standards include mix of uses and open space standards. However, this concept of having flexible standards has led to more discretionary process for projects. Therefore, Housing Element Program 1.E proposes to revise the design standards in the BAP for easier understanding and support of housing production. Since adoption of the BAP, the transit and job-rich Bergamot area has experienced a lack of housing production. Two potential reasons for this may include insufficient Tier 2 development standard increases that would otherwise incentivize housing over commercial development and a general concern about risk and predictability with the development agreement process that is required to access the heightened Tier 3 development standards. Therefore, Housing Element Program 1.J proposes to reevaluate development standards and regulations , both independently and cumulatively, to not only ensure housing projects are feasible, but that but that they also incentivize housing production in the BAP area to meet the City’s housing goals. This program includes, but is not limited to, increasing FAR and building height limits. Figure E-9 presents the main developments standards that control residential development within the BAP zone districts. Figure E-9 Development Standards for Bergamot Area Plan Zone Districts Development Standard Bergamot Area Plan Zone Districts BTV MUC CCS CAC Maximum FAR (Parcel 100,000 SF or Greater / Parcel Less Than 100,000 SF) Tier 1 1.75 / 1.75 (25% FAR bonus for projects providing additional affordable units) 1.5 / 1.5 (25% FAR bonus for projects providing additional affordable units) 1.5 1.0 / 1.0 Tier 2 2.0 / 2.0 (25% FAR bonus for projects providing additional affordable units) 1.7 / 1.7 (25% FAR bonus for projects providing additional affordable units) - 1.0 / 1.5 Tier 3 2.5 / 2.5 2.2 /2.5 - 1.0 / 2.5 Maximum Building Height (Standard / Variation) Tier 1 32’ / 39’ if housing is provided 32’ / 36’ if affordable housing is provided 32’ / 36’ if live/work component is provided 32’ / - Tier 2 – With Provisions of Community Benefits 60’ / - 47’ / - - 60’ / - Tier 3 – With Provisions of 75’ / 86’ with increase ground 57’ / - - 75’ / 86’ with increase ground 8.B.d Packet Pg. 295 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-23 Development Standard Bergamot Area Plan Zone Districts BTV MUC CCS CAC Community Benefits floor-to-floor height floor-to-floor height Minimum Open Space - % of Site Area (Site Greater than 80,000 SF / Site 40,000 SF – 80,000 SF / Site Less than 40,000 SF) Tier 1 20% / 15% / 10% 15% / 12% / 7% 15% - Tier 2 20% / 15% / 10% 15% / 12% / 7% 12% 15% Tier 3 25% / 20% / 15% 20% / 15% / 10% 7% 10% Minimum Required Mix of Uses for Parcels over 120,000 SF - 50% Commercial / 50% Residential (Ratio can vary up to 10%) - - e. Civic Center Specific Plan The Civic Center Specific Plan, adopted in June 2005 with subsequent amendments, is unique in that it established a vision that promotes civic buildings and public open spaces and also provided standards that are more building specific for one of its four special use districts. Currently the plan area is built out and development of additional residential units, which would likely come from the redevelopment of existing buildings, would require an amendment to the plan. However, Housing Element Program 4.A will be removing limitations on where housing can be located within the City, which will enable greater housing opportunities in areas such as the Civic Center Specific Plan areas. Map E-5 presents the Civic Center Specific Plan Special Use Districts. Map E-5 Civic Center Specific Plan Special Zone District 8.B.d Packet Pg. 296 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-24 f. Local Coastal Program The California Coastal Commission (Coastal Commission), in partnership with coastal cities and counties, plans and regulates the use of land, water, and coastal resources in the Coastal Zone. The Coastal Zone in Santa Monica encompasses the mean high tide line as the western border and generally up to 4th Street north of Pico Boulevard and Lincoln Boulevard south of Pico Boulevard. For projects in the Coastal Zone, a Coastal Development Permit (CDP) is required, which is issued by the Coastal Commission unless a local government has a Commission- certified Local Coastal Program (LCP). CDPs are required for development activities broadly defined by the Coastal Act to include (among others) construction of buildings, divisions of land, and activities that change the intensity of use of land or public access to coastal waters. Currently, the City is in the process of certifying an updated LCP to reflect the combined policies, goals, and objectives set forth in the City’s LUCE, Zoning Ordinance, and DCP (all of which were adopted after the City’s existing LCP was partially certified in 1992). In October 2018, the updated Land Use Plan was adopted by the Santa Monica City Council (the first step in the process), but is still awaiting certification from the Coastal Commission. The Implementation Plan, which began in June 2019, is currently in progress. As the City does not yet have a certified LCP, housing projects within the Coastal Zone are required to obtain a CDP from the Coastal Commission before receiving a building permit from the City. While this can add both an additional process and timing constraint on housing projects, the City currently has no control over this process. 2. Zoning for a Variety of Housing Types The City of Santa Monica encourages and facilitates the development of a variety of housing types beyond traditional single-unit and multiple-unit dwellings. These additional housing types include such uses as accessory dwelling units and junior accessory dwelling units, emergency shelters, employee housing, farmworker housing, group residential, low barrier navigation centers, manufactured homes and mobile home parks, residential facilities, single-room occupancy housing, and supportive and transitional housing, as well as accessible housing for the disabled [see Section A(3) below]. Figure E-10 presents a comprehensive matrix of land use regulations compiled from all City implementation plans (Zoning Ordinance, DCP, BAP) that specify where and how each housing type is permitted. Of the 32 zone districts within Santa Monica, all but one (OS) allow for some type of housing. How each housing type is processed is identified with either a “P” for when the use is permitted by right, an “L” for the when use is permitted if it complies with specific limitations such as location or size, or either an “MUP” or “CUP” for when the use requires discretionary approval [see Section 7(e) below]. If the use does not have a process identified it means that the use is not permitted, and if an “L” is coupled with another process it either means that the use must comply with both processes or if separated by a “/”, the use must comply with the second process listed if it cannot abide by the first. 8.B.d Packet Pg. 297 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-25 While Santa Monica has made efforts to remove barriers to all housing types, some land use classifications and zoning implementations might not be consistent with updates to State law that have occurred since the City adopted its comprehensive Zoning Ordinance update in 2015. Therefore, Housing Element Program 2.I states that the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints, including those for persons with disabilities. Additionally, Housing Element Program 4.A proposes to amend the Zoning Ordinance and all specific plans to add multi-unit housing as a permitted use in all non-residential zones where housing is currently prohibited. Housing Element Programs 1.F and 1.J will also be reevaluating other restrictions that prohibit the location of housing, such as limitations on the ground floor. 8.B.d Packet Pg. 298 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-10 Permitted Housing Types by Zone District Residential Uses R1 R2 R3 R4 OP1 OPD OP2 OP3 OP4 LT NV BC (Prom.) BC (2nd/4th) TA OT WT MUBL MUB GC NC BTV MUC CAC CCS IC OC HMU OF CC PL OS RMH Single-Unit Dwelling P P P P P P P P P L(1) L(1) L(1) L(1) L(1) L(1) L(1) P P P P - - - - - - P P - - - - Accessory Dwelling Unit P P P P P P P P P P P P P P P P P P P P P P P P - - P P P - - - Junior Accessory Dwelling Unit P P P P P P P P P P P P P P P P P P P P - - - - - - P P - - - - Duplex MUP P P P - P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P - - - - - - - P - - - - Multiple-Unit Structure - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Senior Citizen Multiple- Unit Residential - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Single-Room Occupancy Housing - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Group Residential - MUP MUP MUP - - MUP MUP MUP MUP MUP, L(3) MUP, L(1) MUP, L(1) MUP MUP MUP MUP MUP MUP MUP P P CUP - - - - MUP L(1) - - - Congregate Housing - P P P - - P P P P MUP, L(3) CUP, L(1) CUP, L(1) MUP MUP MUP P P P P P P CUP - L(1) L(1) P P L(1) - - - Senior Group Housing - P P P - L(2) P P P P MUP, L(3) MUP, L(1) MUP, L(1) MUP, L(1) MUP, L(1) MUP, L(1) P P P P P P CUP - CUP CUP P P L(1) - - - Elderly and Long-Term Care - CUP CUP CUP - - CUP CUP CUP P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - P P P - - - - Emergency Shelters - - CUP CUP - - CUP CUP CUP L(6)/ CUP L(6)/ CUP CUP/ L(1) L(1/6), CUP L(6)/ CUP L(6)/ CUP L(6)/ CUP L(3)/ CUP L(3)/ CUP L(3)/ CUP L(3)/ CUP P P CUP - L(2)/ CUP L(2)/ CUP L(2)/ CUP CUP - P - - Residential Care, General - MUP MUP MUP - - MUP MUP MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - - - - P L(1) - - - Residential Care, Limited P P P P P P P P P P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Residential Care, Senior - L(2)/ MUP L(2)/ MUP L(2)/ MUP L(2) L(2) L(3)/ MUP L(3)/ MUP L(3)/ MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Hospice, General - MUP MUP MUP - MUP MUP MUP MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - - - - - - - - - Hospice, Limited P P P P P P P P P P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P - - - - - Supportive Housing P P P P P P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Transitional Housing P P P P P P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Live-Work - - - - - - - - - L(13) L(3/13) L(1/13) L(13) L(13) L(1/13) L(13) L(14) L(14) L(14) L(14) P P CUP P L(14) CUP L(14) - L(1) - - - Existing Mobile Home Park - - - - - - - - - - - - - - - - - - - - - P - - - - - - - - - - Mobile Home Park - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - P “P” = Permitted by right without discretionary action. “L(#)” = Limited uses, which are permitted by right, provided they comply with specific limitation. “MUP” = Use classifications that are permitted after review and approval of a Minor Use Permit. “CUP” = Use classifications that are permitted after review and approval of a Conditional Use Permit. “-“ = Not permitted 8.B.d Packet Pg. 299 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element E-27 The following analysis details how the City facilitates specific special housing types consistent with State law requirements. a. Accessory Dwelling Units /Junior Accessory Dwelling Units Accessory Dwellings Units (ADUs) play an important role in the production of housing particularly within single-unit residential zoning districts where historically only one unit is permitted per parcel. In recognition of this, the State over the past four years has enacted laws to help spur the production of housing through the development of ADUs. Building off of initial State law passed in 2017 that began removing barriers to ADU production, three new State laws [AB 68, AB 881, and Senate Bill (SB) 13] came into effect on January 1, 2020 that significantly expanded potential ADU development. Statewide, these new laws revised development standards that sometimes limited ADU construction such as eliminating minimum parcel size, establishing larger unit sizes based on bedroom count, reducing minimum side and rear setbacks, and removing on-site parking requirements. In addition, the new laws extended ADUs into multiple-unit residential and mixed-use zoning districts, introduced the new concept of deed restricted Junior Accessory Dwelling Units (JADUs) when in conjunction with single-unit dwellings, and established a strict 60-day processing timeframe and development parameters for ADUs that must be approved ministerially. On September 8, 2020, the City approved an ordinance incorporating these State law requirements into a new ADU/JADU section of the Zoning Ordinance, SMMC Section 9.31.025: Accessory Dwelling Units and Junior Accessory Dwelling Units. Additionally, to further encourage the production of ADUs and JADUs, the City expanded upon the new requirements by exempting all ADUs and JADUs from parcel coverage or floor area calculations and requiring only a ministerial process for review and approval of ADUs and JADUs. Additionally, no development fees are collected for the construction or establishment of ADUs or JADUs. Figure E-11 summarizes the main development standards adopted for an ADU or JADU consistent with State law. Figure E-11 ADU and JADU Development Standards Standard Requirement Minimum Parcel Size No minimum parcel size Maximum Number of Units Single-Unit Development: • One ADU or one JADU is permitted per parcel, except that one JADU and one detached ADU may be permitted on a single parcel • JADUs are only permitted within single-unit zone districts Multi-Unit Development: • Two detached ADUs AND/OR • Any area not used as livable space and that can be brought up to State building standards for dwellings, can be converted to at least one ADU or to a maximum number that equals 25% of the existing unit count. 8.B.d Packet Pg. 300 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-28 Standard Requirement Maximum Size ADUs: • Studio/1 bedroom – 850 square feet • 2+ bedrooms – 1,000 square feet or 1,200 square feet for parcels greater than 10,000 square feet JADUs: • 500 square feet Parcel Coverage / Floor Area Exempt Setbacks Rear and side setbacks – 4 feet Unit Requirements ADUs: • No interior access between the ADU and primary dwelling is permitted • Exterior access separate from the primary dwelling shall be provided • Independent eating and cooking facilities including, but not limited to, a sink, refrigerator, and a stovetop and/or oven shall be provided • Independent sanitation facilities including, but not limited to, a sink, toilet, and a shower and/or bathtub shall be provided JADUs: • Exterior access separate from the primary dwelling shall be provided; however, interior connection is permitted. • An efficiency kitchen that includes a cooking facility with appliances and a food preparation counter and storage cabinets that are of reasonable size in relation to the size of the JADU shall be provided • May provide individual or share sanitation facilities with the primary dwelling Parking • Additional on-site parking is not required for an ADU • Converted parking spaces are not required to be replaced Since implementation of these new State laws, the City has seen an increase in ADU production and interest, averaging 56.5 ADUs per year between 2018 and 2021 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 when State law began to focus on incentivizing ADUs. Figure E-12 Santa Monica ADU Production Building Permit Issuance Year Permits Issued 2018 5423 2019 5160 2020 2741 2021 2102 TOTAL: 134226 8.B.d Packet Pg. 301 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-29 Map E-6 ADU Locations 8.B.d Packet Pg. 302 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-30 8.B.d Packet Pg. 303 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-31 While Santa Monica has taken steps beyond what is required by State law to streamline and incentivize the production of ADUs, Housing Element Program 4.C proposes an ADU incentive program for single-unit residential zone districts. The incentive program will allow a property owner the ability to construct an additional ADU if they deed restrict one of the ADUs as a rental unit. This incentive program would help achieve the Housing Element goal of affirmatively furthering fair housing by providing more housing opportunities that are affordable by design within single-unit residential zone districts, which are areas of the city that have largely been unaffordable to many. To further remove barriers and help facilitate ADU production, Housing Element Program 1.G proposes to develop an ADU Accelerator Program to simplify the ADU process by providing prospective ADU developers 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. Additionally, to ensure compliance with State law, Program 1.G also includes language regarding continuing to review State law and updating the City’s locally adopted ordinance as needed. 8.B.d Packet Pg. 304 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-32 b. Emergency Shelters State law [Government Code Section 65583] requires each jurisdiction to identify one or more zoning districts where emergency homeless shelters are allowed without a discretionary permit. Additionally, Government Code Section 65583(a)(4) limits the development standards and locational restrictions that can be applied to emergency shelters. Emergency shelters may only be subject to those development and management standards that apply to residential or commercial development within the same zone except that a local government may apply written, objective standards that include all the following: • The maximum number of beds or persons permitted to be served nightly by the facility; • Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone; • The size and location of exterior and interior onsite waiting and client intake areas; • The provision of onsite management; • The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart; • The length of stay; • Lighting; and • Security during hours that the emergency shelter is in operation. Emergency shelters are defined in the Zoning Ordinance as “a temporary, short-term residence providing housing with minimal supportive services for homeless families or individual persons where occupancy is limited to six months or less, as defined in Section 50801 of the California Health and Safety Code. Medical assistance, counseling, and meals may be provided.” As shown in Figure E-10, emergency shelters are permitted by-right in the BTV, MUC, and PL zone districts with no limitations and by-right up to 55 beds in 13 other mixed- use/commercial zone districts (identified by the L2, L3, and L6 designations) . Additionally, SMMC Section 9.31.130 of the Zoning Ordinance sets forth standards for emergency shelters to ensure they do not adversely impact adjacent parcels or the surrounding neighborhood and that they will be developed in a manner that protects the health, safety, and general welfare of the nearby residents and businesses while providing for the housing needs of a vulnerable segment of the community. The standards include provisions and limitations on lighting, laundry facilities, common facilities, security, outdoor activity, services (including lengths of stay), maximum unit density, and health and safety standards. In terms of density, emergency shelters that are located in residential zone districts, when not developed in an individual dwelling unit format, are not subject to the underlying zone district’s maximum unit density standard, but the number of beds are limited to three times the maximum number of dwelling units which would otherwise be permitted on the site. Temporary shelter is also available to residents for no more than six months with extensions up to 180 days available if the 8.B.d Packet Pg. 305 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-33 shelter operator determines that no alternative housing is available. Additionally, minimum parking requirement for emergency shelters is one space per 10 beds, which is less parking required compared to other similar type of special needs housing. Therefore, the City is in compliance with State law by allowing emergency shelters by-right in at least one zone district and is within the limits of all development and management standards. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. Revisions will also include, but are not limited to, updated parking requirements for Emergency Shelters pursuant to AB 139. i. Capacity for Emergency Shelters Government Code Section 65583(a)(4)(A) requires the Housing Element to demonstrate that the zones where emergency shelters are allowed by-right include sufficient capacity to accommodate the need for emergency shelter identified in the most recent point-in-time count conducted before the start of the planning period. According to the most recent annual point-in-time homeless count performed in 2020 (2021 count cancelled due to COVID-19 restrictions), a total of 907 individuals were counted on the streets, in cars and encampments, and in shelters and institutions within the City. In order to determine the City’s capacity for emergency shelters, properties on the Suitable Sites Inventory (SSI) with development potential to accommodate emergency shelters were evaluated based on size and location to transit and services. According to the SSI, there are 11 10 parcels within the BTV and MUC zone districts of adequate size that can accommodate emergency shelters with no limitations on bed count and 178 118 parcels in the LT, NV, BC, TA, MUBL, MUB, and GC, NC, IC, and OC zone districts that limit emergency shelters to 55 bed per parcel. SFOf eExisting facilities accommodating an approximate range of 16-70 beds have oan average parcel size of 20,525 square feetXX, and of the 178128 SSI parcels, XX33 parcels would fall within this range SF, NV, BC, TA, MUBL, MUB, GC, BC, IC, and OC SF. Therefore, it can be concluded that the parcel sizes on the SSI can accommodate emergency shelters of at least 55 beds. In order to quantify the number of beds that can be established on sites with no bed count limit, a 160 square foot per bed size was applied based on both local analysis and County of Los Angeles standards . As shown in Figure E-13, the City has capacity of 3,013 3,83811,823 emergency shelter beds. Therefore, Santa Monica has sufficient capacity to accommodate its emergency shelter need based on the 2020 point-in-time count of 907. Figure E-13 Santa Monica Emegency Shelter Capcity Zone District Number of Parcels Total Land Area (SF) Emergency Shelter Bed Capacity LT** 214 141,68943,996 770110 NV** 181 22,651183,480 99055 BC** 4 82,478 220 8.B.d Packet Pg. 306 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-34 TA** 5 57,5820 275 MUBL** 5113 781,058467,399 2805715 MUB** 22929 499,449740,520273,121 15951210495 GC** 383 380,72981,457 2090165 NC** 14 92,5140 770 BTV* 1 38,54838,333 240240 MUC* 104 197,327287,036 1,7931233 IC** 1 19,662 55 OC** 4 26,117 220 Total: 3348189 2,590,3421,646,5691,124,283 11,8233,013838 * No limitation on bed count (160 SF per bed applied) ** 55 bed limit per parcel c. Employee Housing The provisions of Section 17021.5 of the California Health and Safety Code state that employee housing for six or fewer employees must be treated as a single-unit dwelling in regards to land used designation, processing procedure, and fees. As the City does not regulate the occupancy of single-unit dwellings and there are no provisions in the City’s code to restrict employee housing for six or fewer employees, the City complies with this requirement. However, as discussed below in Section A(3), the City’s definition of “household” may present a constraint. Therefore, through Housing Element Program 2.1, regulations impacting special needs housing and residential land uses will be reviewed. d. Farmworker Housing While Santa Monica is highly urbanized and does not have any agricultural industries, according to the 2017 United States Department of Agriculture (USDA) Agricultural Census, there were 1,035 farms with 1,793 total producers within Los Angeles County. Additionally, the California Employment Development Department estimated that the 2020 annual average of agricultural employment was between 1,501 and 5,000 within the County. Therefore, within the region there is a need for farmworker housing, whether that be permanent or seasonal. In order to accommodate this need, Santa Monica provides a variety of housing types, such as employee housing and group residential, that are further discussed in this appendix that would be able to accommodate housing needs for these workers. e. Group Residential Group Residential is defined by the Zoning Ordinance as “shared living quarters without a separate kitchen or bathroom facilities wherein two or more rooms are rented to individuals under separate rental agreements or leases, either written or oral, whether or not an owner, agent or rental manager is in residence, offered for rent for permanent or semi-transient residents for periods generally of at least 30 days.” This land use classification includes rooming 8.B.d Packet Pg. 307 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-35 and boarding houses, dormitories, fraternities, convents, monasteries, and other types of organizational housing, and private residential clubs but excludes extended stay hotels intended for long-term occupancy and residential facilities. As shown in Figure E-10, group residential is allowed in the same zone districts as multiple-unit structures but typically requires discretionary approval of a Minor or Conditional Use Permit. Within the land use category of group residential, the subcategories of Congregate Housing and Senior Group Residential have special standards and are treated separately. Congregate Housing is defined as “a residential facility with shared kitchen facilities, deed- restricted or restricted by an agreement approved by the City for occupancy by low- or moderate-income households, designed for occupancy for periods of six months or longer, providing services that may include meals, housekeeping, and personal care assistance as well as common areas for residents of the facility." Similar to the requirement for transitional housing, the Zoning Ordinance establishes maximum density limitations for beds in congregate housing facilities that is three times the maximum number of dwelling units that would otherwise be permitted, as well as requiring a management plan for the facility. Senior Group Residential is defined as “a residential facility that provides residence for a group of senior citizens as defined in Health and Safety Code Section 1569.2(k) with a central kitchen and dining facilities and a separate bedroom or private living quarters.” To ensure that senior group residential does not “adversely impact adjacent parcels or the surrounding neighborhood and are developed in a manner that protects the health, safety, and general welfare of nearby residents, while providing for the housing needs of an important segment of the community,” the land use must adhere to standards related to location, development, and operation. This includes such standards as maximum number of private living quarters, kitchen and laundry facilities, common area facilities, security, minimum age requirements, minimum private living quarter sizes, and outdoor living area requirements. As shown in Figure E-10, unlike the rest of the group residential land use, both subcategories are permitted by right in all multiple-unit residential and mixed-use districts and only need discretionary approvals in the DCP and employment zone districts. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. f. Low Barrier Navigation Centers AB 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multiple-unit uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a “housing first, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing”. Housing Element Program 5.B proposes to amend the Zoning Ordinance to comply with this new land use requirement. 8.B.d Packet Pg. 308 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-36 g. Manufactured Homes and Mobile Home Parks State law requires jurisdictions to allow the placement of manufactured homes (also referred to as factory-built homes and modular homes) meeting Federal construction standards and manufactured home subdivisions in single-unit neighborhoods. Government Code Sections 65852.3 through 65852.5 require that manufactured homes be permitted in single-unit districts subject to the same land use regulations as conventional homes. In accordance with State law, the City’s Zoning Ordinance includes manufactured housing units within its single-unit dwelling land use classification. This allows manufactured homes to be permitted wherever single-unit dwellings can be located which is in all residential, commercial, and DCP zones districts (single-unit dwellings are not a permitted land use within the BAP area). As manufactured homes are considered single-unit dwellings, they must be compatible in design and appearance with other residential structures in the vicinity and be built on a foundation as well as meet other standards regarding roofing materials, siding, and skirting. Santa Monica defines the “Mobile Home Park” land use as “any area or tract of land where 2 or more lots are rented, leased, or held out for rent or lease, to accommodate mobile homes used for human habitation.” There are only two remaining mobile home parks located within Santa Monica: (1) the Village Trailer Park that consists of 10 units and is located in the MUC zone district and (2) the Mountain View Mobile Home Park. Mountain View, with an approved capacity of 105 units, is located in the specially zoned “Residential Mobile Home Park District” which was established to preserve and protect existing mobile home parks as developments that offer alternative types of residential units and opportunities for affordable housing with special development standards and processes specific to the zone. h. Residential Facilities The City of Santa Monica’s Zoning Ordinance classifies a group home as a “Residential Facility”, which is defined as follows: “Facilities that provide permanent living accommodations and 24-hour primarily non-medical care and supervision for persons in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living. Living accommodations are shared living quarters with or without separate kitchen or bathroom facilities for each room or unit. This classification includes facilities that are operated for profit as well as those operated by public or not- for-profit institutions, including group homes for minors, persons with disabilities, people in recovery from alcohol or drug addictions, and hospice facilities.” Within the Residential Facility classification, the use is divided between five subtypes with the following distinctions: • Residential Care, General: A residential facility licensed by the State of California providing care for more than 6 persons. 8.B.d Packet Pg. 309 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-37 • Residential Care, Limited: A residential facility licensed by the State of California providing care for 6 or fewer persons. • Residential Care, Seniors: housing arrangement chosen voluntarily by the resident, the resident’s guardian, conservator, or other responsible person, where residents are 60 years of age or older and where varying levels of care and supervision are provided as agreed to at the time of admission or determined necessary at subsequent times of reappraisal. This classification includes continuing care retirement communities and life care communities licensed for residential care by the State of California. • Hospice, General: A facility that provides residential living quarters for more than 6 terminally ill persons. • Hospice, Limited: A facility that provides residential living quarters for up to 6 terminally ill persons. California State law mandates that State-licensed group homes of six or fewer residents must be regulated in the same manner as single-unit dwellings for zoning purposes. As shown in Figure E-10, Santa Monica is consistent with State law as Residential Care Limited is permitted in the same zone districts and/or to the same locational standards as single-unit dwellings and in some cases even where single-unit dwellings are not permitted such as in the BTV, MUC, CAC, IC, and OC zone districts. As for Residential Care General, the use is permitted by right in most of the City’s mixed-use and commercial zone districts that allow for larger development, but it is only permitted if certain locational standards are met or if the use obtains approval of either a Minor or Conditional Use Permit in the City’s multiple-unit residential zone districts. As Residential Care Facilities are treated as residential uses, they are subject to the same development standards as any permitted residential use of the same housing type in the district in which they are located. However, Residential Care General is required to be located a minimum distance of 300 feet from any other Residential Facility. Hospice Limited and Hospice General generally follow the same approval process as their Residential Care counterparts, whereas Residential Care Senior follows the approval process based on the number of residents the facility holds. While Santa Monica is in compliance with State law for group homes of six or fewer residents, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure compliance with all State laws and to remove any unintended constraints, such as when and how land uses are permitted. This would include reviewing requirements for group homes with seven or more residents. i. Single-Room Occupancy Housing Single-Room Occupancy (SRO) housing is defined in the City’s Zoning Ordinance as “multiple- unit residential buildings containing housing units that may have kitchen and/or bathroom facilities and are guest rooms or efficiency units as defined by the State Health and Safety Code.” Additionally, SROs are only permitted to be “occupied by no more than two persons,” 8.B.d Packet Pg. 310 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-38 must be “offered on a monthly rental basis or longer,” and are subject to specific standards that all SROs must abide by as set forth in SMMC Section 9.31.330. These standards include the following: • Maximum Occupancy. Each SRO unit shall be designed to accommodate a maximum of two persons. • Minimum Size. An SRO unit must have at least 150 square feet of floor area, excluding closet and bathroom. No individual unit may exceed 375 square feet. • Minimum Width. An SRO of one room shall not be less than 12 feet in width. • Entrances. All SRO units must be independently accessible from a single main entry, excluding emergency and other service support exits. • Bathroom. An SRO unit is not required to but may contain partial or full bathroom facilities. A partial bathroom facility shall have at least a toilet and sink; a full facility shall have a toilet, sink and bathtub, shower or bathtub/shower combination. If a full bathroom facility is not provided, common bathroom facilities shall be provided in accordance with the California Building Code for congregate residences with at least one full bathroom per floor. • Closet. Each SRO unit shall have a separate closet. • Common Area. Four square feet per living unit shall be provided, excluding janitorial storage, laundry facilities and common hallways. At least 200 square feet in area of interior common space provided as a ground floor entry area that provides a central focus for tenant social interaction and meetings. • Tenancy. Tenancy of SRO units shall be for 30 or more days. • Facility Management. An SRO structure with ten or more units shall provide full-time on-site management. An SRO structure with fewer than ten units shall provide a management office on-site. SROs are classified by the City’s Zoning Ordinance under the multiple-unit dwelling land use classification and are therefore permitted wherever and however multiple-unit structures are allowed; however, it is important to note that since 2019, SROs are only permitted if they are 100% affordable housing projects, elderly and long-term care, emergency shelters, residential facilities, supportive housing, or transitional housing. This change was made in response to a threat of over-proliferation of market-rate SROs that would have been inconsistent with the City’s longstanding commitment to providing a range of housing types. This is not a constraint given the wide range of alternatives available. j. Supportive/Transitional Housing Consistent with the State Health and Safety Code, the City defines supportive housing as “housing with no limit on length of stay, that is occupied by the target population, and that is linked to on-site or off-site services that assist the supportive housing resident in retaining the 8.B.d Packet Pg. 311 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-39 housing, improving their health status, and maximizing their ability to live and, when possible, work in the community.” The target population for supportive housing is defined as persons, including persons with disabilities, and families who are homeless or who are homeless youth. While transitional housing is similar to supportive housing, transitional housing units are meant to be for a limited length of stay and “are operated under a program requiring recirculation to another program recipient at some future point in time.” Transitional housing may be designated for homeless or recently homeless individuals or families transitioning to permanent housing, and the classification includes domestic violence shelters. Also, unlike supportive housing, transitional housing has maximum density limitations for beds that is three times the maximum number of dwelling units that would otherwise be permitted and requires a management plan for the facility. In compliance with Government Code Section 65583, both land uses are considered residential uses and are subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. Therefore, supportive and transitional housing are both permitted uses without discretionary action within the City wherever and however single or multiple-unit dwellings are permitted and even in the IC and OC zone districts where most housing is not currently permitted as demonstrated in Figure E-10. Additionally, pursuant to recent changes in State law to Government Code Section 65651 (AB 2162), the City must allow 100% affordable housing projects that include at least 25% or 12 units of supportive housing by right where multiple-unit and mixed-use developments are permitted, including nonresidential zones permitting multi-unit uses. Santa Monica is already in compliance with this requirement as all affordable housing projects of any housing type mix are permitted where multi-unit structures are permitted. Additionally, as shown in Figure E-10, Supportive Housing on its own is a permitted use without discretionary action in all multi-unit zones and commercial zones where multi-unit housing is a permitted use. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. 3. Zoning Regulations and Practices for Persons with Disabilities The City of Santa Monica recognizes the importance of addressing the housing needs of persons with disabilities. This section reviews potential governmental constraints to the development and improvement of housing for persons with disabilities. a. Definition of a Family Local governments may unintentionally restrict access to housing for households failing to qualify as a “family” by the definition specified in a zoning code. Specifically, a restrictive definition of “family” that limits the number of and differentiates between related and unrelated 8.B.d Packet Pg. 312 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-40 individuals living together may impermissibly limit the development and siting of group homes for persons with disabilities but not housing for families that are similarly sized or situated. Santa Monica’s Zoning Ordinances does not include a definition of “family”, nor is family used in any of the City’s land use classification titles. Instead, it defines the persons who occupy a housing unit as a “household”. A household is defined as follows: “One or more persons living together in a single dwelling unit, with access to and use of all common living and eating areas and all common areas and facilities for the preparation and storage of food and who maintain a single mortgage, lease, or rental agreement for all members of the household.” This definition of household does not refer to related or unrelated persons who may occupy a housing unit. Therefore, the zoning regulations do not discriminate against unrelated individuals with disabilities who reside together in a congregate or group living arrangement. However, the provision of requiring a “single mortgage, lease, or rental agreement” may inadvertently be a constraint on housing options for persons with disabilities. Therefore, Housing Element Program 2.I will be evaluating all special needs housing types and all provisions related to housing access for persons with disabilities to ensure consistency with State law and to remove any unintended constraints. b. Definition of Disability With the adoption of the updated Zoning Ordinance in 2015, Santa Monica incorporated the following definition of “disability” consistent with the Federal Fair Housing Act: “Physical or mental impairment that substantially limits one or more of a person’s major life activities or a record of having an impairment, but the term does not include current, illegal use of, or an addiction to, a controlled substance. Current users of illegal controlled substances, persons convicted with illegal manufacture or distribution of a controlled substance, sex offenders, and juvenile offenders are not considered disabled under the Fair Housing Act, by virtue of that status.” The addition of this definition provides consistency with Federal law and brings clarity to land use classifications within the Zoning Ordinance. c. Reasonable Accommodation Both the Federal Fair Housing Act and the California Fair Employment and Housing Act direct local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. One of the primary reasons for a reasonable accommodation procedure is to provide a way – other than through a discretionary entitlement – for residents with disabilities to request a 8.B.d Packet Pg. 313 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-41 modification from zoning, building, and land use rules, standards, policies, practices, and procedures. In the 2015 Zoning Ordinance update, Santa Monica adapted reasonable accommodation procedures (SMMC Chapter 9.49) that specify the applicability of eligible applicants and requests, application requirements, reviewing authority and procedures, findings and decisions, appeal process, and the duration limits of the accommodation. The findings for approval include: 1. That the housing or other property which is the subject of the request for reasonable accommodation will be used by an individual or organization entitled to protection; 2. The request for accommodation is necessary to afford an individual with a disability an equal opportunity to use and enjoy a dwelling or common areas of the premises; 3. The request for accommodation would not impose an undue financial or administrative burden on the City; and 4. The request for accommodation would not require a fundamental alteration in the nature of the City’s land use and zoning or building program. Generally, a reasonable accommodation is a self-certified process consisting of a simplified application with limited information requested by the City in order to approve a request. On average, the City receives two applications per year, and both the findings above and the overall process have never presented a constraint. To date, a reasonable accommodation has never been denied. 4. Building Codes and Code Compliance Building codes regulate the construction of dwellings and apply to plumbing, electrical, and mechanical systems. The purpose of building codes and their enforcement is to protect the public from unsafe conditions associated with faulty construction. a. Building Code Implementations The City of Santa Monica enforces State building code standards for all structures subject to the Code, including the construction and rehabilitation of housing, and has adopted the 2019 California Building Standards Code (based on the 2018 International Building Code), the 2019 California Green Building Standards Code, and the 2019 California Residential Code. For historic resources, the City allows determinations to be made based on the State Historical Building Code. The State Building Standards Code establishes accessibility requirements in Chapters 11A (Housing Accessibility) and 11B (Accessibility to Public Buildings, Public Accommodations, Commercial Buildings and Publicly Funded Housing). Consistent with the Federal Fair Housing Act, the Code requires all multiple-unit structures with four or more units built after March 13, 1991 to provide accessible routes throughout the property, and “adaptable” dwelling units to 8.B.d Packet Pg. 314 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-42 allow conversion to a fully accessible unit without significant costs and the need to make significant structural modifications. In multiple-unit structures with an elevator, 100% of the units must meet the accessibility requirements, whereas in buildings without an elevator, all of the ground floor units must be accessible. The Code requires compliance with the following seven basic design and construction requirements for accessible routes and unit adaptability: 1. Accessible building entrance on an accessible route 2. Accessible and usable public and common-use areas 3. Usable doors by a person in a wheelchair 4. Accessible route into and through the dwelling unit 5. Light switches, electrical outlets, thermostats, etc. in accessible locations 6. Reinforced bathroom walls for later installation of grab bars 7. Usable kitchens and bathrooms for persons in a wheelchair These accessibility requirements pertain to new construction only and not renovations or remodels. However, the Building Code applies a more stringent standard for publicly funded housing requiring 20% of public funds utilized on renovation, structural repair, alterations, or additions to existing multiple-unit buildings be allocated towards removal of architectural barriers. Section 504 of the Federal Rehabilitation Act of 1973 adds additional accessibility requirements for projects receiving federal funds such as the HOME Investment Partnership Program (HOME) or Community Development Block Grants (CDBG). In federally assisted new construction or substantially rehabilitated housing with five or more units, 5% of the units, or at least one unit, must be accessible for persons with mobility disabilities. An additional 2% of the dwelling units, or at least one unit, must be accessible for persons with hearing or visual disabilities. These units must be constructed in accordance with the Uniform Federal Accessibility Standards (UFAS) or a standard that is equivalent or stricter. UFAS generally defines an accessible housing unit as a unit located on an accessible route that can be approached, entered, and used by individuals with disabilities. b. Local Amendments In 2019, along with the adoption of the California Building Code, the City adopted various local amendments. Local amendments provide for higher orders of seismic safety, structural safety, fire safety, occupant safety, and environmental conservation. The local amendments are reasonably necessary given the City’s local climactic, geological and topographical conditions, particularly the specific seismic conditions of Santa Monica with known earthquake faults and the special environmental conditions of the City’s beach community. The majority of the amendments, particularly for the Building Code and Residential Code, were discussed, conceived, and authored by the collaborative group of building officials in Los Angeles County. City staff participated in each of the committees of this collaborative group, and staff 8.B.d Packet Pg. 315 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-43 determined that the technical suggestions of the collaborative group were applicable to Santa Monica. In accordance with local amendments to the California Energy Code, new buildings in Santa Monica have two design pathways: all-electric design and mixed-fuel design. As an incentive to design all-electric buildings, a higher level of energy efficiency is required for mixed-fuel buildings. All-electric buildings are not subject to higher levels of energy efficiency and may be built to the State’s standard design requirements. For residential projects specifically: • New single-family, duplex, and multi-family residential buildings up to three stories: o All-Electric Building: shall be designed to code established by the 2019 CEC. o Mixed-Fuel Building: shall be designed to CalGreen Tier 1 established by the 2019 CEC. CalGreen Tier 1 buildings have additional integrated efficiency and on-site renewable energy sufficient to achieve a Total Energy Design Rating of 10 or less. • New multi-family buildings, four stories and greater: o All new buildings shall have a solar photovoltaic system with a minimum rating of 2 watts per square foot of the building’s footprint. o All-Electric Building: shall be designed to code established by the 2019 CEC. o Mixed-Fuel Building: shall be designed to be 5 percent more efficient than the code established by the 2019 CEC. (The change from the current Energy Reach Code, which requires these buildings to be 10 percent more efficient is the result of a cost-effectiveness study.) In accordance with local amendments to the Green Building Standards Code, major additions to one- and two-unit dwellings shall install a solar photovoltaic system with a minimum total wattage of 1.5 times the square footage of the addition. All major additions to multi-family and non-residential buildings are required to install a solar photovoltaic system with a minimum total wattage of 2 times the square footage of the addition’s footprint. Local amendments to the 2019 California Energy Code and 2019 California Green Building Standards Code are reasonably necessary because of local climatic, geological, topographic, and environmental conditions. The amendments are consistent with the City’s Climate Action & Adaptation Plan and establish requirements to increase energy efficiency and the use of renewable energy, including in particular solar energy, which will reduce demands for local energy and resources, reduce regional pollution, and promote a lower contribution to greenhouse gases. Cost effectiveness studies prepared by the California Statewide Investor Owned Utilities Codes and Standards Program in conjunction with consultants and cities (collectively known as the “Reach Code Team”), demonstrate that the local amendments are cost-effective and do not result in buildings consuming more energy than is permitted by the 2019 California Energy Code. 8.B.d Packet Pg. 316 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-44 In addition to local amendments to the Building Code, Stata Monica has specific High-Rise Safety Code requirements for buildings over 55 feet in height. In contrast, State law (Health & Safety Code Section 13210(b)) classify buildings over 75 feet in height as high-rise. The local high-rise amendment was put in place after the 1994 Northridge earthquake when there were multiple building fires and collapses. With limited resources at the time and since the City is surrounded on all sides by the City of Los Angeles, there were inadequate resources coming into the City in a timely manner. Since the City is very compact in many sections, especially in the downtown area, the purpose of this local amendment to the high-rise definition is to provide an extra level of occupant safety and fire protection in the event of a citywide emergency that might overwhelm the Fire Department’s ability to respond. Essentially, buildings over 55 feet high are required to add a higher level of safety to the building to ensure greater reliance on the built- in safety systems. While this can be a cost constraint on housing projects over 55 feet, it is a necessary safety precaution to ensure protection of human life. c. Compliance and Enforcement Santa Monica’s Building and Safety Division ensures compliance with all State building and accessibility requirements as part of the plan check process. During the construction phase, building inspectors conduct site visits to ensure the project adheres to the approved project plans and required accessibility specifications prior to signing off on the final certificate of occupancy (CofO). Code enforcement can be a potential fair housing concern because code compliance actions may create disproportionate impacts on protected groups such as minority populations. In Santa Monica, however, code enforcement is triggered by complaints, and the City seeks voluntary code compliance through administrative processes that allow for retroactive compliance. In some cases, proactive campaigns are also undertaken when a widespread problem or a specific life/health/safety concern is identified. In conjunction with inspecting and noticing property owners regarding a violation, Code Enforcement personnel inform property owners of assistance provided through the City’s various housing rehabilitation programs. 5. On- and Off-Site Improvements Various City departments implement on- and off-site improvement requirements, including standards for street construction, sidewalks, curbs, gutters, on-street parking and bicycle lanes. Residential development may also necessitate constructing water, sewer, and drainage improvements. All improvements are generally required as conditions of approval and are developer financed. Complying with certain infrastructure improvements may be perceived as a constraint on the provision of housing for all income levels. For infill projects, the SMMC Section 7.04.800 requires the construction of standard improvements that may include repair of defective sidewalks, construction of standard driveways, and maneuvering areas. The Code also requires dedication and improvement of 8.B.d Packet Pg. 317 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-45 full-street or alley frontages. The City's respective departments may approve variances from City standards based on hardship considerations on a case-by-case basis per City Code. Although infrastructure requirements represent a cost to developing housing, these improvement standards are not unreasonable nor do they represent a significant constraint. However, the City recognizes there are issues with infrastructure adequacy in certain areas of the City, including infill areas with aging infrastructure. These infrastructure deficiencies are a recognized constraint for infill development. 6. Entitlement and Development Impact Fees Similar to other cities throughout California, Santa Monica collects various impacts fees, charges, and taxes on new residential development. Charges for such things as entitlement applications or development impact fees are set at rates designed to recover the cost of permit processing and to provide public services to residents as well as to mitigate certain development impacts (e.g., parks and open space and affordable housing). The City annually reassesses its fees to ensure they reflect the actual cost of providing services with most user fees adjusted annually based on the change in the Consumer Price Index (CPI). The City has been active in meeting State requirements of Government Code Section 65940.1(a)(1)(A) to increase transparency and predictability of fees. All entitlement application and development impact fees, as well as building permit and plan check estimates, are posted on the City’s Finance Department website. Figure E-14 and E-15 summarize the City’s adopted entitlement application processing fees and potential development impact fees for new housing developments, respectively. The cost of development impact fees is determined by the type of development or uses proposed, the size of the project (square footage or unit count), and the development tier of a project as described above in Section A(1). When a housing development project requires multiple entitlement applications, the City charges 100% of the cost for the highest application fee and 50% of the cost of associated applications filed concurrently or after the initial filing for the project. It should be noted that while some entitlements are listed in Figure E-14, such as Conditional/Minor Use Permits, Variances, and Modifications, these fees are either not required for typical housing projects within Santa Monica or are self-imposed by a developer. Conditional Use Permits (CUPs) are not required for typical multiple-unit residential projects. CUPs are unusual for residential use classifications in the Zoning Code and a CUP for a residential use has not been requested in the past 10 years. Application fees, including CUPs, are based on cost recovery of services provided (i.e. staff time spent processing the permit), which typically requires significant analysis and development of conditions to mitigate potential impacts (e.g. noise, circulation, loading) on surrounding land uses. Additionally, as discussed below in Section 7, Entitlement and Permit Processing, housing projects in Santa Monica are largely processed ministerially and will continue to be with implementation of Housing Element Program 1.A, which has removed the need for a Development Review Permit. Furthermore, all application fees and development impact fees are waived for 100% affordable housing projects. 8.B.d Packet Pg. 318 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-46 Figure E-14 City Planning Residential Development Application Fees, Fiscal Year 2020-2021 Most planning and construction fees and taxes are due at building permit issuance, but some fees and charges such as the in-lieu AHPP fee may be paid at the end of the construction process (e.g., Certificate of Occupancy). In limited cases, off-site improvements may be required to mitigate project impacts (e.g., street, utility, or sewer capacity improvements), to repair public facilities damaged during project construction (e.g., sidewalk and curb reconstruction or alley repaving), and to protect the public health, safety and general welfare of city residents, businesses, and visitors. Entitlement Application Type Total Fee Amount Administrative Approval: Non-Downtown $7,990.46 Administrative Approval: Downtown – Non-residential Projects Up to 10,000 SF $7,990.46 Administrative Approval: Downtown – Housing Projecting up to 75,000 SF $13,947.51 Architectural Review Board: New Construction $4,563.52 Coastal Zone (Approval in Concept) $190.38 Conditional Use Permit $19,727.12 Deed Restrictions $887.68 Development Review Permit $28,539.79 Final Subdivision Map $1,993.13 Major Modification $5,486.47 Minor Modification $2,027.74 Minor Use Permit $8,065.39 Pre-Submittal Review $3,553.16 Tentative Subdivision Map $9,001.05 Variance $15,120.46 Waiver of Zoning Ordinance $5,486.47 Waiver of Parcel Map $3,042.71 8.B.d Packet Pg. 319 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-47 Figure E-15 Development Impact Fees, Fiscal Year 2020-2021 Transportation Impact Fee Parks and Recreation Development Impact Fee Land Use Adopted Fee Fee Basis Land Use Adopted Fee Fee Basis Area 1 Area 2 Area 3 Residential Residential Single Unit $8,901.19 $9,135.43 $9,135.43 per unit Single Unit $8,584.88 per unit Multi-Unit $3,045.14 $3,864.99 $3,045.60 per unit Multi-Unit (Studio/1 BR) $4,652.20 per unit Non-Residential Multi-Unit (2+ BR) $7,493.22 per unit Retail $24.60 $35.25 $35.25 per SF Non-Residential Office $11.36 $12.65 $12.65 per SF Office/Creative Office $2.60 per SF Medical Office $32.91 $34.90 $34.90 per SF Medical Office/Hospital $1.43 per SF Hospital - $17.22 $17.22 per SF Retail/Auto Sales $1.68 per SF Lodging $4.21 $4.21 $4.21 per SF Hotel $3.50 per SF Industrial $1.40 $1.53 $1.53 per SF Industrial $1.46 per SF Auto Sales Display $1.40 $1.53 $1.53 per SF - - - Cultural Arts Contribution Affordable Housing Commercial Linkage Fee Land Uses Onsite In-Lieu Fee Basis Land Uses Adopted Fee Fee Basis New Residential/ Commercial 2% of $200 1% of $200 per SF Office $12.60 per SF Commercial Tenant Improvement 2% of 50 1% of $50 per SF Creative Office $10.78 per SF Childcare Linkage Fee Medical Office $7.75 per SF Land Use Adopted Fee Fee Basis Hospital $6.91 per SF Residential $156.54 per unit Retail $10.96 per SF Office $7.43 per SF Hotel $3.45 per SF Retail $5.31 per SF Industrial $8.47 per SF Hotel $3.73 per SF Institutional $11.50 per SF Santa Monica’s AHPP allows eligible housing projects of three or fewer units to pay an affordable housing fee in-lieu of providing units on-site or off-site. Calculations resulting in a fractional unit of less than 0.75 can also be met through payment of a unit development cost fee. The unit development cost fee reflects the average cost to the City to develop an affordable housing unit and is adjusted annually based on changes in land and construction costs. Figure E- 16 provides the affordable housing in-lieu fee costs. 8.B.d Packet Pg. 320 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-48 Figure E-16 Affordable Housing In-Lieu Fee, Effective November 1, 2020 Affordable Housing In-Lieu Fees Apartment Developments $36.49 per sq. ft. of entire project Condominium Developments $42.62 per sq. ft. of entire project Unit Development Cost $382,795.00 As a means of assessing the total cost that fees contribute to development in Santa Monica, Figure E-17 provides a breakdown of individual and cumulative costs of City permit fees, charges, and taxes applicable to three typical housing development types: (1) a mixed-use development, (2) a three-unit condominium development, and (3) a single-unit dwelling. As Figure E-17 shows, total development fees are approximately $27,155.75 per unit ($23.04 per square foot) for the mixed-use development, $124,588.59 per unit ($64.66 per square foot) for the three-unit condominium development, and $35,870 ($10.63 per square foot) for the single- unit dwelling. Figure E-17 Development Fees Applicable to Prototypical Residential Development Projects Fees Mixed-Use Development 3-Unit Condo Development Single-Unit Dwelling Zone MUBL R2 R1 Stories 3 2 2 Market Rate 25 units 3 units 1 unit Affordable 3 units 0 units N/A Total Units 28 units 3 units 1 unit Residential Floor Area 24,000 SF 5,780 SF 3,375 SF Ground Floor Commercial 9,000 SF Retail N/A N/A Avg. Unit Size 704 SF per Unit 1,926 SF per unit N/A Tenure Type Rental Ownership Ownership # Parking Spaces 49 spaces 6 spaces 2 spaces Entitlement and Development Impact Fees Administrative Approval $7,990.46 Exempt Exempt Subdivision Map Exempt $10,994.63 Exempt Architectural Review Board: New Construction $4,563.52 $4,563.52 Exempt CEQA analysis Exempt Exempt Exempt Aff. Housing In-lieu Exempt $246,343.603 Exempt Aff. Housing Comm. Linkage $4,393.96 Exempt Exempt Parks & Rec. $146,110.38 $14,986.44 Exempt Transportation Impact Fee $115,085.58 $7,729.98 Exempt Cultural Arts $66,000.00 Exempt Exempt Childcare Linkage $52,173.12 $469.62 Exempt Construction Fees Plan Check $34,353 $11,156 $7,773 Building Permits/ Inspections $41,581 $10,152 $6,203 Water Meter1 $8,429 $8,429 $8,429 Fireline Meter2 $84,292 $26,973 $0 Wastewater Capital Facilities $128,492 $13,767 $ 4,589 8.B.d Packet Pg. 321 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-49 Fees Mixed-Use Development 3-Unit Condo Development Single-Unit Dwelling Other Requirements and Taxes School Facilities Fee $66,900 $15,201 $8,876 Condo Tax $0 $3,000 $0 Total Fees and Taxes $760,361.02 $373,765.79 $35,870 Total Fees/Unit $27,155.75 $124,588.59 - Total Fees/ Sq. Ft. $23.04 $64.66 $10.63 1 Assume 1 inch water meter 2 Assumes 4 inch Fireline meter 3 Only required when a developer choses to not provide an on-site affordable unit In 2021, the average cost to develop an apartment unit in Santa Monica is approximately $735,0001, including construction and land costs. Given that cost, the percentage of cumulative development fees the City imposes on an apartment unit is approximately 3.7% of the construction cost. Additionally, using the mixed-use development prototype above, the cost City fees contribute to an 100% affordable housing project is approximately $364,047 (mixed- use development total minus all entitlement and development impact fees) or $13,001.68 per unit. As of November 2020, with the average cost for the City to develop an affordable housing unit at $382,795.00, it can be assumed that applicable City fees amount to approximately 3.4% of the cost to construct an affordable unit. Similarly, it is estimated that one condominium unit in a three-unit development in Santa Monica costs approximately $1.6 million2 to develop in some areas of the City. Given this cost, the percentage of cumulative development fees the City imposes is approximately 7.8% of the development cost of one condominium unit. However, it should be noted that the main reason City fees are high for the above prototype is because typically developers of three-unit condominium developments elect to pay an affordable housing in-lieu fee. This fee could be avoided if a developer provided an affordable unit on-site, which would lower the total fee amount to $127,422.79 or $42,474.26 per unit, which is 2.6% of the total development cost for one condominium. Therefore, this fee in a self-imposed constraint and the City provides an alternative to not pay it. As for single-unit dwellings, the development cost range is too wide and varied to approximate a realistic cost. However, as detailed in Section E of Appendix B, the average price in 2019 for a single-unit dwelling within Santa Monica was $3,966,251. Given this price, the percentage of cumulative development fees the City imposes is approximately 0.9% of the average single- unit dwelling sales price. Given the percentages that City fees represent of average development and sales prices, combined with the fact that the volume of new housing construction in the last housing cycle exceeds the City’s regional housing need, it can reasonably be concluded that the City’s permit fees and other development charges and taxes do not impose an undue constraint on the 1 From investigation of total development cost for market-rate housing by HR&A in 2021 2 From investigation of total development cost for 3-unit condominium projects by HR&A in 2021 8.B.d Packet Pg. 322 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-50 production of new housing. However, in addition to development standards, Housing Element Programs 1.F and 1.J propose to review all development impact fees applied to housing projects. 7. Entitlement and Permit Processing Housing development in Santa Monica is subject to varying ministerial and discretionary processes depending on such parameters as size, development tier, and land use. Below is a description of typical processes, thresholds, requirements, and timeframes housing projects may encounter. a. Processes and Thresholds New housing developments within Santa Monica are reviewed through one of three processes based on size, use, and location thresholds – Building Permit review, Administrative Approvals, or Development Review Permits. In August 2020, an Interim Zoning Ordinance (IZO) was adopted that temporarily revised the processing thresholds for most housing projects. The intent behind the IZO was to streamline and incentivize housing projects, especially those that are subject to the protections of the Housing Accountability Act (HAA), by making projects that were once discretionary now ministerial. This has had the effect of shortening project approval time as well as allowing for housing projects to be exempt from the environmental review process mandated by the California Environmental Quality Act (CEQA). Housing Element Program 1.A proposes to make these interim process thresholds permanent and to expand the streamlining applicability to housing projects that are granted deviation from certain zoning ordinance objective standards through the minor modification process. Figure E-18 and E-19 summarize the IZO thresholds and typical processes for housing projects within the City, respectively. With these IZO thresholds, the vast majority of housing projects fall into a ministerial (by-right) process which alleviates the processing time and discretionary review barriers that provide constraints for housing production in Santa Monica. Figure E-18 Entitlement Application Thresholds Review Process Entitlement Development Thresholds Ministerial Building Permit Review Only • Projects in residential zone districts • Single-Unit Dwellings Administrative Approval • Projects more than 1,000 sq. ft. in nonresidential zone districts • All 100% affordable housing projects • Any project that meets the definition of “housing development project” under the HAA, up to Tier 2 maximum limits and meets all objective standards* Discretionary Development Review Permit Projects that exceed: • Tier 2 maximum limits in the DCP and BAP • Tier 1 maximum limits for projects that do not meet the definition of “housing development project” under the HAA or do not meet all 8.B.d Packet Pg. 323 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-51 objective standards* • 10,000 sq. ft of floor area located in Residential Zone Districts • 7,500 sq. ft. of floor area in the NC and OF Zone Districts • 15,000 sq. ft. of floor area located in Nonresidential Zone Districts (Not including NC and OF) • 30,000 sq. ft. of floor area in projects containing no more than 15% commercial floor area located in Nonresidential Zone Districts (Not including NC and OF) • 7,500 sq. ft. feet of floor area located in the Pico Neighborhood Area * The Housing Accountability Act defines a “housing development project” as a project that is either (1) residential units only, (2) a mixed-use development consisting of residential and nonresidential uses with at least two-thirds of the square footage designated for residential use, or (3) transitional or supportive housing. Figure E-19 Housing Development Project Processes Step in Entitlement Process Building Permit Review Only Administrative Approval Development Review Permit Application Submittal X X X ARB Preliminary Review X (DCP only) X Staff Administrative Review and Approval X Planning Commission Review and Approval X ARB Formal Review and Approval X X X Plan Check / Building Permit Approval X X X b. Ministerial Approvals Housing projects that require either an Administrative Approval or only a building permit are processed ministerially for conformance with objective development standards with no discretion exercised by the Community Development Director, Planning Commission, or City Council, although certain projects are required to receive design review approval by the Architectural Review Board (ARB) [see Section 7(d) below]. Below is a description of these processes. i. Administrative Approvals The Administrative Approval (AA) entitlement is intended to allow for the approval of projects which conform to the standards established for the applicable zone district in which the project is located and do not require discretionary review or approval by the Director, Planning Commission, or City Council. AAs provide for an administrative review and assessment of the proposed development project in light of explicit standards which have been designed to ensure that the completed project will be in harmony with existing or potential development in the surrounding area consistent with the goals, objectives, and policies of the LUCE. Generally, the AA process consists of the following steps: 1. Application submittal 2. ARB preliminary review for Downtown projects only 8.B.d Packet Pg. 324 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-52 3. Staff review and approval 4. ARB review and approval 5. Plan Check/Building Permit approval For an AA to be issued, only approval from the City Planning, Mobility, and Resource Recovery and Recycling Divisions are required, and the following findings must be made in the affirmative: 1. The proposed development conforms precisely to the development standards for the area and the Santa Monica Municipal Code and General Plan. 2. The proposed development does not require discretionary review or approval as outlined in the Municipal Code. The typical processing time for an AA is approximately three months, not including building permit or ARB review and approval. This timeframe coupled with the lack of discretionary review does not present a constraint on housing development projects. The lack of discretionary review also means that AA projects cannot be appealed. ii. Building Permit Only Projects Projects that only require building permit approval consist of single-unit and multiple-unit dwellings in residential districts. However, ARB review is required for all multiple-unit structures and in limited cases, for single-unit dwellings. Building permit review time varies based on project type, but due to the lack of discretionary approval these projects are not constrained by the building permit process. Building permit projects also cannot be appealed. c. Discretionary Approval Housing developments that fall within the discretionary category for processing are required to obtain approval of a Development Review Permit (DRP). Below is a description of the DRP process and requirements. i. Development Review Permit A DRP is intended to allow for the construction of certain projects provided that the building design, siting, and use are compatible with the site and neighborhood, and the project does not result in an adverse impact on the surrounding area. DRPs are reviewed and approved by the Planning Commission, and as part of the review, consideration is given to the location, size, massing, and placement of structures on a site as well as to the location of proposed uses within a project. A DRP review also consists of an evaluation of a project’s compliance with the development standards of the Zoning Ordinance, and approval of a DRP takes into account the potential impacts of a project, as evaluated under the aforementioned aspects of review, and weighs it against the public need for benefits derived from the project. 8.B.d Packet Pg. 325 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-53 Generally, the current DRP process consists of the following steps, subject to compliance with SB 330 limitations on number of hearings: 1. Application submittal 2. ARB preliminary review 3. Planning Commission review and approval 4. ARB review and approval 5. Plan check/Building permit approval A DRP will only be granted if the Planning Commission determines that the following findings of fact can be made in support of the project as submitted or modified. The inability to make one of the following required findings is grounds for denial of an application. 1. The physical location, size, massing, setbacks, pedestrian orientation, and placement of proposed structures on the site and the location of proposed uses within the project are consistent with applicable standards and are both compatible and relate harmoniously to surrounding sites and neighborhoods; 2. The rights-of-way can accommodate autos, bicycles, pedestrians, and multi-modal transportation methods, including adequate parking and access; 3. The health and safety services (police, fire etc.) and public infrastructure (e.g., utilities) are sufficient to accommodate the new development; 4. The project is generally consistent with the Municipal Code, General Plan, and any applicable Specific Plan; 5. Based on environmental review, the proposed project has no potentially significant environmental impacts or any potentially significant environmental impacts have been reduced to less than significant levels because of mitigation measures incorporated in the project or a Statement of Overriding Considerations has been adopted; 6. The project promotes the general welfare of the community; 7. The project has no unacceptable adverse effects on public health or safety; and 8. The project provides Community Benefits consistent with SMMC Chapter 9.23. In granting a DRP, the Planning Commission (or the City Council if appealed) must make findings that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or in such modifications thereof, as may be deemed necessary to protect the public health, safety, and general welfare and secure the objectives of the LUCE and the Zoning Ordinance. They may also impose any other conditions as deemed necessary to achieve these purposes and to support the findings for approval. The typical time to process a DRP takes between six to nine months not including building permit or ARB review and approval. Given the discretionary process of DRPs, the lack of predictably 8.B.d Packet Pg. 326 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-54 and timing can be a constraint on housing production. Additionally, DRP approvals can also be appealed which results in a project having an additional public hearing before a higher decision- making body (City Council) adding more time and uncertainty to the overall process. However, with the IZO thresholds in place and the intent to make them permanent through Housing Element Program 1.A, DRPs for housing projects are only required in very limited circumstances when a projects is greater than 75,000 square feet in the Downtown Community Plan area. Additionally, it should be noted that if a project is compliant with the Housing Accountability Act as described further below, the City is unable to deny a housing project. The DRP process also triggers environmental review requirements under CEQA. In the past, many housing projects were subject to a rigorous environmental review process (such as preparation of an Environmental Impact Report) that could take up to 2 years or more. However, with passage of new CEQA legislation in recent years, most housing projects in the City are determined to be CEQA exempt. d. Architectural Review Board The Architectural Review Board’s (ARB) role in the development of housing is to preserve existing areas of natural beauty and cultural importance, and to assure that buildings, structures, signs, or other developments are in good taste, good design, harmonious with surrounding developments and in general contribute to the preservation of Santa Monica’s reputation as a place of beauty, spaciousness, and quality. The ARB’s purview relative to housing production is over all new multiple-unit and mixed-use developments within the City and only single-unit dwellings if they are located on sloped parcels. Currently, for housing projects in residential zone districts that only require a building permit or for housing developments that only require an AA, the ARB’s review and approval happens either before the building permit process or after the AA is approved. When it comes to housing development projects that require DRPs, in addition to the formal ARB review and approval after the entitlement is approved, a preliminary review takes place prior to the discretionary public hearing in order to provide initial design feedback that can be considered by the Planning Commission. This preliminary review also serves to provide the project applicant feedback on their design as the project advances through the entitlement process. In order for the ARB to approve a project, the following findings must be made: 1. The plan for the proposed building or structure is expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity, and individuality. 2. The proposed building or structure is not of inferior quality such as to cause the nature of the local neighborhood or environment to materially depreciate in appearance and value. 3. The proposed design of the building or structure is compatible with developments on land in the general area. 8.B.d Packet Pg. 327 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-55 4. The proposed development conforms to the effective guidelines and standards adopted pursuant to Chapter 9.55 – Architectural Review Board, and all other applicable ordinances insofar as the location and appearance of the buildings and structures are involved. Projects that are subject to ARB review are typically approved on the first or second round of review which can take approximately six weeks to three months. The City does not prohibit applicants from submitting an application for a building permit prior to obtaining ARB approval, but there is risk that the ARB process may result in changes to the building permit application. While good design is a priority to the City, the ARB process can add a constraint on housing projects as it adds either a discretionary process to otherwise ministerial projects or another level or review to projects that are already going through one discretionary process. ARB approvals can also be appealed which results in a project having to go to an additional public hearing at a higher decision-making body (Planning Commission) adding more time and uncertainty to the overall process. Additionally, while the design review process focuses only on project design and cannot be used to reduce density or deny a housing project, the approval findings can be perceived as not objective. To help remove barriers to some housing projects, the City has made recent revisions to staff- level ARB review and approval thresholds. Projects such as exterior remodels and the addition of new housing units in the rear of the parcel can now be reviewed and approved by staff. However, Housing Element Program 1.B stipulates adoption of additional streamlining efforts to expedite ARB review for housing projects. This includes expansions to the staff-level approvals, shifting the design review process to occur before or be concurrent with entitlement review, placing time and hearing limits on projects, review and establish mechanisms to promote approval certainty, and developing objective design standards. Together, these efforts will help remove constraints on housing projects by reducing processing time and will bring increased certainty for housing providers. e. Use Permits and Other Processes Additional processes are described below that some residential land use types may need to adhere to. i. Conditional and Minor Use Permits As shown in Figure E-10, the only kinds of residential use classifications that very few residential land uses require approval of a Conditional Use Permit (CUP) are elderly and long-term care facilities and emergency shelters. Residential use classifications that require approval of aor Minor User Permit (MUP) in some zones are group residential, residential care general, residential care senior, and hospice general. These uses are not typical multiple-unit residential uses in that they typically consist of shared living quarters and provide care for persons in need 8.B.d Packet Pg. 328 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-56 of personal services, supervision, protection, or assistance for sustaining the activities of daily living. These use permits and the processes they require are to help ensure that the uses being proposed are consistent with the purposes of the zone district in which they are located and that special consideration is given to the design, location, and operation of the use in a manner that will not interfere with the use and enjoyment of surrounding properties. Both use permits are required to be reviewed by a decision-making body (Planning Commission for a CUP and the Community Development Director for a MUP) and can only be granted if the following findings can be made in the affirmative: 1. The proposed use is conditionally allowed within the applicable Zoning District and complies with all other applicable provisions of the Zoning Ordinance and all other titles of the Municipal Code. 2. The proposed use is consistent with the General Plan and any applicable specific plan. 3. The subject parcel is physically suitable for the type of land use being proposed. 4. The proposed use is compatible with any of the land uses presently on the subject parcel if the land uses are to remain. 5. The proposed use is compatible with existing and permissible land uses within the District and the general area in which the proposed use is to be located which may include but not be limited to size, intensity, hours of operation, number of employees, or the nature of the operation. 6. The physical location or placement of the use on the site is compatible with and relates harmoniously to the surrounding neighborhood. 7. Based on environmental review, the proposed project has no potentially significant environmental impacts or any potentially significant environmental impacts have been reduced to less than significant levels because of mitigation measures incorporated in the project or a Statement of Overriding Considerations has been adopted. 8. The proposed use and related project features would not be detrimental to the public interest, health, safety, convenience, or general welfare. In granting a CUP or MUP, the decision-making body shall require that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or in such modifications thereof, as may be deemed necessary to protect the public health, safety, and general welfare and secure the objectives of the General Plan and the Zoning Ordinance. The decision-making body may also impose any other conditions as may be deemed necessary to achieve these purposes and to support the findings of approval. Typically, a CUP or MUP is processed concurrently with other associated entitlements that are being proposed but on their own can take approximately three months to process. However, use permit approvals can be appealed which results in a project having to go to an additional 8.B.d Packet Pg. 329 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-57 public hearing at a higher decision-making body (City Council for CUP appeals and Planning Commission for MUP appeals) adding more time and uncertainty to the overall process. These timeframes can add a constraint on certain types of housing that require a use permit, but as shown in Figure E-10, the vast majority of residential land uses are permitted by right and therefore, would not be required to go through any of these processes. However, through Housing Element Program 2.I, the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. ii. Subdivision Maps For some housing projects, such as condominiums or mixed-use developments that have commercial and residential components, developers may choose to subdivide the airspace rights of individual units or uses. For example, this typically happens when a housing developer wants to develop for-sale housing units. Additionally, a developer may also choose to process a subdivision map in order to vest current development standards at time of application. The process is conducted in two steps: a Tentative Map that is approved by the Planning Commission and a Final Map that is approved by City Council. The Tentative Map may be denied by the Planning Commission on any of the grounds provided by City ordinances or the California Subdivision Map Act. The Planning Commission may deny approval of the Tentative Map if it makes any of the following findings: 1. The proposed map is not consistent with applicable general and specific plans as specified in Government Code Section 65451. 2. The design or improvement of the proposed subdivision is not consistent with applicable general and specific plans. 3. The site is not physically suitable for the type of development. 4. The site is not physically suitable for the proposed density of development. 5. The design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat. 6. The design of the subdivision or the type of improvement is likely to cause serious public health problems. 7. The design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements for access or for use will be provided, and that these will be substantially equivalent to ones previous acquired by the public. This subsection shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or 8.B.d Packet Pg. 330 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-58 use of property within the proposed subdivision. 8. The proposed subdivision is inconsistent with any ordinance or law of the City of Santa Monica. The subdivision process can add a time constraint on a housing project, but a subdivision map is only a requirement if the developer is selecting to develop for-sale units, wants to divide the uses within a building for financing reasons, or wants to vest development standards.. While the processing time for a subdivision map is approximately 50 days, the approval can also be appealed which results in a project having to go to an additional public hearing at a higher decision-making body (City Council). This possibility adds more time and uncertainty to the overall process. However, the requirements of the Subdivision Map Act cannot be waived or amended by local ordinance when a subdivision of airspace or land is a part of the proposed project. f. State Law Existing and new State laws have an impact on housing developments and how they are processed. Below is a description of three pertinent laws. i. Senate Bill 330 Senate Bill (SB) 330, “The Housing Crisis Act of 2019”, established a statewide housing emergency to be in effect until January 1, 2025 (“housing emergency period”). During the housing emergency period, the City of Santa Monica, as an urban area, is generally prohibited from enacting any development policy, standard, or condition that would have the effect of the following: 1. Changing the land use designation or zoning to a less intensive use or reducing the intensity of land use within an existing zoning district below what was allowed on January 1, 2018; 2. Imposing or enforcing a moratorium on housing development; 3. Imposing or enforcing new non-objective design standards established on or after January 1, 2020; or 4. Establishing or implementing certain limits on the number of permits issued for housing development projects or the population of Santa Monica. SB 330 also limits the demolition of existing housing units in conjunction with a housing development project, as that term is defined for purposes of SB 330, unless replacement units are provided and only allows the demolition of affordable, rent-controlled, or other protected units if certain tenant protections are met. 8.B.d Packet Pg. 331 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-59 Additionally, new specific requirements and limitations on development application procedures have been established by SB 330. Housing developers may now submit a “preliminary application” for a housing development project that requires a specified subset of information prior to providing a formal application. Submittal of the preliminary application secures the applicable development standards and fees adopted at that time. The project is considered vested unless the project changes substantially or no formal entitlement application is filed within 180 days. SB 330 also limits the processing time of housing development projects to 60 or 90 days depending on environmental review requirements and limits the number of public hearings to no more than five including Planning Commission, Architectural Review Board, and City Council. To facilitate this process, Santa Monica has developed a preliminary application form consistent with SB 330. ii. Senate Bill 35 Senate Bill (SB) 35, passed in 2017, requires jurisdictions that have not approved enough housing projects to meet their Regional Housing Needs Allocation (RHNA) to provide a streamlined, ministerial entitlement process for housing developments that incorporate affordable housing. Pursuant to SB 35, if a jurisdiction has not approved enough market rate or affordable housing units to meet its RHNA, review and approval of proposed projects with at least 10% affordability or 50% affordability must be based on objective standards and cannot be based on subjective design guidelines, respectively. However, to be eligible, projects must also meet a long list of other criteria including prevailing wage requirements for projects over 11 units. In order for applicants to take advantage of SB 35, per Government Code Section 65913.4 (10)(b)(1)(a)(et seq.), they need to submit a Notice of Intent, and jurisdictions need to give Native American tribes an opportunity for consultation. The City is currently not subject to SB 35 under the 5th Cycle Housing Element reporting period (2013-2021) because the City meet its RHNA targets. Nevertheless, the City will be undertaking the development of objective design standards and written procedures for implementation of SB 35’s streamlined review should the City become subject to SB 35 in the coming 6th Cycle Housing Element reporting period (2021-2029) as part of Housing Element Programs 1.A and 1.B. It should also be noted that the City has enacted an interim ministerial approval process for nearly all housing projects that meet objective standards of the Zoning Ordinance, and Housing Element Program 1.A proposes to make those interim process thresholds permanent. iii. Housing Accountability Act The Housing Accountability Act (Government Code Section 65589.5) ( HAA) is a State law that restricts the City's ability to deny, reduce the density of, or make infeasible any housing development project that complies with objective general plan, zoning, and subdivision standards and criteria (collectively, "Objective Standards") in effect at the time that the housing development's application is determined to be complete. The HAA has been in effect since 1982 and has undergone several amendments to further reinforce the state legislature's intent to 8.B.d Packet Pg. 332 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-60 increase the supply of residential housing stock. The most recent amendments went into effect on September 25, 2020. In essence, the HAA precludes the City from denying or imposing any conditions upon any housing project (including residential units only or mixed-use projects with at least two-thirds of square footage designated for residential use) unless specific findings are made. However, the HAA does not preclude the City from exercising its discretion and imposing design conditions as part of its review as long as any such conditions does not have the effect of reducing the number of residential units and/or the residential density of this mixed-use project. The City reviews all housing development projects that meet objective LUCE, zoning, and subdivision standards and criteria in accordance with the limitations set forth in the HAA. As discussed above, the City expanded its ministerial processing thresholds for housing development projects to now include all Tier 2 projects that meet the definition of “housing development project” under the HAA and all Objective Standards. This expansion was to not only acknowledge that the HAA limits the ability to deny or reduce the density of such housing development projects but, also was a way to further streamline the vast majority of new housing projects in the City. In addition, Housing Element Program 1 A will expand this streamlining to projects that seek and are granted deviation from certain objective standards through the ministerial Minor Modification process. 8. Local Measures, Propositions, Rent Control Law, and Ordinances The following section focuses on key policies in Santa Monica which serve to promote the production and preservation of housing for all residents, many of which have been in place during prior Housing Elements cycle. As evidenced by the robust housing development the City has seen in recent years, these policies are not impeding housing production and should not prevent the City from achieving its quantitative housing goals. a. Santa Monica City Charter Section 615 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. The 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. 8.B.d Packet Pg. 333 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-61 Housing Element Programs 1.F and 1.J propose 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. b. Rent Control Santa Monica Rent Control was adopted by the voters in April 1979 in response to a shortage of housing units, low vacancy rates, and rapidly rising rents. The law was intended to alleviate the housing shortage and to ensure that owners received no more than a fair return. Regulations were adopted by the Rent Control Board to implement and enforce the Rent Control Law. Changes to the City Charter can only be made by the voters, whereas changes to the implementing Regulations are made by the Board. The City’s Rent Control Law does the following: • Controls the amount that may be charged for a rental unit during a tenancy and provides remedies for the collection of excess rent. • Determines the amenities and services that are included as part of the rent and provides remedies for removal or reduction of those amenities. • Limits the reasons why tenants may be evicted. • Limits removal of controlled units from rental market. The following units are covered under the Law: • Most residential rental buildings in the City constructed prior to April 10, 1979 and certain units constructed after that date (e.g., those on properties on which a rent- controlled building stood within the last five years) are covered by Rent Control. • In addition to apartment buildings, Rent Control also applies to some single-unit dwellings and condominiums used as rentals. • Duplexes and triplexes where one unit is occupied by the owner are eligible for an exemption from rent control. The services of the Rent Control Agency are financed by a per unit annual registration fee charged to owners of controlled rental units. Owners who are in compliance with the law may pass through half of the fee to the tenant(s) on a monthly basis. The Rent Control Board provides waivers of Rent Control registration fees to units occupied by their owners, subsidized by HUD (Section 8 or HOME program), or occupied by low-income tenants who are at least 62 years old or who are disabled. There are also fee waivers for condominiums and single-unit dwellings on 8.B.d Packet Pg. 334 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-62 which rent restrictions have been lifted pursuant to the Costa-Hawkins’ Rental Housing Act and in mobile home parks for units where tenants have signed long-term leases. i. Vacancy Decontrol The Costa-Hawkins Rental Housing Act, passed by the State Legislature in 1995, has had a significant impact on local rent affordability. Under this State law, a unit’s rent is decontrolled at the end of a tenancy. The owner can set a new rent for the next tenancy which is then recontrolled using the new rent as the base leading some to characterize Costa- Hawkins as a system of “vacancy decontrol-recontrol.” The following highlights some of the major effects Costa Hawkins’s has had on the Santa Monica rental market during its 22 years of implementation (1999- 2020)3: • Since the passage of Costa-Hawkins, nearly 20,000 controlled units have received vacancy increases, representing 73% of the City’s total rent-controlled housing stock. Market-rate rents are on average roughly double that of long- term controlled rents. • Median rents for decontrolled-recontrolled apartments have gone up by well over 200% between 1999-2020 • 84% of Santa Monica’s rental units that have now been re-rented at least once were affordable to low income households (<80% AMI) prior to Costa Hawkins with 73% of the rental stock decontrolled-recontrolled as of 2020 due to tenant turnover. Even moderate-income households (<120% AMI) are challenged to afford the majority of rental housing in the community. The impact of this increase in rents on lower income households is significant. For example, many young people earning entry-level pay will be unable to afford to live in Santa Monica, and those living on fixed incomes—principally seniors and the disabled—will likely be unable to continue to live here if they lose their long-term rent-controlled housing. As passed by Santa Monica voters, the Rent Control Law provides Just Cause Eviction protections to help protect existing tenants in rent-controlled housing from unfair evictions. The voters expanded these protections in 2010 through Measure RR to most residential tenants regardless of rent control status. The City Council has also enacted Tenant Anti-Harassment laws to protect all renters in the city. ii. Just Cause Eviction Santa Monica’s Rent Control Law establishes “Just Cause Eviction” provisions and defines procedures that a property owner must follow to lawfully evict a tenant. These local provisions 3 Santa Monica Rent Control Board, 2020 Annual Report, March 2021 8.B.d Packet Pg. 335 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-63 are in addition to State regulations on landlord and tenant rights and responsibilities. The Rent Control Law identifies the following permissible grounds for eviction: • Fault-Based Evictions o Nonpayment of rent o Materially and substantially breaching the lease o Causing or permitting a substantial nuisance or damage to the unit o Being convicted of using the unit for an illegal purpose o Refusing to renew or extend the lease on the same terms as the original lease when lawfully asked to do so by the landlord o Refusing to grant the landlord reasonable access to the unit to make necessary or agreed-upon repairs or improvements, or show the property for sale o Subletting in violation of the lease • No Fault Evictions o The landlord seeks possession of a unit in good faith for use and occupancy by herself or himself, or her or his children, parents, grandparents, brother, sister, father-in-law, mother-in-law, son-in-law, or daughter-in-law o The landlord seeks to recover possession to demolish or otherwise remove the controlled rental unit from rental residential housing use after having obtained all proper permits from the City of Santa Monica. o The landlord seeks to recover possession of the unit to remove the rental unit permanently from rental housing use pursuant to the Ellis Act enacted by the State Legislature. In November 2010, Santa Monica voters passed Measure RR amending the City Charter to further strengthen tenant protections against eviction in the following three ways: • Extending “just cause” eviction protections to all tenants in multi-unit apartment buildings that are permanently exempt from rent control, as well as two- and three- unit owner-occupied properties, and newly constructed rental units. • Requiring owners to give tenants a reasonable opportunity to correct an alleged lease violation, nuisance activity, or failure to provide lawful access before serving a three- day notice to perform or quit. • Forbidding owners to evict for owner occupancy any tenant who has occupied a rental unit for at least five years and is 62 or older, disabled, or terminally ill, unless the owner (or qualified relative intending to occupy the unit) meets at least one of these same criteria. 8.B.d Packet Pg. 336 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-64 The strengthened eviction protections under Measure RR have had a noticeable impact. From 2005 to 2010, the Rent Control Board received on average copies of 109 eviction notices per year for reasons other than non-payment of rent. By comparison, the Board received on average 85 notices annually after Measure RR took effect (excluding 2020 when eviction moratoria related to the COVID-19 pandemic reduced the number to just 31). iii. Tenant Harassment Protections In 2002, the City Council adopted a Tenant Harassment Ordinance to protect tenants in rent- controlled units from landlords’ conduct in derogation of tenants’ rights. The ordinance prohibits the following acts by landlords if they are done with the intent to harass: • Taking away services provided for in the lease (such as parking or laundry) • Failure to perform repairs and maintenance required by law • Entering the apartment without proper notice • Using lies or intimidation intended to make a tenant move out • Giving a “3-day notice” or other eviction notice that is based on false charges where the landlord does not intend to take the case to court • Threatening the tenant, by word or gesture, with physical harm • Intentionally disturbing a tenant’s peace and quiet • Interfering with a tenant’s right to privacy • Refusing to acknowledge receipt of a tenant’s rent payment without justification • Violating any law which prohibits discrimination based on race, gender, sexual preference, sexual orientation, ethnic background, nationality, religion, age, parenthood, marriage, pregnancy, disability, Acquired immunodeficiency syndrome (AIDS), or occupancy by a minor child In December 2011, the City Council extended these tenant harassment protections to all tenants covered by just cause eviction rules. Tenant harassment complaints are referred to the City Attorney’s Office for investigation and enforcement of the law. As a neutral enforcer of the law, the City cannot represent tenants directly and refers tenants requiring representation to Legal Aid (located near City Hall) and the Santa Monica Bar Association. iv. Relocation Assistance Under the City’s Municipal Code, a property owner is required to pay relocation assistance to a tenant when terminating a tenancy for any of the following reasons: • The owner seeks to withdraw all rental units from the rental market as provided for under the Ellis Act • The owner seeks to recover possession of a rental housing unit for use by the owner or 8.B.d Packet Pg. 337 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-65 family member • The landlord seeks to demolish or otherwise withdraw a rental housing unit from residential rental housing use, including units that were illegally converted to residential use, after having obtained the proper permits from the City Santa Monica had not increased its permanent relocation benefit amounts (other than cost of living increases) since 2007, during which time rent levels in the city had increased and vacancies had decreased. In December 2011, the City Council adopted increased relocation fees. In addition, the City established augmented relocation amounts to households with seniors, disabled persons, and children because these households are particularly vulnerable. It increased the assistance amounts again effective February 2019 to mitigate the financial impacts of involuntary displacement and to keep pace with living costs. Figure E-20 presents the City’s adopted relocation amounts effective July 1, 2020. The fees are adjusted each July to reflect increases in the cost of living. Figure E-20 Residential Relocation Fee Amounts, Fiscal Year 2020/2021 v. Rent Control Dispute Resolution The Rent Control Law provides processes for filing of petitions, complaints, and applications to resolve disputes between landlords and tenants. • Excess rent complaints are reviewed by staff, and the owner is given a chance to resolve the complaint. Complaints which are unable to be resolved administratively are referred to the Hearings Division for mediation and/or hearing. • Owner-occupied exemption applications are reviewed by staff and granted or denied by the Rent Control Board. If staff review indicates an exemption may be recommended to be denied, or if a tenant challenges the granting of an exemption, it is referred to the Hearings Division for an evidentiary hearing and for preparation of a recommendation to the Board. • The Hearings Division provides mediation services as part of the decrease and excess rent processes, as well as for issues involving lack of maintenance, loss of housing services, and unreasonable construction impacts. Mediators have been very Unit Size Fee Amount Augmented Fee Amount* Single or Studio $16,500 $17,200 One bedroom $22,700 $24,250 Two or more bedrooms $31,550 $33,650 Source: City of Santa Monica, Ordinance #2383 *Eligible households include those with a senior citizen, occupant with a disability, or an occupant with whom a minor child resides. 8.B.d Packet Pg. 338 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-66 successful in settling a large percentage of these cases. The City has found that mediation may be particularly useful when a building is purchased. For example, new owners may want to fix up the building and make improvements in the common areas yet may be unaware of how the Rent Control Law affects those changes such as proper notice being required before entering the tenants’ units or the tenants being entitled to certain amenities. The tenants may be concerned about changes to their home and disruptions to the longstanding practices or “culture” of a building and may not know how to communicate their concerns effectively. Mediation is often appropriate and helpful in this type of situation. 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 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 future for up to 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 the production of affordable housing. Housing Element 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. 8.B.d Packet Pg. 339 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-67 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 are 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. d. Home Sharing (Short-Term Rental) Ordinance In response to the increase in vacation rentals due to the popularity of Airbnb and other online platforms, the City desired to reaffirm its long-standing prohibition of vacation rentals in Santa Monica while allowing individuals to be able to rent a spare room in their homes for periods of thirty days or less (“home-sharing”). Therefore, on May 12th, 2015, the City adopted the "Home- Sharing Ordinance" adding Chapter 6.20 to the SMMC to expressly adopt and confirm its longstanding prohibition against short-term vacation rentals and establish regulations for home-sharing. This law became effective on June 12th, 2015, and was subsequently amended by ordinances adopted on January 24, 2017, June 27, 2017, and September 24, 2019. The Home- Sharing Ordinance allows eligible residents (owners and long-term residents) to apply for a home-sharing permit and business license so that they can home-share their primary residence. In addition, the September 24, 2019 amendments to the ordinance contain listing and advertising requirements, restrictions on the number of group bookings, occupancy and visitor vehicle limitations, and other prohibitions. These amendments took effect on October 24, 2019 and apply to all home-shares including those operating under business licenses obtained prior to the effective date of the ordinance. The Home-Sharing Ordinance provides for regulations of two types of Short-Term Rentals: • “Home-Sharing” – The rental of 30 consecutive days or less of one or more bedrooms in the home that is the primary residence of the host while the host lives on-site in the home throughout the visitor’s stay. The Home-Sharing Ordinance authorizes home- sharing. • "Vacation Rental” – A vacation rental is the rental of 30 consecutive days or less of a home, in whole or in part, for exclusive transient use. The visitor enjoys the exclusive private use of the unit. The Home-Sharing Ordinance restates and clarifies the City’s 8.B.d Packet Pg. 340 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-68 longstanding prohibition against Vacation Rentals. The City’s Home-Sharing Ordinance does not present a constraint on the production or preservation of housing. e. Residential Leasing Requirements Ordinance To protect the City’s rental housing stock for use as long-term permanent housing, the City enacted a Residential Leasing Requirement Ordinance on September 8, 2020. The ordinance established the following new leasing requirements which apply to all rental housing units in Santa Monica: • Units must be rented only to natural persons • Units must be rented only to tenants intending the unit to be their primary residence • Units must be rented for an initial term of not less than 1 year • Units must be rented unfurnished Subsequent to adoption, on October 13, 2020 the requirements were amended to allow the following limited exemptions to the residential leasing regulations: • Leases of owner-occupied rental housing units for more than 30 days and less than a year no more than twice a year for a total period of 6 months. This would not apply to a unit that had been the subject of an Ellis Act or owner-move-in eviction within the last ten years. • Leases that provide temporary relocation for tenants who are subject to a temporary relocation order under the City’s tenant projection laws. • Leases of ADUs and JADUs for which plans are submitted for plan check before December 2020 for more than 30 days and less than one year. This would only apply if the ADU or JADU is located on a parcel with an owner-occupied single-unit dwelling and the owner of the single-unit dwelling resides onsite throughout the duration of the lease. The City’s Medium-Term Housing Ordinance does not present a constraint on the production of housing and helps preserve the City’s rental housing supply. f. City Anti-Discrimination Ordinances Santa Monica maintains the following anti- discrimination protections within its Code: 8.B.d Packet Pg. 341 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-69 i. Sexual Orientation or Domestic Partnership Chapter 4.40 of the Municipal Code prohibits housing discrimination against persons based upon sexual orientation or domestic partnership. Specifically, the Code prohibits unlawful real estate practices, generally defined as the refusal to treat persons fairly in the sale, lease, or rental of housing; the provision of credit or insurance; the advertisement of housing; and the provision of tenant services. In addition, the Code prohibits evictions against any tenant on the grounds that he or she has breached a rental agreement if the alleged breach arises from an increase in the number of occupants due to the domestic partnership of the tenant provided that the occupancy by the tenant’s domestic partner and children of the domestic partner is otherwise lawful. ii. Persons Living with AIDS Passed by the City Council in 1988 as one of the first ordinances in California to address AIDS discrimination, Chapter 4.52 of the Municipal Code prohibits housing discrimination against a person with AIDS, a history of AIDS, or those regarded as having or transmitting AIDS. Specifically, the Code prohibits unlawful real estate practices, which are generally defined as the refusal to treat persons fairly in the sale, lease, or rental of housing; the provision of credit or insurance; the advertisement of housing; and the provision of tenant services. The only exception applies to the rental or leasing of any housing unit in which the owner or lessor or any member of his or her family occupies one of the living units and it is necessary for the owner or lessor to use a bathroom or kitchen facility in common with the prospective tenants. iii. Families with Children Chapter 4.28 of the SMMC establishes the following actions as unlawful for any person offering for rent, leasing, or listing any housing accommodation, or any authorized agent or employee of such person: • Refuse to rent or lease a housing accommodation, allow access to or use of the common areas and facilities, serve a notice of termination of tenancy, commence an unlawful detainer action or otherwise deny or withhold a housing accommodation on the basis of age, parenthood, pregnancy, or the actual or potential occupancy of a minor or child. • Advertise, represent, or include in any contract with regard to a housing accommodation offered by that person a statement that indicates any preference, limitation, or discrimination with respect to age, parenthood, pregnancy, or the potential actual occupancy of a minor child. • Include in any rental agreement or lease for a housing accommodation a clause providing that as a condition of continued occupancy, the tenants shall remain childless or shall not bear children or otherwise not maintain a household with a person or persons of a certain age. 8.B.d Packet Pg. 342 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-70 • Threaten to commence or commence eviction proceedings against any tenant head of household on the grounds of breach of a rental agreement due to an increase in the number of occupants arising out of the marriage of the tenant, or the birth, adoption, or change of legal custody of a minor child of whom the tenant head of household or his or her spouse is the parent or legal guardian. Exceptions to this chapter include housing designed and operated exclusively for senior adults and their spouses, or any nursing, convalescent, or retirement home. g. Rent Control Bootleg Unit Ordinance In the past, City regulations regarding the status of certain units that had been illegally created and then registered with Rent Control caused conflict. To address this, the City passed an ordinance in 2008 that set forth terms to allow these “bootleg units” to become legal, non- conforming. Pursuant to SMMC Section 9.27.090, a “bootleg unit” is defined as “a rental unit registered with the Santa Monica Rent Control Board, which was built or created without City planning or building permits.” Typically, these units do not meet applicable development standards, but the ordinance allows for the unit to not be required to meet setback and density requirements if the unit is or can be made habitable pursuant to the Building Code. While the legalization of these units might require the addition of parking for the unit, if the Community Development Director determines it is not feasible, the requirement may be waived. The Rent Control Bootleg Unit Ordinance does not present a constraint on housing as it provides a path forward to legalize existing units. h. Water Neutrality Ordinance In response to the State emergency proclamations in 2014 and the Governor’s drought-related executive orders in 2014 and 2015, the City developed a water neutrality ordinance in order to counterbalance increasing potable water demand from new development. Adopted in 2017, the City’s water neutrality ordinance, which is codified in SMMC Section 7.16.050 (the “Water Neutrality Ordinance”), imposes a land use requirement that new development offset net new potable water demand through on-site water saving measures or, alternatively, by installing equivalent off-site improvements (such as water saving toilets and shower heads) or paying an in-lieu offset fee, which is used by the city to fund off-site improvements. The City of Santa Monica is an urban water supplier. Urban water suppliers are required to prepare and implement an Urban Water Management Plan (UWMP) and a Water Shortage Continency Plan (WSCP) in accordance with California Water Code, §10610-10656 and §10608. The Water Neutrality Ordinance is an effective water conservation tool that is considered an integral part of the City’s UWMP and WSCP. These plans support the City’s long-term resource planning to ensure that adequate water supplies are available to meet existing and future water needs. The City’s UWMP and WSCP were last updated and adopted by the City Council on June 8, 2021. 8.B.d Packet Pg. 343 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-71 The Water Neutrality Ordinance applies to new development, including new housing development. A 1:1 offset of the new potable water demand is required for new development, however, the ordinance allows a lower offset of 0.5:1 for new affordable housing development and new ADUs New development projects with projected usage equal to or less than their calculated baseline water demand (i.e. the average annual water demand the previous five years) are not required to offset water usage. Therefore, these projects are not impacted by the Water Neutrality Ordinance at all since they do not generate net new water demand. In reviewing the Water Neutrality Offset Fees assessed to multi-family and mixed-used developments over the past four years, the actual fee assessed in comparison to the development's job value is minimal or insignificant. Thirty-six projects were analyzed with an average valuation of approximately $7.2 million. For these thirty-six projects, the average Water Neutrality Offset Fee assessed was $67,585, or less than 1% of the valuation for the development. City staff is not aware of any development project that has been reduced in scope or not built due to Water Neutrality Offset Fees, nor has any project appealed the fees due to undue hardship. In addition to the minimal Offset Fee to project valuation percentage described above, the following factors also contribute to minimizing or reducing any perceived constraints of Water Neutrality compliance on housing developments: • When older developed sites are redeveloped, the impact of Water Neutrality Offset Fees on the development can be insignificant or non-existent as the redevelopment will use new high-efficiency water saving fixtures (e.g., low flow toilets and high efficiency faucets) that will replace older, higher water consumption fixtures. • Projects that choose to, or may be required to in the future, use recycled water, will have a significant reduction in potable water demand, resulting in a corresponding reduction, or elimination, of the Water Neutrality Offset Fee. • 100% Affordable Housing projects have a reduced offset of 50% of the projected new potable water demand, thus lowering the Water Neutrality Offset Fee accordingly. • ADU projects (conversions or additions) for both single-unit and multi-unit properties are exempt from Water Neutrality Offset Fees if the total water demand for the parcel (including the demand created by the new ADU) is below the property’s Water Conservation Threshold. • If an ADU project is not exempt from the Water Neutrality Offset Fee (per the previous bullet), the new water demand offset is reduced to 50%, thus lowering the Water Neutrality Offset Fee accordingly. Water Neutrality Fees are assessed on a case-by-case basis since the baseline water usage (the average annual water demand the previous five years) is specific to each site and its land use. The City recognizes that there may be potential sites where the Water Neutrality Offset Fee could potentially pose impactful constraints such as redeveloping an existing parking lot (i.e., where the baseline is typically zero) or a single-story commercial site for housing purposes 8.B.d Packet Pg. 344 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-72 (i.e., a change of use with a relatively low baseline for the new project). The City is in the process of evaluating potential impacts and identifying mitigation measures (e.g., reduced offsets, default baseline values), if necessary, in such cases and balance that with water supply availability to ensure the community has access to a reliable and affordable water supply. B. NON-GOVERNMENTAL CONSTRAINTS State law [California Government Code, Section 65583(a)(6)] requires Housing Elements to contain an analysis of nongovernmental constraints to the maintenance, improvement, or development of housing for all income levels including cost of construction, the price of land, and the availability of financing. Potential nongovernmental constraints are largely determined by market conditions over which local jurisdictions have little control. However, local governments can influence market conditions and their associated costs even if only indirectly. 1. Construction Costs A number of factors, such as the type of construction, site conditions, application of parking, unit size, fire safety requirements, and amenities, all impact the cost of housing. In general, multiple- unit housing projects are less expensive to construct than single-unit housing. However, construction costs vary significantly depending on the size of the unit and the number and quality of amenities offered. These include features such as parking supply, swimming pools, rooftop gardens, gyms, and other less obvious decisions based on the types of flooring, appliances, light fixtures, and quality of cabinetry and woodwork. Based on recently completed affordable housing projects built in the City, Santa Monica Housing Office data indicate that total development costs average $480,000 per unit4. Of these total costs, it is estimated that $300,000, or 69%, are “hard costs” related to construction. Total development costs have increased in the past several years due to labor and material availability constraints. Based on construction cost estimates prepared by a third-party City consultant and interviews with market-rate developers, total development costs of apartment projects are approximately $799,000 per unit. Of these total costs, it is estimated that $413,000, or 52%, are “hard costs” related to construction5. Though construction costs comprise a large portion of the total development cost of a project, the costs in Santa Monica are not atypical compared to Los Angeles County and therefore, would not constitute an actual constraint on housing production. 4 November 20, 2019 HR&A Feasibility Analysis 5 HR&A Advisors and MGAC 2021 8.B.d Packet Pg. 345 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-73 2. Land Costs and Availability Land costs include the cost of acquiring land. Land costs typically account for a large share of the total housing production costs. In Santa Monica, one of the primary market constraints to producing market rate and affordable housing is land cost. This is directly attributable to the City’s desirable location and limited availability of vacant and developable land for residential development. Land costs can vary depending on which area of the City the project is located, ranging from $690 per square foot in Downtown to $430-$435 on Lincoln Boulevard/Main Street and the Boulevards. Land costs on recent affordable housing projects in the city averaged $180,000 per unit6 comprising 37% of the total unit development cost. Land costs for market- rate apartment projects are approximately $233,000 per unit comprising 29% of the total unit development cost7. The persistent demand for housing and competition for limited available land has kept Santa Monica residential land values high for many years. The combination of non-governmental constraints (e.g. high land costs) and governmental constraints (low-density development standards) are a constraint to new residential development. It is often challenging to find sites that are large enough to accommodate projects at a preferred development scale (i.e., 60- to 100-unit projects at four to five stories). To the extent that total development costs can be reduced through changes in zoning, development standards, City-imposed development costs, and/or permit processing time, affordability goals can be better accomplished. 3. Availability of Financing The availability of financing is a critical factor that can influence the cost and production of housing. There are generally two types of financing used in the multi-unit housing market: (1) construction financing used for initial site preparation and construction; and (2) permanent financing used to purchase existing buildings or to pay off more-expensive construction financing. Both of these products are generally distinguished from financing available to purchasers of single-unit dwellings as they are commercial real estate products, and there is less government involvement to stabilize rates and availability of debt. The availability and cost (i.e., interest rates) of financing can substantially impact housing production either because it adds cost to a project or because it reduces the value or attractiveness of the sale/purchase of a completed project. Generally, the cost of development in Santa Monica and associated risks present challenges for developers to secure financing for new multiple-unit buildings. The COVID-19 pandemic has also had an impact broadly on the availability of financing although less so for multiple-unit developments. While interest rates remain reasonably low, lenders have been underwriting projects more conservatively during the pandemic leading to tightened credit despite affordable interest rates. These impacts are likely to ease as pandemic conditions continue to improve and the economy recovers. 6 November 20, 2019 HR&A Feasibility Analysis 7 HR&A Advisors and MGAC 2021 8.B.d Packet Pg. 346 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-74 4. Requests for Housing Development at Reduced Densities State law requires the Housing Element to include an analysis of requests to develop housing at densities below those anticipated in the sites inventory. In Santa Monica, density is controlled differently between residential and nonresidential zone districts. In residential zones, density limitations are traditionally prescribed, whereas in nonresidential zones, density is controlled through a combination of building height and FAR development standards. Through a review of projects within these different zone types, projects in residential zones have typically been developed at or below density maximums. This is largely due to when the City’s Affordable Housing Production Program (AHPP) requires affordable units to be provided on site versus when a developer can pay an in-lieu fee. While this can be viewed as a constraint on housing production, it must be weighed against the need for affordable housing. However, Housing Element Program 2.C proposes to reevaluate the City’s AHPP in comparison to achieving the City’s housing goals., and Programs 1 F and 1 J will ensure that housing development projects remain feasible, taking into consideration any AHPP requirements. As for the City’s nonresidential zones, it is rare for developers to not maximize the allowable development potential of a parcel, and therefore, it can be assumed that developers are not under-densifying their developments. Additionally, as described throughout this appendix, the City has implemented several measures to streamline housing projects, which limits or removes the City’s discretion to reduce densities. The sites inventory analysis takes into account past production trends when calculating the capacity for residential redevelopment amongst various zone districts throughout the City. 5. Length of Time Between Project Approval and Applications for Building Permits State law requires an analysis of the length of time between receiving approval for a housing development and submittal of an application for a building permit. On average, the time between these two stages of a housing project varies between three to six months for smaller projects, and sometimes up to a year or more for larger mixed-use projects. This time between approval and applying for a building permit can be contributed to the applicant preparing necessary construction drawings, finalizing construction financing, and retaining various contractors, amongst other actions. 8.B.d Packet Pg. 347 Attachment: Appendix E Constraints Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F: Report on Suitable Sites Inventory Analysis ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●● ● ● ● ● ● ●●● ● ● ● ● ● 8.B.e Packet Pg. 348 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-1 Introduction Santa Monica’s Regional Housing Needs Allocation for the October 2021 through October 2029 planning period is 8,895 units broken down as follows: Income Level % of AMI* Units % of RHNA Allocation Very Low 31-50% 2,794 31% Low 51-80% 1,672 19% Moderate 81-120% 1,702 19% Above Moderate 120%+ 2,727 31% Total 8,895 100% Source: http://SCAG.ca.gov.gov/Housing/rhna.htm * AMI – Area Median Income. Note: SCAG’s RHNA does not include the income level of Extremely Low Income (ELI) (0-30% AMI) units, which are required by the City’s AHPP. ELI units produced in the City are counted towards SCAG’s Very Low Income category. The housing element of the general plan must include an inventory of land suitable and available for residential development to meet the locality’s regional housing need allocation (RHNA) by income level. This inventory is known as the Suitable Sites Inventory (SSI) and is used to demonstrate that there is sufficient land at appropriate densities and development standards to accommodate the RHNA at the income levels specified. This document has been prepared to outline the methodology used for identifying potential housing sites for the City of Santa Monica’s 6th Cycle Housing Element SSI. The methodology follows State Housing Element Law and the guidance of the Housing Element Site Inventory Guidebook prepared by the Housing and Community Development Department (June 2020). Overview of the City’s Suitable Sites Inventory Per State law, the City’s SSI consists of sites that are reasonably likely to be redeveloped into residential during 6th Cycle planning period. The SSI includes sites with approved/pending projects, underdeveloped sites that were identified, and non-site-specific accessory dwelling unit potential. A total of 340 sites are identified. Under current zoning, the SSI has an anticipated unit potential of 7,596 units with capacity for 4,064 affordable units. Therefore, the City will have an anticipated shortfall of 1,109 lower income units and 1,003 moderate units. State law dictates that if sufficient capacity to meet the RHNA cannot be demonstrated based on existing zoning, the City is required to rezone sites on the inventory by October 15, 2024 to demonstrate the ability to meet sufficient capacity. The rezoning programs are Programs 1.F, 1.J, 1.K, and 4.A. With these rezoning programs, the City’s 8.B.e Packet Pg. 349 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-2 SSI capacity is estimated to be approximately 13,600 units which includes capacity for 8,044 lower income units and 1,901 moderate income units. Methodology for Suitable Sites Inventory The City of Santa Monica maintains a comprehensive land use inventory that includes details for every parcel within City limits. The methodology for the Suitable Sites Inventory consists of a multistep process that narrows down the list of suitable sites from the City’s Land Use Inventory. The Land Use Inventory was first created in 2010 during preparation of the City’s Land Use and Circulation Element, and is a master inventory of each parcel in the City that identifies existing uses, ownership, building age, zoning, and other information. The Land Use Inventory is updated every two years using assessor land use information, the City’s building permit database (for demolitions and new construction), and site visits to confirm existing uses. The SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning and general site constraints such as historic designations and land use. After screening out unavailable sites, City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, market factors, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. The methodology is described step by step below: 8.B.e Packet Pg. 350 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-1 Step 1: Identify Available Multi-Unit Residential Zoned Parcels  Difficult to identify Single Unit parcels for SSI Step 2: Site Screening  Properties with Residential Unlikely to Redevelop (rent control units, condos, multifamily, SB330 replacement requirements) Step 3: Assess Suitability of Sites Review Residential Potential with Consideration to:  Parking lots (or A-lots) associated with Commercial fronting parcels  Parking lots associated with religious institutions  Vacant sites City Land Inventory 1. Filter out: Single Family, Ocean Park Single Family, Ocean Park Duplex, Residential Mobile Home Commercial and City Parcels Residential Parcels 2. Remove properties based on Site Constraints & Other Known Factors Screened Commercial and City Parcels 4. Assess Suitability of Sites based on Factors Step 3: Categorize Potential Sites Categorize Potential Sites that have highest potential for turnover Step 1: Identify Available Commercial Zoned Parcels & City Owned Properties • Ensures No Net Loss • Consistent with Housing Preservation goals and policies • Consistent with LUCE Neighborhood Protection goals and policies Step 2: Site Screening Remove sites based on Factors That Impede Residential Redevelopment • Government Open Space • Historic Landmarks • Affordable Housing & Condominiums • Unique land uses (cemetery, hospital, parks, libraries, fire/police stations etc) • Under Construction or Recently Constructed Projects • Newer buildings (constructed post 1980) • Right-of-ways (such as medians/transportation corridors) Step 4: Assess Suitability based on Site Specific Evaluation Review Residential Redevelopment Potential with Consideration to:  Physical Attribute - Sites with these factors are most suitable: • Sites of 15,000 sf or more • Corner parcels  Existing Use - Sites with these factors are most suitable: • Parking lots (if site is completely or partially developed as parking) • One story building • Vacant (no tenants) or Less than 2 Tenants  Redevelopment Potential – Sites with these factors are most suitable • AVR less than 0.5 • Ownership by known housing provider • Developer interest based on current or past discussions with City staff  Other Local Knowledge – Sites are removed if • Existing tenants have longevity (eg, well known successful tenant with long term lease) • Significant improvements and investments have occurred on the site within the past 4 years 1. Approved/Pending Projects 2. Prior SSI properties 3. Downtown Community Plan buildout 4. City Owned Sites 5. Vacant & Parking Lots 6. Auto Dealership Inventory Lots 7. Recently sold/for sale 8. Large parcels (15,000 sf +) 9. Development Potential of 20K sf 10. Remaining parcels less than 0.5 ILR 3. Categorize Potential Sites SSI Sites *Identified as high potential sites meeting the suitability factors of Existing Use, Physical Attribute, and Development Potential 2. Remove properties if there are existing residential uses Screened Residential Parcels 3. Assess Suitability of Sites SSI Sites *Identified as A lots associated with commercial fronting parcels or those associated with religious institutions 8.B.e Packet Pg. 351 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-3 Step 1: Identify Available Commercial and Residential Parcels As a first step in the SSI process, parcels that are not available for residential redevelopment due to zoning were removed from consideration. Parcels in the City’s single unit zones (R1, OP1, and OPD) were filtered out from the SSI process for the following reasons:  Lack of vacant parcels in these zones  Difficulty in identifying specific parcels for the inventory since there are no known factors that could assist in determining which parcels would be redeveloped.  Even if parcels were identified, redevelopment would likely consist of demolition and replacement of existing on-site units  Parcels in the Residential Mobile Home (RMH) and Open Space (OS) districts are also removed from the SSI process since these parcels are protected by the City for low income housing and open space uses respectively. Step 12: Site Filtering Screening for Non-Suitable Parcels The City of Santa Monica maintains a comprehensive land use inventory that includes details for every parcel within City limits. This inventory was utilized to prepare the SSI. As a second step in preparing the SSI, parcels in the City that are not potential candidates for housing development during the Housing Element planning period were filtered screened out based on a set of criteria. Since housing development on residential and commercial parcels are influenced by different sets of factors, residential and commercial parcels were separately screened. Commercial Parcels In general, commercial parcels meeting any of these criteria were determined to not be suitable as a housing site and screened out from the SSI:  RMH (residential mobile home), OS (open space) zones  Historic Designations: Parcels Designated with existing Landmarks or hHistoric rResources, including Landmarks and/or Structures of Merits, are protected by the City’s Landmark Ordinance and the California Environmental Quality Act. Demolition of historic resources are only permitted with a Certificate of Hardship. While there have been instances where new residential development is proposed on larger parcels in conjunction with the preservation or adaptive reuse of historic resources, such instances are uncommon. Therefore, the presence of historic resources is presumed to preclude new housing development on the site.  Under Construction or Recent Construction Projects: Parcels that are under construction, or have recently completed projects are not available for redevelopment into housing and therefore, are screened out from the SSI process., approved entitlements, and  Commercial Entitlements: Parcels that have approved or pending entitlements for solely for commercial commercial uses onlyuses are screened out from the SSI process since these parcels will be redeveloped into commercial. 8.B.e Packet Pg. 352 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-4  Government or Institutional Uses: Parcels that have unique land uses such as governmental or institutional uses are unavailable for redevelopment and are also screened out from the SSI process. These include parcels with uses such as the Civic Center government uses (Santa Monica City Hall, Los Angeles County Courthouse, Civic Auditorium), UCLA and Providence Saint John hospitals, Santa Monica Ccemetery, SMUUSD schools, Santa Monica College, public parks, churches/religious facilities, utilities, government offices, libraries, police/fire stations, transportation infrastructure/Metro Expo Light Rail and the Santa Monica Aairport. The City and institutions are unable to remove these uses in this housing element cycle as they are necessary to serve the community.  Residential Uses: The City filtered the inventory to remove parcels that are currently occupied by residential uses. In particularly, pParcels developed with affordable housing, condominium units, and rent control units are highly unlikely to be redeveloped. Affordable housing is protected by long term deed restrictions, and therefore were screened out. Condominium units are common interest properties with multiple owners, and therefore, are screened out due to infeasibility of acquiring all condo ownership parcels. Rent control units are governed by the City’s Rent Control laws that limit the removal of such units and are therefore screened out from the inventory.  Newer Buildings: Parcels with newer buildings developed post 1980 are highly unlikely to be redeveloped as supported by a review of current approved and pending projects (see Attachment 1, Table 2).  Residential Parcels The City screened the inventory to remove residential parcels that are currently occupied by residential uses. This approach is conservative since the City’s general plan emphasizes the protection of existing residential units and because parcels with residential uses are governed by SB330 unit replacement requirements. Furthermore, parcels developed with affordable housing, condominium units, and rent control units are unlikely to be redeveloped. Affordable housing is protected by long term deed restrictions, condominium units are common interest properties with multiple owners, and rent control units are governed by the City’s Rent Control laws that limit the removal of such units. 8.B.e Packet Pg. 353 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-5 Step 23: Categorizing Sites After screening out parcels that are not available for redevelopment, the remaining list of sites were categorized. Commercial Parcels Based on this first set of filtering screening criteria, 1,300 368 potential commercially zoned sites and City-owned sites were initially identified. These sites were then categorized according to the figure below: Figure F-1 Category of Potential Commercially Zoned and Mixed Use Zoned Sites Category Description Count of Parcels Land SF 1 Approved and Pending Housing Projects 172118 3,222,0922,439,430 2 Prior SSI Sites 4650 1,015,5451,098,659 3 DCP Buildout 1220 180,263240,248 4 City-Owned Sites 106100 3,723,5053,641,062 5 Parking Lots 116118 1,026,7091,037,700 6 Auto Inventory Lots 4143 407,651422,680 7 Parcels with recent/active sales 4741 385,129340,818 8 Underutilized Sites (20,000 excess sf development potential) 183217 5,953,8997,520,075 9 Large Parcels (15,000 sf+) 6617 2,268,697274,850 10 Remaining Sites less than 0.5 AVRILR 579576 3,721,8703,675,065 Category 1 Sites: Pending/Approved Housing Entitlements The RHNA projection period for the 2021-2029 Housing Element begins on June 30, 2021. Therefore, pipeline housing projects that are pending or have received approved entitlements but did not receive a building permit as of July 1, 2021 are expected to count toward the 6th Cycle RHNA. As of February 2021, there were approximately 1,670 approved units (of which 401 are affordable) and 756 pending units. Category 2 Sites: Prior Sites listed in the 2013-2021 5th Cycle Housing Element 83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have undergone entitlements but the remaining have not. These are categorized as Category 2 Sites. Category 3 Sites: Downtown Buildout Sites 8.B.e Packet Pg. 354 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-6 As part of the Downtown Community Plan (DCP), sites in the Downtown were identified for potential redevelopment. A number of these sites have already undergone pending and approved entitlements (captured in Category 1), and as such, are eliminated from further consideration. In addition, a small number were previously identified in the prior SSI for the 5th Cycle Housing Element (hence are captured in Category 2). The remaining DCP sites are classified as Category 3. Category 4 Sites: City-owned Sites An important strategy for the City to meet its RHNA targets is the utilization of existing City owned sites for housing, particularly affordable housing. All City owned sites that are not currently developed with open space/parks, community centers, civic uses, utilities, etc. are categorized as Category 4 sites. Public parking structures such as Parking Structure (PS) #3, PS#1, PS#2, and PS#4 are reviewed in this category since these structures require seismic retrofit improvements for their continued operation. Additionally, the City’s parking lots on Main Street are reviewed as potential housing sites. Category 5 Sites: Parking Lots There are no vacant sites in the City as it is highly urbanized. No vacant sites are located in the commercial and mixed use zones. However, a number of sites in the City are developed as surface parking lots. Surface parking lots are very underutilized and represent the greatest opportunity for new housing without displacement of existing uses. Redevelopment of these lots are considered with the commercial uses they serve. Category 6 Sites: Auto Inventory Lots These are parcels currently being utilized almost entirely as auto inventory surface lots, with the majority occurring on the eastern end of Santa Monica Boulevard. Auto dealerships have indicated interest in turning over these large surface lots into redevelopment opportunities as they are rethinking their sales operations. Category 7 Sites: Recent/Active Sales Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites (such as Loopnet), a number of properties have recently sold during 2019-2021 or have active sales listings. These sites could have redevelopment potential. Category 8 Sites: Underutilized Sites (20,000 sf excess development potential) Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to have a net new development potential of 20,000 sf or greater (based on their existing built area compared against the maximum floor area permitted). Category 9 Sites: Remaining Large parcels Category 9 sites are all remaining sites that are 15,000 sf and larger. Category 10 Sites: Remaining Parcels with 0.5 AVRILR or less 8.B.e Packet Pg. 355 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-7 Category 10 sites are all the remaining sites (not meeting Category 1-9) with an assessor’s improvements to land value ratio (AVRILR) of 0.5 or less. Residential Parcels For residentially-zoned parcels, sites that are developed with existing residential uses were filtered out to be consistent with the City’s goal of preserving existing housing and preventing displacement of residents. were not screened out are categorized as religious institutional uses, or parking lots. Approximately 38 parcels were identified as parking lots that are associated with religious institutions and 97 parcels are surface parking lots for adjacent street fronting commercial uses. Figure F-2 Category of Potential Residentially Zoned Sites Category Description Count of Parcels Land SF 11 Religious Institutions 38 555,589 12 A-Lots and Residentially Zoned Parking Lots 97 911,847 Category 11 Sites: Religious Institutions Category 11 sites are properties of religious congregations (churches, synagogues, etc.). AB1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. A number of religious institutions with large surface parking lots are located throughout the City. These lots could play an important part in providing affordable housing. Program 4.B of the Housing Element would amend the Zoning Ordinance to create special standards for housing projects on sites owned by community assembly uses so that these sites would be incentivized for the production of housing. Category 12 Sites: A-Lots and Residentially Zoned Parking Lots “A-Lots” are residentially-zoned (R1/R2/R3/R4) parcels with an “A” Off-Street Parking Overlay. Within the City, there are 42 A-lots. Zoning regulations prevent their use to enable the expansion of associated commercial uses, but also effectively prevent their redevelopment for housing. Additionally, there are other residentially-zoned parcels without the A-Lot overlay that are similarly developed as surface parking lots. These surface parking lots are intended to support the parking needs of commercial corridors and neighborhood commercial areas, and to serve as a buffer between commercial and residential uses. The existing multi-unit residential zones have density caps of 4-6 units regardless of the size of the property, which limits their capacity for housing potential . 8.B.e Packet Pg. 356 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-8 Step 34: Evaluating Suitability of Nonvacant Sites for Housing Potential Government Code section 65583.2(g)(1) requires that, where non-vacant sites comprise over 50% of the Suitable Sites Inventory, existing uses are presumed to impede development unless findings with substantial evidence are provided that the use is likely to be discontinued. Santa Monica is a dense, urban coastal community and is entirely built out with little to no vacant land remaining. Therefore, the methodology used to identify the suitability of non-vacant sites for housing potential must consider factors such as site physical characteristics, existing uses, improvements to land value ratio, ownership, development interest, location and context, local knowledge, and environmental constraints. Methodology As a second stepOnce all the screened sites were categorized, all individual sites in Category 1-10 were reviewed by the City’s Housing Policy team using Google Streetview, City Accela permit database, and if necessary, in-person site visits. All of the sites are non-vacant, and have an existing use or are developed as parking lots. The City focused the list of non-vacant sites to those that are underutilized and primarily located within the mixed use and commercial districts where the City has encouraged housing. These districts include, but are not limited to, the Downtown districts, the Bergamot Area, and the corridors of Santa Monica Boulevard, Wilshire Boulevard, Colorado Avenue, Broadway, and Lincoln Boulevards. Recent project applications that have been filed by the City support the assumption that there is a strong housing demand in these districts. Each site was analyzed to determine its likelihood and suitability for residential redevelopment based on a set of site-specific factors. These factors were selected based on City Staff’s experience and long standing knowledge of the current projects in the pipeline and development interest in certain areas of the City. Interviews with local developers and architects from the Housing Production Technical Working Group and the general public confirmed also informed the factors and assumptions in the Site Inventory. The criteria and factors for the City’s Housing Element site inventory was presented to the public, Planning Commission, and City Council where all agreed these are appropriate criteria. The City also verified its assumptions by analyzing recent project application since adoption of the LUCE to assess development trends. Since July 2010, 152 residential and mixed use residential development applications have been received for more than 5,553 new housing units – all of which have occurred on non-vacant sites. A review of these past and current housing projects support the use of these site specific fFactors (see Attachment B) , which are described belowconsidered included: Per HCD, a vacant site is a site without any houses, offices, buildings, parking lot, or other significant improvements on it. The City of Santa Monica is a dense, urban coastal community and is entirely built out with no vacant land remaining. Nonvacant, underutilized sites will be relied on to achieve the 6th Cycle RHNA. This is supported by past residential development trends which has primarily consisted of new multi-unit buildings replacing older one-story buildings on infill sites (see Attachment 1). 8.B.e Packet Pg. 357 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-9  Site Physical Characteristics - Sites were reviewed for physical characteristics that could make them more amenable to residential development, such as size, location relative to the urban grid, and shape of the site. o Size: Based on a review of past and current housing projects (see Attachment 2), housing projects have occurred on commercial and mixed used zoned sites that are as small as 7,500 sf. This includes 100% affordable housing projects where site sizes have ranged from 7,500 sf to 30,000 sf. Housing development trends in the City indicate that a site that is 15,000 sf is generally considered sufficiently sized for residential redevelopment in the mixed-use, commercial zones (see Attachment 2). Since the majority of the housing projects (more than 90%) have occurred on sites that are 15,000 sf or greater, City staff used a size threshold of 15,000 sf for the SSI process. Sites as small as 7,500 sf may be appropriate for certain projects such as those in the Downtown and/or 100% affordable housing projects which do not require parking. Individual parcels less than 15,0007,500 sf are unlikely to be developed. However, if two smaller adjacent parcels share common ownership, there could be potential for housing development depending on the remaining factors. The City does not have any restrictions on lot consolidations for the commercial or mixed use zoning districts, and consolidation is a common practice. Housing developers have historically consolidated lots for development and such consolidations are administratively approved as part of the plan check process. Based on review of past housing projects, a site that is 15,000 sf is generally considered sufficient sized for residential redevelopment in the mixed-use, commercial zones. Sites as small as 10,000 sf may be appropriate for certain projects such as those in the Downtown and/or 100% affordable housing projects which do not require parking. Appendix B provides evidence of past and current housing projects that have occurred on sites that are 15,000 sf or less. o Corner Parcels or Parcels with Alleys: As a general policy, the City’s General Plan discourages vehicular access from the main boulevard. Therefore, based on City staff experience as well as current trends of development, sites with corner parcels are more likely to be redeveloped given that vehicular access can be taken from the side street or from the alley. o Other Factors: In addition to size, sSites were reviewed for any other potential physical characteristics that could make them more amenable topreclude residential development, such as access to an alley, shape of the site (including narrow depth/width), grade, and other physical constraints such as lack of accesslocation relative to the urban grid.  Existing uses – Due to the built up nature of the City, As listed in Attachment B, past and currently proposed housing projects have all occurred all on non-vacant sites. 8.B.e Packet Pg. 358 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-10 These sites were built or proposed on sites with existing uses consisting of older buildings or surface parking lots as listed in Attachment B. Based on City staff’s knowledge of the community Using Google Streetview supplemented with site visits as necessary, existing uses on the site were assessed to determine its future viability and likelihood for the uses to be discontinued. For example, uses that are more unique in a particular location (such as a successful grocer in a residential neighborhood, a popular restaurant, long-standing reputable business, etc.) have demonstrated longevity, and, as such, may be considered an impediment to redevelopment of the site. Similarly, sites with multiple tenants are more unlikely to turn over than single tenant sites. Sites that are developed as parking lots are considered more likely to be redeveloped than sites with existing building improvements. Based on past experiences as well as review of approved/pending projects (see Attachment 1, Table 2), City staff determined that sites with these existing uses are most suitable: o Parking lots (if site is completely or partially developed as parking) - Sites that are developed as parking lots are considered more likely to be redeveloped than sites with existing building improvements. o One story building - Sites that are developed with one story buildings are also more likely to be redeveloped as they are considered underutilized. o Vacant (no tenants) or Less than 2 Tenants - Similarly, sites that are vacant or have only a single tenant are more likely to turn over than multiple tenant sites.  Location and Context – The location of the site was also considered in terms of its access to schools, jobs, transit, residential amenities such as parks/open space, health care services, and retail shops such as grocers. Many of the sites south of Olympic Boulevard lack access to these amenities and services, and, as such, were determined to not be suitable. Additionally, existing/past housing development trends in the site surrounding area were considered – reviewing if the project is located in an area where there is significant residential growth.  Redevelopment Potential – Sites were also reviewed using redevelopment potential factors such as the improvements to land ratio based on assessor’s value of land to improvements ratio, ownership information, and known developer interest. o Improvements to Land Value Ratio - A low improvements to land value ratio (ILR), which is the ratio of improvement value to the land value, is a strong indicator of the likelihood that a site has a high probability of being redeveloped.1 A review of current pending and approved projects show that these projects have occurred almost all on commercial/mixed use zoned parcels with ILR less than 0.5 (see Attachment 1, Table 2). 1 The Institute of Urban and Regional Development (IURD) at the University of California, Berkeley suggests that a ratio of improvement value to land value that is below 1.0 is an appropriate factor to identify potential housing sites on infill commercial properties. 8.B.e Packet Pg. 359 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-11 o Ownership – Ownership of properties was also considered in the analysis. As previously stated, if two smaller adjacent parcels share common ownership, there is a high potential for housing development. The City does not have any restrictions on lot consolidations for the commercial or mixed use zoning districts, and will continue to facilitate consolidation through administrative lot tie agreements as part of the plan check process. Therefore, adjacent parcels that are held by the same owner could be developed jointly as evidenced in the City’s list of approved and pending projects (see Attachment 1, Table 2). Furthermore, parcels that are owned by known housing developers, for example, are very likely to be redeveloped. Several underutilized sites in the City are owned by State entities, institutions, and public utility companies that have the potential to accommodate housing, including the Department of Motor Vehicles (DMV) site at 2235 Colorado Ave, Santa Monica Municipal Unified School District (SMMUSD) former district offices at 1651 16th St, and the University of California, Los Angeles (UCLA)-owned parking lots at 1521 & 1601 Santa Monica Blvd. The City initiated discussions with these entities to inquire about their potential interest in housing development. Both the DMV and UCLA indicated that they had no plans for future housing on their properties. However, the SMMUSD indicated their intent and interest in developing housing for their staff at their former district offices (see Attachment 4). If State controlled sites are included in the SSI, HCD requires documentation be provided that shows that housing can be accommodated with the Housing Element planning cycle. o Known Developer Interest – If a developer has expressed interest in developing a site either through a pre-submittal meeting with the City or through general inquiry, then there is a higher likelihood that the site will be redeveloped.  Location and Context – The location of the site was also considered in terms of its access to schools, jobs, transit, residential amenities such as parks/open space, health care services, and retail shops such as grocers. Many of the sites south of Olympic Boulevard lack access to these amenities and services, and, as such, were determined to not be suitable. Additionally, existing/past housing development trends in the site surrounding area were considered – reviewing if the project is located in an area where there is significant residential growth.  Other Local Knowledge – City Staff have in-depth local knowledge of properties that could preclude site development. For example, specific parcels were removed if: o Existing tenants have longevity (eg, well known successful tenant with long term lease) - For example, uses that are more unique in a particular location (such as a successful grocer in a residential neighborhood, a popular restaurant, long-standing reputable business, etc.) have demonstrated longevity, and, as such, may be considered an impediment to redevelopment of the site. 8.B.e Packet Pg. 360 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-12 o Significant improvements and investments have occurred on the site within the past 4 years – Where there has been significant investments and improvements that have been made to a site, the site is unlikely to be redeveloped in the near term.Assumptions of Residential Probability vs Commercial  Market Conditions - The Housing Element will continue to incentivize commercial projects over residential projects across the City through Program 1.J, which will rezone the mixed-use and commercial zoning districts with higher maximum allowable FAR and height for housing projects. The FARs for housing projects will be at least 75% greater than the commercial FARs. Financial feasibility testing conducted by the City’s economic consultant indicates that with the new higher FARs and heights, housing projects will be more likely to occur than commercial projects. All the sites selected on the SSI will be rezoned with the new higher FARs and heights for housing projects. Therefore, it is highly likely that the sites will be redeveloped for residential rather than commercial.  Availability of Regulatory Incentives – The City has also most recently adopted regulatory incentives to encourage residential development, including adopting an Emergency Interim Ordinance on March 10, 2020, allowing 100% affordable housing 4 7 7 8 4 10 19 17 23 15 18 44 2 4 3 1 3 6 2 2 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021# OF PROJECTSAPPLICATION YEAR Number of New Construction Commercial and Residential Projects by Application Year Residential Commercial 8.B.e Packet Pg. 361 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-13 projects and housing projects up to Tier 2 maximums that are subject to the protections of the Housing Accountability Act to be reviewed through a by-right administrative process. Program 1.A would make this streamlining provision permanent and expand the applicability to other housing projects, including projects that are granted minor modifications.  Environmental and Infrastructure Constraints –HCD requires that cities identify any environmental constraints (e.g., fault hazard zones, flood areas, landslide zones, very high fire hazard severity zones) and infrastructure limitations that have the potential to impact the development viability of the identified sites. These constraints can include natural resources, hazards/safety concerns, or lack of sufficient infrastructure capacity. All parcels included in the sites inventory were reviewed for any known environmental constraints, such as flood zones, steep slopes, and other possible constraints to development feasibility. The sites included in the inventory are not constrained by topography, known environmental factors, or other site-specific constraints that would limit development. As summarized in Attachment 3, environmental concerns do not pose a significant constraint to housing production. Infrastructure upgrades, however, would be necessary to accommodate the development of 8,895 units in the next 8 years but these are anticipated to occur with the City’s Capital Improvements Program or in conjunction with housing projects. Therefore, infrastructure systems do not pose a constraint to housing. Evaluation City staff reviewed the current status of each site and evaluated the sites using the factors above. Sites were given a rating n evaluation of whether they had low, medium, medium high, and high potential for housing redevelopment. The table below show the qualifying factors for each rating. Staff did extensive research on the site, reviewing physical conditions, existing uses and other factors and removed any identified sites with demonstrated impediments. Finally, staff also conducted additional market research to support assumptions around parcel turnover at the sites. In general, as shown in the table, high potential sites include those that are adequately sized or have common ownership with adjacent parcels, are occupied with single tenants, are underutilized and occupied with aging, one story buildings, and are located in proximity to other recent housing projects. Figure F-3 Sites Inventory Evaluation Factors Factors Utilized Redevelopment Potential High Medium High Medium Low Physical Attribute Sites of 15,000 sf or more x x x Corner parcels x x Existing Use Parking lot or One Story x x Vacant or Less than 2 tenants x Redevelopment Potential 8.B.e Packet Pg. 362 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-14 ILR less than 0.5 At least one x Ownership by Developer Known Developer Interest Location Near transit/amenities x x x Other Local Knowledge Existing uses have longevity x Recent investments x The Suitable Sites Inventory is comprised of 332 341 high potential sites categorized as follows. Category 1 Sites: Pending/Approved Housing Entitlements As of May 2022, there were approximately 2,594 approved units (of which 637 are affordable) and 2,550 pending units (of which 420 are affordable)As of February 2021, there were approximately 1,670 approved units (of which 401 are affordable) and 756 pending units. All approved and pending projects are considered high potential sites. Category 2 Sites: Prior Sites listed in the 2013-2021 5th Cycle Housing Element The parcels listed in the 5th Cycle 2013-2021 Housing Element were re-evaluated to determine suitability for housing potential. Parcels were determined to have low potential if they are inadequately sized (less than 7,500 sf), have undergone recent tenant improvements, or are occupied with newer tenants (indicating long term leases). Remaining sites were evaluated and considered high potential if they are adequately sized and if there is a low AVR ILR of less than 1.0 FAR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or unoccupied, etc). Category 3 Sites: Downtown Buildout Sites As part of the Downtown Community Plan (DCP), sites in the Downtown were identified for potential redevelopment. All these sites have low AVRILR and have older buildings, indicating high potential. The Downtown is one of the most attractive areas for housing development due in part to higher development standards for housing, access to a variety of amenities, proximity to transit, and no parking minimums. In general, the limiting factor is site size. Based on discussions with developers from the Housing Element Housing Production working group, single lot parcels (generally consisting of 7,500 sf) are infeasible to develop. Therefore, sites within the DCP that are 7,500 sf or smaller were eliminated. The remaining DCP sites are considered high potential. Category 4 Sites: City-owned Sites City staff reviewed all City-owned land to determine if there is potential for housing development. A number of City-owned sites have the highest potential to accommodate the 8.B.e Packet Pg. 363 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-15 production of affordable housing. These sites do not have long-term leases with outside parties that extend beyond the 6th Cycle Housing Element planning period and do not have existing uses that are non-City operated, and therefore are considered high potential. High potential City-owned sites include the parcels serving as the parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Public Parking Structure 3, and the Bank of America/Chase bank site at 4th Street/Arizona. Category 5 Sites: Parking Lots As previously stated, there are a number of sites in the City that are developed as surface parking lots. Many of these lots serve one-story commercial uses. These surface parking lots were considered in conjunction with the commercial uses they serve, if any. Sites were considered high potential if they are adequately sized, if there is common ownership with adjacent commercial parcels they serve, the existing buildings on the site are more than 40 years old, there is known developer interest, and if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, on-site business is not well known in the community, etc.). Category 6 Sites: Auto Inventory Lots Santa Monica has a number of auto dealerships with large surface parking lots used for auto inventory. In some cases, auto dealerships span multiple parcels with some on adjoined lots and some on separate lots. Some of the parcels serve as inventory parking for used cars or new cars. Sites were considered high potential if they are adequately sized, there is common ownership with adjacent parcels, there are other multiple parcels located elsewhere that are also owned by the same owner (if so, they can adequately serve as inventory for both used and new cars), or if there has been known developer interest. Category 7 Sites: Recent/Active Sales Properties that have recently sold during 2019-2021 or have active sales listings were evaluated and considered high potential if they are adequately sized and located in an area where residential has occurred or occurred nearby. Recently sold sites that are occupied with new tenants were excluded and determined to have low potential. Category 8 Sites: Underutilized Sites (20,000 sf excess development potential) Category 8 sites have a net new development potential of 20,000 sf or greater (based on their existing built area compared against the maximum floor area permitted). Sites were evaluated and considered high potential if they are adequately sized and if there is a low AVRILR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc). Category 9 Sites: Remaining Large parcels Category 9 sites are all remaining sites that are 15,000 sf and larger. Sites were evaluated and considered high potential if they are adequately sized and if there is a low AVRILR, the existing 8.B.e Packet Pg. 364 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-16 buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc.). Category 10 Sites: Remaining Parcels with 0.5 AVRILR or less Category 10 sites are all the remaining sites (not meeting Category 1-9) with an assessor’s improvements to land value ratio (AVRILR) of 0.5 or less. Sites were evaluated and considered high potential if they are adequately sized and if there is a low AVR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc). Based on the review assessment of sites using the above factors and methodology, there are 108 137 parcels that have approved and /pending projects for residential development (Category 1) and 200 185 commercially/ mixed used zoned and City-owned non-vacant commercial/mixed use zoned parcels (Categories 2-10) in the City identified to have high potential for residential redevelopment. Together these 308 parcels comprise approximately 4.4 million sf of land area and are included in the SSI. An additional 24 22 residentially zoned sites developed as surface parking lots are identified as having high potential, and therefore are also included in the SSI. The Housing Element includes Program 1.C to adopt standards that will incentivize A-Lots and residentially zoned parking lots to be developed in support of multi-unit housing development. Together these 340 parcels comprise approximately 5.2 million sf of land area and are included in the SSI. Figure F-3 4 Summary of Commercial and Mixed Use Zoned Sites in SSI High Potential for Redevelopment Category Description Total Land Area Count of Parcels 1 Approved and Pending Housing Projects 1,301,284921,522 108138 2 Prior SSI Sites 535,920466,371 2321 3 DCP Buildout 124,51794,015 137 4 City-Owned Sites 726,027778,481 2524 5 Vacant Sites/Parking Lots 164,891 21 6 Auto Storage Lots 243,704206,212 2723 7 Parcels with recent/active sales 253,802168,576 2317 8 Underutilized Sites (20,000 excess sf development potential) 814,893767,643 3230 9 Large Parcels (15,000 sf+) 135,267 6 10 Remaining Sites with less than 0.5 AVRILR 214,016210,996 31 Grand Total 4,498,1584,913,974 308318 Figure F-4 5 Summary of Residentially Zoned Sites in SSI High Potential Residentially Zoned Sites Category Total Land Area Count of Parcels 8.B.e Packet Pg. 365 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-17 Description 11 Religious Institutions 149,307 7 12 A-Lots/Residentially Zoned Parking Lots 185,083168,609 1715 Grand Total 334,390317,916 2422 Reliance on Nonvacant Sites to Accommodate more than 50 percent of RHNA The City of Santa Monica is a dense, urban coastal community and is entirely built out with little to no vacant land remaining. As such, this Housing Element relies on nonvacant sites to accommodate 100 percent of its RHNA for lower income households. Based on analysis of the factors discussed above for each category of sites (such as age of buildings, known developer interest, low AVRILRs, size of sites, development trends, market conditions, ownership information), the City anticipates that the existing uses on the SSI sites will likely be discontinued during the planning period. Pursuant to Government Code Section 65583.2(g)(2), as part of its resolution adopting this Housing Element, the City will include findings stating that uses on nonvacant sites identified in the SSI to accommodate the RHNA for lower income is likely to be discontinued during the planning period. Replacement of Affordable Units Excluding approved and pending housing projects (Category 1 sites), two sites on the SSI have existing residential uses. As required by Government Code Section 65915(c)(3), this Housing Element includes Program 3.A, which would require new housing projects on sites with existing residential units or within the last 5 years, that have or had residential units that are lower income, rent control, or affordable units to replace those units at the same or lower income level. 8.B.e Packet Pg. 366 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Map F- 1 Suitable Sites Inventory 8.B.e Packet Pg. 367 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-19 Step 45: Housing Realistic Capacity Analysis of Suitable Sites 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. Category 1 – Approved and Pending Projects As previously stated, as of February 2021 May 2022, there were approximately 1,6702,594 approved units (includes 416 637 affordable) and 756 2,550 pending units (includes 165 420 affordable) on 109 parcels. These sites are listed in Appendix A. A review of the past 5th Cycle Housing Element show that 1015% of approved and pending projects are withdrawn , and/or have had permit approvals expire, or have not pulled building permits within 8 years of project approval (i.e., housing element cycle).. It is not possible for City staff to predict which specific approved and pending projects would be withdrawn or ultimately not developed. Eliminating some projects and not others would be arbitrary and speculative. However, based on information from the prior Housing Element cycle, a 1015% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 1,5032,205 approved units and 680 2,168 pending units that are projected to be counted towards the 6th Cycle Housing Element. Figure F-5 6 Approved and Pending Projects Housing Capacity # of Units # Units Counted for SSI (w/ 10% discount) Category 1 Approved 1,6702,594 1,5032,205 Category 1 Pending 7562,550 6802,168 Category 4 – City-Owned Sites The City-owned sites determined to have the highest potential to accommodate the production of affordable housing include parcels serving as parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Parking Structure 3, and the site at 4th Street/Arizona. All parcels are developed as public parking or have uses with expiring lease terms during this 6th Cycle planning period, which provide for the most housing development potential. Furthermore, these sites do not have any existing residential uses. However, the existing density standards and FARs limit housing potential. For example, the public parking parcel on Main Street is zoned R3 and has a density cap of 5 units on a parcel. Therefore, this 6th Cycle Housing Element includes Program 2.E, which would commit City-owned sites for the development of affordable housing through a public process, which would include necessary rezoning to accommodate the estimated realistic capacity for these sites. To determine the estimated realistic capacity, the City engaged with HR&A advisors and local architects who considered existing constraints, including, but not limited to, lease terms for commercial uses on the property located at 4th/Arizona and Property Management Agreement with associated 8.B.e Packet Pg. 368 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-20 annual an Exclusive Negotiating Agreementleases for potential development ofat the Bergamot Arts Center which are set to expire during the 6th Cycle, financial feasibility, available funding sources, etc. Based on an assumption that affordable housing would likely not be greater than 6-7 stories (due to increasing costs associated with construction type – e.g., Type 3 vs. Type 4 construction), it is estimated that the City-owned sites could accommodate a density of 150 units per acre. Therefore, applying a density factor of 150 units/acre, City-owned sites have the potential for accommodating 1,884 1,880 units. To ensure that City-owned SSI sites can be counted towards meeting the RHNA, Program 2.E commits the City to plan for a target of 1,8841,880 affordable units across City-owned sites which may include, but shall not be limited, to rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. 8.B.e Packet Pg. 369 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-21 Figure F-6 7 City-Owned SSI Sites Address Parcel Nos. GP Designation Zoning Existing Use Existing Base Allowable Density or FAR Proposed Density with Program 2.E Land Area (sf) Unit Capacity with Program 2.E Other Info 1146 16th St 4281005900 Low Density Residential R2 Public parking lot 8 behind Café Zella 1 unit/2000 sf or 4 units (whichever less) 150 units/acre 7,500 26 No leases – parking is City operated 1217 Euclid St 4282004900 Medium Density Residential R3 Public parking lot 7 1 unit/1500 sf or 5 units (whichever less) 150 units/acre 7,500 52 No leases– parking is City operated 1217 14th St 4282003900 Medium Density Residential R3 Public parking lot 12 behind Petco 1 unit/1500 sf or 5 units (whichever less) 150 units/acre 22,500 52 No leases– parking is City operated 4282003901 (Blank)Main St between Ocean Park Blvd and Kinney St 42880099001 High Density Residential R3/R4 Public parking lots 9, 10, and 11 on Main St (excludes alleys) 1 unit/1500 sf or 5 units (whichever less) 150 units/acre 175,56816 7,388 605577 No leases– parking is City operated; but replacement parking will be necessary (Coastal Zone) 4288010900 42880109014 288014901 4288011900 4288011901 4288012902 4288013905 4288015901 1333 4th St 4291011909 Bayside Conservation BC Bank of America; Chase bank 2.25 FAR 150 units/acre 44,60952, 489 154181 Bank of America’s lease ends in 2026 and Chase Bank has requested to extend their lease to 2026 and terminate alongside the BofA lease. 4291011910 1324 5th St 4291011900 Neighborhood Village NV Public pParking lot 27 2.25 FAR 150 units/acre 53,30052, 470 184181 No leases– parking is City operated 4291011901 8.B.e Packet Pg. 370 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Address Parcel Nos. GP Designation Zoning Existing Use Existing Base Allowable Density or FAR Proposed Density with Program 2.E Land Area (sf) Unit Capacity with Program 2.E Other Info 4291011902 4291011903 4291011904 4291011905 4291011908 1318 4th St 4291012900 Bayside Conservation BC Parking Structure 3 2.25 FAR 150 units/acre 30,000 104 City Council authorized exclusive negotiation agreement on 1/22/2022 with EAH for development of affordable housing; Demolition began March 2022 4291012901 2500 Olympic 4268013919 Conservation Arts Center CAC Bergamot Arts Center1 1.0 FAR 150 units/acre 205,000 707 Property Management Agreement until April 2027. City has annual leases with 30 businesses (expiring 12/31) that will be renewed each year until redevelopmentInterim Ground Lease and ENA with Private Developer expires on 12/31/22 4268014900 Total Estimated Capacity 1,884880 1 The 205,000 sf land area accounts for half of the Bergamot Arts Center parcel being occupied by an existing leased R&D building which precludes housing development on this portion of the site 8.B.e Packet Pg. 371 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-23 Category 11 and 12- Religious Congregations and Parking Lots Surface parking lots located in the multi-unit residential zoning districts have the ability to accommodate housing. These include parking lots associated with religious congregations and parking lots associated with street-fronting commercial uses. Discussions with religious congregation leaders have indicated that there is a strong desire to develop affordable housing on the parking lots of sites owned by religious congregations. Program 4.B in this Housing Element would amend the Zoning Ordinance to allow housing projects on these religious congregation sites to be developed to unlimited density, no minimum parking requirements, and an additional 33 feet of building height, provided that 50% of the units are provided as affordable. However, based on discussions with affordable housing developers, it is unlikely that affordable housing projects will be built greater than 5 stories. Therefore, housing capacity of sites owned by religious congregations were analyzed assuming a height of 5 stories. Surface parking lots in residential zones have housing potential but their potential is limited by existing residential unit caps. The Housing Element includes Program 1.C which would amend the Zoning Ordinance to eliminate the maximum unit caps within these residentially-zone surface parking lots and to create special standards for housing projects on these sites. The capacity analysis applies the following factors to calculate realistic capacity of Category 11 and 12 sites:  Typical Density: Parking lots owned by religious congregations would be developed with affordable housing projects and as such, would be afforded new development standards that would give it increased height as compared to other sites in the residential zones. However, as stated above, such projects would likely be limited by the number of stories. Affordable housing developers have indicated that they will likely build no more than 5-6 stories due to construction costs and prevailing wages requirements for projects constructed at greater heights. Therefore, the capacity analysis assumes a maximum of 5 stories for parking lots associated with religious congregations. For surface parking lots, the capacity analysis assumes removal of the unit caps and applies the density factors of the underlying zones as well as the maximum building height.  Realistic capacity of Site: Application of the maximum parcel coverage permitted based on the underlying multi-unit zoning.  Land Use Controls and Site Improvements: Incorporation of the Zoning Ordinance’s requirements for unit size and unit mix requirements which could reduce maximum residential yield.  Infrastructure Availability and Environmental Constraints: No application of environmental constraints and infrastructure constraints, per the discussion in Attachment 3. 8.B.e Packet Pg. 372 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins))  Income levels: Some religious congregational leaders have indicated that there may be a need to provide some market rate units as part of housing redevelopment to ensure revenue. Therefore, these sites assume 50% of the total unit capacity could be accommodated at affordable low-income levels consistent with Program 4.B. With this methodology, Category 11 sites yielded an estimated housing capacity of 257 units and Category 12 sites yielded an estimated housing capacity of 94 96 units. Figure F-8 Example Capacity Calculation for Multifamily Parcel Site Attribute Zoning R2 Site Area (SF) 10,000 Typical Density Max # Stories 5 Density unlimited Realistic Capacity Parcel Coverage (Maximum % of site area) 0.45% Ground Floor Parcel Coverage Floor Area (GSF) 6,750 SF Land Use Controls Upper Story Parcel Coverage (% of ground floor parcel coverage) 90% Upper Story Floor Area [(6,750 SF*.90)*4 stories] = 24,300 SF Capacity Total Floor Area 31,050 SF Average GSF per Unit based on Unit Mix requirements 1,050 Max # of Units 30 All Remaining Sites – Categories 2, 3, 5, 6, 7, 8, 9, 10 The City of Santa Monica’s General Plan and Zoning Ordinance implements a Zoning Ordinance using floor area ratios (FAR) and heights to determine maximum development. The Housing Element includes Programs 1.F and 1.J, which would amend the Downtown Community Plan and Zoning Ordinance to establish new increased FARs and heights for housing projects.  Assumptions of Residential Probability vs Commercial  Development Trends – In the past decade, development in Santa Monica has trended towards new residential development rather than new commercial development (see graphic below). This is particularly true in the Downtown district, where housing projects are incentivized with greater FARs than commercial projects. Housing is in high demand in the southern California region, particularly in Santa Monica, which has seen a significant increase in development applications for residential and mixed use projects. This trend is expected to continue to increase during the timeframe of the Housing Element. The City allows standalone, multi-unit residential development as a use permitted by-right (without discretionary approvals) in most mixed-use, commercial, and industrial zones throughout the City. These zones also allow for a broad range of other nonresidential uses. For example, a review of project applications in the City revealed that approximately 15% of projects were commercial only while the 8.B.e Packet Pg. 373 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-25 overwhelming majority were residential or mixed-use with a large residential component. As such, the City developed assumptions for the realistic capacity for the likely mix of residential and non-residential (e.g., retail, office, hotel, employment) projects on commercially and mixed use zoned sites.  Market Conditions - The Housing Element will continue to incentivize commercial projects over residential projects across the City through Program 1.J, which will rezone the mixed-use and commercial zoning districts with higher maximum allowable FAR and height for housing projects. The FARs for housing projects will be at least 75% greater than the commercial FARs. Financial feasibility testing conducted by the City’s economic consultant indicates that with the new higher FARs and heights, housing projects will be more likely to occur than commercial projects. All the sites selected on the SSI will be rezoned with the new higher FARs and heights for housing projects. Therefore, it is highly likely that the sites will be redeveloped for residential rather than commercial. However, to be conservative,  Availability of Regulatory Incentives – The City has also most recently adopted regulatory incentives to encourage residential development, including adopting an Emergency Interim Ordinance on March 10, 2020, allowing 100% affordable housing projects and housing projects up to Tier 2 maximums that are subject to the protections of the Housing Accountability Act to be reviewed through a by-right administrative process. Program 1.A would make this streamlining provision permanent and expand the 4 7 7 8 4 10 19 17 23 15 18 44 2 4 3 1 3 6 2 2 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021# OF PROJECTSAPPLICATION YEAR Number of New Construction Commercial and Residential Projects by Application Year Residential Commercial 8.B.e Packet Pg. 374 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) applicability to other housing projects, including projects that are granted minor modifications.  Site Capacity Calculation To assess the housing capacity of the remaining Category 2-10 sites that have been identified for the SSI, the realistic capacity of the sites was assessed by applying the new rezoned heights and FAR for housing projects as listed in Programs 1.F and 1.J. The capacity analysis applies the following factors to calculate realistic capacity of sites within Category 2, 3,5, 6, 7, 8, 9, and 10:  Typical Density: The maximum allowable Tier 1 FARs for housing project (for both on- site and off-site affordable housing) is utilized for the site capacity analysis. This assumption is supported by past production trends which demonstrate that all residential developers will utilize the maximum FAR for residential and mixed-use projects, especially given high land cost and construction cost. Attachment 1 provides a list of approved and pending projects which show that almost all developers have proposed the maximum allowable FAR. Additionally, in the past (prior to the City’s 2017 adoption of the Downtown Community Plan), a couple of approved housing projects were processed as development agreements and therefore, proposed FARs exceeded the established maximum FARs in the Zoning Ordinance. For the purposes of this SSI analysis, Tier 2 FARs and Tier 3 FARs (which are greater than Tier 1) are not utilized since these are considered elective and require project developers to contribute community benefits.  Realistic capacity of Site: The capacity analysis assumes that 80% of the site area will be developed given setback and open space requirements based on a review of past housing projects.  Land Use Controls and Site Improvements: Incorporation of the Zoning Ordinance’s requirements for active ground floor use (for example retail) and unit mix requirements which could reduce maximum residential yield.  Commercial Likelihood: To account for the possibility that commercial use could be built, a 15% discount factor was applied to the capacity calculation. The 15% is based on the percentage of commercial projects vs residential projects that have occurred in the past 8 years. With this discount factor, the assumed capacity on the sites in the inventory is significantly lower than the actual housing development potential that is allowed on the sites per the Zoning Code and General Plan. For example, a 0.23 acre site that is zoned MUBL (Mixed Use Boulevard Low) with a max FAR of 2.25, has a maximum development potential of 22 units. However, this site is a mixed use-zoned site that allows 100% commercial projects, so to account for market feasibility and the potential for commercial development on the site, the inventory only counts 19 units on the parcel. 8.B.e Packet Pg. 375 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-27  Infrastructure Availability and Environmental Constraints: No application of environmental constraints and infrastructure constraints, per the discussion in Attachment 3. Site Capacity Calculation Step 1: Apply Max FAR to site area Maximum Building Floor Area Step 2: Apply Site Coverage Factor (80% buildable) Realistic Buildable Floor Area Step 4: Apply Unit Mix Requirement Residential Floor Area Step 3: Assume Ground Floor Commercial Max # of Units Step 5: Apply Commercial Probability Factor Realistic Number of Units 8.B.e Packet Pg. 376 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-28 With this methodology and under programs in this Housing Element, Category 2, 3, 5, 6, 7, 8, 9, and 10 sites yielded an estimated total housing capacity of 6,025 units Figure F-9.Example Capacity Calculation for Mixed Use and Commercial Parcel: 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) 8,000 SF Ground Floor Use Retail Commercial Floor Area (NSF) 6,960 SF Capacity Upper Floor Uses Residential Residential Floor Area (NSF) 15,540 SF Average NSF per Unit based on Unit Mix requirements 688 Max # of Units 22 units Commercial Probability 15% 19 units Max Density Capacity Max # units/acreage of site (22 19 units/0.23 acres) = 95 83 units/acre The unit capacity that resulted with this calculation was spot checked against the typical densities of housing projects that have occurred in the past 10 years which is shown in the table below. Figure F-10 Typical Densities of Housing Projects by Zoning since LUCE City Areas Zoning District Housing Current Tier 1 FARs Parcel Sizes of Housing Projects (SF) % of Max FAR or Density1 Typical Densities Units/acre Bergamot BTV 1.75 35,000 92% 77-110 MUC 1.50 20,000 –145,000 95-100% 103-107 CCS 1.50 -- -- -- CAC 1.0 -- -- -- Blvd MUBL 1.50 7,500-203,000 88-150% 58-129 MUB 1.50 7,500 82-135% 52-197 GC SMB 1.25 13,000 100-125% 79-108 GC Lincoln/ Pico 1.50 14,000-32,000 92-150% 63-114 NC 1.50 15,000-30,000 100-137% 97-113 NC (Main, Montana) 1.00 -- -- -- Industrial IC Not permitted -- -- -- Office Campus OC Not permitted -- -- -- Hospital HMU 1.50 -- -- -- Downtown LT 1.50 15,000-37,000 80-100% 87-192 NV 2.25 7,500-18,500 89-100% 116-349 BC 2.25 15,000 189% 160 8.B.e Packet Pg. 377 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-29 TA 2.25 7,500 – 108,000 100-163% 161-390 OT2 2.25 -- -- - WT 1.50 15,000 100% 122 Multi-family OF 1 unit/1500 sf 23,000-45,000 100% 41-80 OP2 1 unit/2000 sf 4,700-11,000 100% 22 OP3 1 unit/1500 sf 7,500-18,000 100% 29 OP4 1 unit/1250 sf 24,500 100% 35 R2 2,000 (or 4 total units)* 7,500-29,000 100% 22 R3 1,500 (or 5 total units)* 5,000-22,000 100% 29 R4 1,250 (or 6 total units)* 19,000 200% 74 Step 56: Assessing Appropriateness of Sites to Accommodate Lower Income levels For the City of Santa Monica, California Government Code Section 65583.2 states that a density of 30 units per acre is appropriate to enable lower income housing. In the City’s mixed-use and commercial districts, the Zoning Ordinance uses FAR rather than the density factor of units per acre. Therefore, to determine how many units per acre are possible on each SSI site, the number of units possible was first calculated based on the current Tier 1 FARs and new allowable FARs established in Programs 1.A and 1.J. The number of units was then translated into units/acre based on the parcel size of each site. Under current development standards and with the rezoning in Programs 1.F and 1.J, all the SSI sites that are zoned mixed-use or commercial can accommodate housing at greater densities than default density of 30 units per acre. Therefore, per HCD, all the mixed-use and commercial zoned sites are considered as having capacity for Low-Income units. Accommodating for Very Low- and Low-Income Housing The State uses the density allowed on a site as a “proxy” for determining whether a site can accommodate housing at lower-income levels.  Very Low- and Low-Income. State law establishes a “default density standard” of 30 units per acre for lower-income units in the City of Santa Monica. This means that if a site’s zoning allows for a density that is greater than 30 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households. Under current standards and with the rezoning in Programs 1.F and 1J, all the non-vacant, commercially zoned sites in the SSI can accommodate housing at greater densities than default density of 30 units. Therefore, per HCD, these sites can be identified as lower-income sites that have the capacity to accommodate lower-income units.  Moderate-income. Since all the identified SSI sites that are commercially zoned can accommodate lower- income units, the City has also determined that each of these sites can accommodate moderate-income housing since units affordable to lower-income households would also be affordable to moderate- income households. 8.B.e Packet Pg. 378 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-30 Step 67: Summary of Capacity to Accommodate the RHNA Without rezoning, the sites in the inventory can accommodate 7,596 units, resulting in a shortfall in total capacity which includes a shortfall in lower income capacity. While HCD requires that only candidate sites need to be rezoned to accommodate the shortfall, the HE includes programs to rezone entire districts, rather than individual sites. This approach is conservative and allows for the potential for candidate sites to be removed or sites to be added over the Housing Element cycle. With rezoning, the sites in the inventory can accommodate 13,600 units. All of the sites are non-vacant, and almost all are consolidated sites. The City will continue to administratively process lot tie agreements as part of the plan check process. After accounting for consolidation, only 4 sites identified in the SSI accommodate less than 15 units (inclusive of lower income). These sites are vacant parcels located in the R2/R3 zones which have a density limit of 4 to 5 units. Capacity to Accommodate the RHNA by Income Under Current Zoning Based on current FARs and densities in the City’s Zoning Ordinance, Bergamot Area Plan, and Downtown Community Plan, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate 6,0067,596 units, a shortfall of 3215% below the City’s RHNA of 8,895 units. This includes a shortfall of 1,109 units in all lower-income categories (ELI, VI, and LI) and the 1,003 units in the moderate income category. Figure F-7 11 Summary of Capacity Analysis – Under Current Zoning Standards Total Capacity Capacity for Affordable Units # Units Total Affordable Capacity ELI VLI LI Moderate Category 1 Approved 2,205 1,503 637 416 127 104 162 104 148104 148 104 Category 1 Pending 2,168 680 420 165 24 42 321 42 4142 41 42 Category 4 City Sites 788808 647808 162269 162269 162269 162- Category 11 Religious Sites 29 0 0 0 0 0 Category 12 Parking Lots 61 0 0 0 0 0 All Remaining Categories 1,950 2,593 1,950 2,593 488 648 488 648 488 648 488 648 ADUs 376 352 249 232 56 53 8 7 162 151 23 21 Total 7,596 6,006 4,064 4,053 964 1,009 1,247963 1,146 1,107 700 977 RHNA Targets 8,895 8,895 6,168 6,168 1,397 1,397 1,397 1,397 1,672 1,672 1,702 1,702 Shortfall (1,299)(2,889) (2,104)(2,115) (433)(388) (150)(434) (526)(565) (1,003)(725) -3215% Capacity to Accommodate the RHNA Shortfall of Sites by Income Under Proposed Rezoning Programs 1.F and 1.J would amend the Zoning Ordinance, LUCE, and associated specific and area plans to allow for increased FARs and heights in the mixed use and commercial districts in 8.B.e Packet Pg. 379 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-31 the City in order to incentivize greater housing production. Additionally, Program 4.A would 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. Under current zoning, the City has a shortfall of 1,109 lower income units. The City-owned sites can accommodate 1,880 lower income units, sufficient to meet this shortfall. To ensure compliance with Government Code section 65583.2, subdivisions (h) and (i), the HE includes Program 1K which requires that development on City-owned sites identified in the SSI must be at minimum 50% residential uses and flexibility to have 100% residential useFurthermore, Program 1.K would implement an Adequate Sites Program which would allow all sites designated for mixed-uses (except for NC Main and NC Montana) to develop 100 percent residential use and would require residential use to occupy at least 50 percent of the floor area in a mixed-use project. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. With the rezoning programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate at least 11,07013,600 units providing a 24 53 percent buffer above the City’s RHNA of 8,895 units as shown in Figure F-8. The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing. The land inventory includes capacity for 2,4442,521 extremely low, 2,3982,891 very low income, 2,5422,703 low income, and 1,7841,901 moderate income units. Figure F-9 provides a summary breakdown of the SSI by zoning and income levels. Figure F-8 12 Summary of Capacity Analysis – With New Development Standards Under HE Rezoning Programs Total Capacity Capacity for Affordable Units # Units Total Affordable Capacity ELI VLI LI Moderate Category 1 Approved 2,205 1,503 637 416 127 104 347 104 148104 15 104 Category 1 Pending 2,168 680 420 165 24 42 224 42 4142 131 42 Category 4 City Sites 1,880 1,884 1,880 1,884 627 628 627 628 627 628 - - Category 11 Religious Sites 257 257 130 129 32 32 32 32 32 32 34 32 Category 12 Parking Lots 96 105 9 53 - 13 - 13 9 13 - 13 All Remaining Categories 6,619 6,289 6,619 6,289 1,655 1,572 1,655 1,572 1,655 1,572 1,655 1,572 ADUs 376 352 249 232 56 53 8 7 162 151 23 21 Total 13,600 11,070 9,944 9,168 2,521 2,444 2,819 2,398 2,7032,542 1,9011,784 RHNA Targets 8,895 8,895 6,168 6,168 1,397 1,397 1,397 1,397 1,672 1,672 1,702 1,702 Buffer +4,705+2,175 +3,776+3,000 + 1,124 +1,047 + 1,495 +1,001 + 1,031+870 +199+82 2453% 8.B.e Packet Pg. 380 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-32 Figure F-8 13 Summary of SSI Sites Capacity by Zoning (excludes Category 1 Approved/Pending Projects) City Areas Zoning District # Units Capacity Lower Income Moderate Income Above Moderate Bergamot Area Plan BTV 156 39 39 78 CCS 25 6 6 13 MUC 888 223 217 448 CAC 707 707 - - Blvd GC 967 254 225 488 MUB 1,334 334 325 675 MUBL 2,368 604 574 1,190 NC 157 40 35 82 Downtown NV 381 233 48 100 BC 285 285 - - LT 270 72 63 135 Industrial IC 54 14 13 27 Office Campus OC 59 15 13 31 Multifamily R2 306 109 26 171 R3 655 604 8 43 R4 99 99 - - Total 8,852 3,674 1,626 3,552 City Areas Zoning District Land Area (sf) % of Total Land Area Count of Parcels Bergamot Area Plan BTV 38,548 0.9% 1 CCS 11,703 0.3% 1 MUC 359,465 8.0% 11 CAC 410,253 9.1% 2 Blvd GC 415,703 9.2% 44 MUB 491,050 10.9% 29 MUBL 969,554 21.6% 62 NC 151,351 3.4% 20 Downtown NV 250,989 5.6% 25 TA 237,531 5.3% 20 8.B.e Packet Pg. 381 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-33 LT 292,933 6.5% 31 BC 80,233 1.8% 4 OT 190,963 4.2% 1 WT 30,014 0.7% 4 Hospital HMU 6,242 0.14% 1 Industrial IC 19,662 0.4% 1 Multi-family OF 68,537 1.5% 2 OP2 32,299 0.7% 5 R2 175,001 3.9% 24 R3 199,919 4.4% 12 R4 40,091 0.9% 4 Office Campus OC 26,117 0.6% 4 Total 4,498,158 100.00% 308 8.B.e Packet Pg. 382 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-34 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 approximately 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 of 8,895 units is more than twice than the planned amount of units anticipated under City plans and zoning. 8.B.e Packet Pg. 383 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-35 Step 78: Assessment of Sites to Affirmatively Furthering Fair Housing This section analyzes the distribution of sites in the inventory by fair housing metrics and provides a comparison to the distribution of existing households in the City within each census tract. A disproportionately high number of units are within the mid-City and Downtown area, which reflects the City’s General Planning strategy of focusing new housing in areas served by transit, consistent with planning best practices and state guidelines for reducing greenhouse gas emission emissions. Census tracts in the mid-City and Downtown have a higher share of low-income units within it compared to other unit income categories. In contrast, a relatively low share of all units, including low-income units, are identified within the North of Montana and Northeast neighborhoods, which are discussed in Chapter 2 as being higher-resourced, whiter, and more wealthy. These areas are being underrepresented in the SSI given limited opportunity for high-density growth. Additional units are anticipated in these areas through lower-scale development such as Accessory Dwelling Units or “missing middle” housing, but are not reflected on the site inventory. The R2/R3/R4 zones also has a lower share of units allocated to it compared to its proportion of existing housing stock, but this reflects the city’s focus on preserving existing housing, particularly rent-controlled housing. Effects of Sites on Segregation and Integration The City’s suitable sites inventory was evaluated to determine how sites planned for future development could further affect patterns of segregation and integration relative to racial concentrations and income levels. As previously discussed in Chapter 2, the City is generally more homogenous than the other nearby cities in Los Angeles. Within Santa Monica, there are more predominant populations of Hispanic/Latino residents in the Pico Neighborhood while the remaining areas of the City are predominantly White. Most of the identified sites are in the Downtown and in Mid-City, which have predominantly White households. The table below shows that the census tracts with most of the available lower-income sites identified in the SSI are in areas with white predominance. About 11 percent of the lower-income capacity is identified in census tracts with a Hispanic/Latino majority. The distribution of low income and moderate unit capacities correspond generally to existing racial patterns. Therefore, the sites would not exacerbate ongoing patterns of segregation by race in the City. Figure F-14 Sites Distribution by Racial Predominance Racial Predominance White Hispanic Total City Existing % 78% 13% SSI Lower Income Units 89% 11% SSI Moderate Income Units 88% 12% SSI Above Moderate Unit 96% 4% 8.B.e Packet Pg. 384 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-36 Map F-2 Distribution of Sites by Racial Predominance 8.B.e Packet Pg. 385 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-37 Map F-3 Site Capacity Increases by Racial Predominance Relative to segregation based on household income, the sites are distributed across a number of census blocks with various median household income levels (Map F-3). The census tracts with most of the available lower-income SSI sites have lower median income levels. This is mostly due to the availability of land suitable for higher density development along the I-10 freeway such as the Downtown and Bergamot Plan areas. Development on the SSI identified sites in the inventory has the potential to add housing of all income levels, including low-income housing. There are 115 sites identified in the census tracts with more than 55% low- to moderate-income populations, which include the Downtown, Pico Neighborhood and the Bergamot Area. While development of low-income housing on these sites could moderately exacerbate ongoing patterns of segregation, it is very unlikely that all these sites would develop as low-income particularly given the higher land cost in the Downtown. Furthermore, these sites are located in areas that are the most accessible to the Metro E light-rail stations, jobs, and other resources including schools (Santa Monica College). Therefore, while the Sites Inventory does not actively improve conditions, the sites would not exacerbate ongoing patterns of segregation by race in the City. 8.B.e Packet Pg. 386 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-38 Figure F-15 Sites Distribution by Median Income Map F-3 4 Distribution of Sites by Median Household Income Median Income Less than $69K $69K to $81K $81K to $107 $107 to $136,500 > $136,500 Existing Citywide Households 21% 4% 42% 30% 3% SSI Lower Income Units 54% 8% 26% 12% 0% SSI Moderate Income Units 59% 11% 17% 13% 0% SSI Above Moderate Unit 65% 3% 14% 18% 0% 8.B.e Packet Pg. 387 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-39 Map F-5 Site Capacity Increases by Median Income Figure F-16 Sites Distribution by Lower Moderate Income Households Lower Moderate Income Households 0-25% 25.1-35% 35.1% to 45% 45.1% to 55% 55.1% + Existing Citywide Households 14% 13% 52% 4% 17% SSI Lower Income Units 2% 9% 35% 13% 41% SSI Moderate Income Units 2% 10% 28% 16% 43% SSI Above Moderate Unit 4% 14% 17% 6% 60% 8.B.e Packet Pg. 388 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-40 Map F-4 6 Distribution of Sites by Low to Moderate Income Households 8.B.e Packet Pg. 389 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-41 Map F-7 Site Capacity Increases by Low to Moderate Households Effects of Sites on Displacement Potential and Disproportionate Housing Needs Reflecting the geographic analysis above, the tracts designated as more stable or exclusive, which are primarily located in the North of Montana and Northeast neighborhoods, are underrepresented in the inventory. While not large in numbers, the sites inventory do show some unit capacity in these areas, representing a small step towards opening up these areas to new housing at all income levels and reducing gentrification and displacement pressure from other areas in the City. Additionally, the sites inventory show a greater proportion of lower income and moderate income capacity within areas that are classified as “advanced gentrification” or “at risk”. This has a greater potential to protect vulnerable residents from being displaced under changing market pressures and ensure that these areas do not become exclusive. The identified sites would not exacerbate disproportionate housing needs. As described in Chapter 2, the significant contributing factors to disproportionate housing needs in the City are: displacement due to economic pressures, high housing cost, lack of affordable accessible housing, and land/zoning laws that limit density. The sites would not contribute to these factors but rather would result in improved conditions since housing development on these sites would 8.B.e Packet Pg. 390 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-42 minimize displacement of existing rent controlled units,2 provide new housing choice and affordability to high opportunity areas, produce new inclusionary affordable units as part of the City’s Affordable Housing Production Program, and contribute to increased residential density. Figure F-16 Sites Distribution by Displacement Potential Displacement Typology Advanced Gentrification Stable Moderate At Risk Becoming Exclusive Stable Exclusive Existing Citywide Households 10% 17% 35% 17% 21% SSI Lower Income Units 25% 25% 31% 15% 3% SSI Moderate Income Units 29% 22% 37% 9% 3% SSI Above Moderate Unit 16% 48% 17% 4% 15% 2 With the exception of two sites, sites that have existing residential uses included in the SSI consist of approved/pending housing projects. The other two sites were included in the SSI because of identified developer interest. All remaining sites in the inventory are developed with commercial uses or surface parking. 8.B.e Packet Pg. 391 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-43 Map F-5 8 Distribution of Sites Relative toSites Capacity Increases by Displacement Potential 8.B.e Packet Pg. 392 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-44 Effects of Sites on Access to Opportunity As shown in the Figure F-9 below, the identified sites would increase housing opportunities throughout the City, furthering fair housing in areas of high resources and opportunity. The identified sites would have access to low-cost transportation, jobs, and neighborhood-serving commercial uses that serve residential. Additionally, almost all of the identified sites (with the exception of the approved/pending projects) are on properties that are developed with underutilized commercial buildings and/or parking lots and therefore, would generally, minimize displacement potential. With the proposed development standards in Program 1.J, the identified sites would all have sufficient densities to accommodate lower-income units. Additionally, the City’s Affordable Housing Production Program requires housing projects to include inclusionary, affordable units, thereby expanding housing opportunities for lower- income households. 8.B.e Packet Pg. 393 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-45 Figure F-6 9 Map of Sites within High Resource Areas In terms of environmentally healthy areas, the census tracts that represent the North of Montana and Northeast neighborhoods generally have a higher (more healthy) environmental index than the remaining areas of the City. Similar to the discussion above, these areas are underrepresented in the sites inventory as they have the least housing capacity. Figure F-17 Sites Distribution by Environmental Health Index Least Healthy Most Healthy Environmental Health Index 0 1 to 4 5 to 6 7 to 8 9 to 19 Existing Citywide Households 37% 34% 10% 16% 3% SSI Lower Income Units 27% 58% 11% 4% 0% SSI Moderate Income Units 15% 70% 11% 4% 0% 8.B.e Packet Pg. 394 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-46 SSI Above Moderate Unit 49% 31% 4% 16% 0% Map F-10 Sites Capacity Increases by Environmental Health Index 8.B.e Packet Pg. 395 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-47 Attachment 1 – Approved and Pending Housing Projects The table below provides a list of approved (not yet constructed) and housing projects pending review in the City of Santa Monica. All projects are located on non-vacant sites that are developed with existing buildings or surface parking lots. All housing projects with 4 or more units are required to meet the inclusionary requirements in the City’s Affordable Housing Production Program, Santa Monica Municipal Code Chapter 9.64, providing either on-site or off-site affordable housing units. These affordable housing units (Extremely Low Income, Very Low Income, Low Income, and Moderate) are required to be deed restricted for a term of no less than 55 years. Table 1 - Approved and Pending Housing Projects as Broken Down by Affordability APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 12/7/2010 10FIM002 2 Unit Multifamily 1021 Grant Street market rate 2 Approved R2 6/1/2015 15ARB-0038 3-Unit Condos 610 California Ave market rate 3 Approved R2 5/11/2016 05TM-009 15-Unit Condominium 1211 12th St market rate 9 Approved R3 5/11/2016 05TM-009 15-Unit Condominium 1211 12th St VLI 4 Approved R3 6/1/2016 16ENT-0011 5-Unit Condos 1840 17th St LI 1 Approved R2 6/1/2016 16ENT-0011 5-Unit Condos 1840 17th St market rate 4 Approved R2 7/13/2016 16ENT-0072 3-Unit Condos 1422 20th St market rate 3 Approved R2 7/13/2016 16ENT-0071 3-Unit Condos 1420 20th St market rate 3 Approved R2 6/21/2017 16ENT-0041 3-Unit Townhomes 1121 22nd St market rate 3 Approved R2 6/21/2017 17ENT-0027 3-Unit Condos 1649 Centinela Ave market rate 3 Approved R2 10/18/2017 15ENT-0266 Mixed Use 1430-1444 Lincoln Blvd market rate 100 Approved MUB 10/18/2017 17ENT-0105 3-Unit Condos 1900 20th St market rate 3 Approved R2 11/28/2017 16ENT-0143 Mixed Use 1313-1325 6th St market rate 64 Approved NV 12/6/2017 16ENT-0098 Mixed Use (Upscale furniture building) 1437-1443 Lincoln Blvd LI 6 Approved MUB 12/6/2017 16ENT-0115 Mixed Use DRP 601-611 Wilshire Blvd market rate 37 Approved MUB 12/6/2017 16ENT-0115 Mixed Use DRP 601-611 Wilshire Blvd ELI 3 Approved MUB 8.B.e Packet Pg. 396 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-48 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 12/6/2017 16ENT-0098 Mixed Use (Upscale furniture building) 1437-1443 Lincoln Blvd market rate 34 Approved MUB 1/1/2018 17ENT-0286 3-Unit Condos 2512 7th St market rate 3 Approved OP2 2/7/2018 16ENT-0102 Mixed Use 1318 Lincoln Blvd market rate 39 Approved MUB 2/7/2018 16ENT-0102 Mixed Use 1318 Lincoln Blvd ELI 4 Approved MUB 4/4/2018 11DEV014 Mixed-Use DRP 1650-1660 Lincoln Blvd ELI 8 Approved MUB 4/4/2018 11DEV014 Mixed-Use DRP 1650-1660 Lincoln Blvd market rate 90 Approved MUB 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica Blvd VLI 5 Approved MUBL 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica Blvd LI 2 Approved MUBL 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica Blvd market rate 44 Approved MUBL 7/5/2018 18ENT-0199 Mixed Use (Fritto misto) 601-609 Colorado Ave market rate 104 Approved TA 7/5/2018 18ENT-0199 Mixed Use (Fritto misto) 601-609 Colorado Ave Moderate 36 Approved TA 7/27/2018 18ENT-0077 Condos 1443 18th St market rate 11 Approved MUBL 8/1/2018 17ARB-0043 Apartments 1754 10th St market rate 3 Approved R2 10/12/2018 18ARB-0221 100% Affordable Housing 1342 Berkeley ELI 8 Approved R2 11/7/2018 18ENT-0005 Mixed Use (bowling alley) 216-248 Pico Blvd VLI 9 Approved MUBL 11/7/2018 18ENT-0005 Mixed Use (bowling alley) 216-248 Pico Blvd market rate 93 Approved MUBL 11/7/2018 18ENT-0005 Mixed Use (bowling alley) 216-248 Pico Blvd LI 3 Approved MUBL 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St LI 7 Approved TA 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St market rate 14 Approved TA 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St SRO 38 Approved TA 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St SRO 80 Approved NV 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St market rate 20 Approved NV 8.B.e Packet Pg. 397 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-49 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St LI 14 Approved NV 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St ELI 6 Approved NV 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St ELI 4 Approved TA 3/6/2019 18ENT-0182 Mixed Use 1618 Stanford market rate 43 Approved MUC 3/6/2019 18ENT-0182 Mixed Use 1618 Stanford ELI 4 Approved MUC 4/18/2019 223 Auto Dealership 1802 Santa Monica Blvd market rate 0 Approved GC 4/18/2019 17ENT-0297 Mixed Use 1707 Cloverfield market rate 58 Approved BTV 4/18/2019 17ENT-0297 Mixed Use 1707 Cloverfield ELI 5 Approved BTV 4/23/2019 15ENT-0300 Mixed Use Project 1828 Ocean Ave VLI 16 Approved OF 4/23/2019 15ENT-0297 Mixed Use Project 1921 Ocean Front Walk market rate 22 Approved OF 4/23/2019 15ENT-0300 Mixed Use Project 1828 Ocean Ave market rate 67 Approved OF 5/15/2019 15ENT-0310 21-Unit Condominium/2020 Virginia 2002-2008 21st St market rate 19 Approved R2 6/14/2019 19ENT-0054 3-Unit Condos 1802 Delaware Ave market rate 3 Approved R2 7/9/2019 19ENT-0130 3-Unit Condos 122 Strand St market rate 3 Approved OP3 9/4/2019 17ENT-0298 Mixed Use 2906-2918 Santa Monica Blvd market rate 42 Approved MUBL 9/4/2019 17ENT-0298 Mixed Use 2906-2918 Santa Monica Blvd ELI 4 Approved MUBL 9/6/2019 19ENT-0128 Addition of 4 units 1410 5th St market rate 4 Approved TA 10/2/2019 19ENT-0258 3-Unit Condos 949 10th St market rate 3 Approved R2 10/4/2019 18ENT-0129 Mixed Use 100% affordable housing 711 Colorado Ave ELI 17 Approved TA 10/4/2019 18ENT-0129 Mixed Use 100% affordable housing 711 Colorado Ave Moderate 39 Approved TA 10/21/2019 18ENT-0211 Mixed Use 1425-1427 5th St market rate 92 Approved TA 8.B.e Packet Pg. 398 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-50 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 11/7/2019 18ENT-0244 Mixed Use 3223 Wilshire Blvd market rate 49 Approved MUB 11/7/2019 18ENT-0244 Mixed Use 3223 Wilshire Blvd ELI 4 Approved MUB 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St Moderate 8 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St ELI 5 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St VLI 5 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St LI 7 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St market rate 75 Approved TA 11/14/2019 186 Commercial building 3280 Lincoln Blvd market rate 1 Approved GC 12/4/2019 16ENT-0118 Mixed Use 3030 Nebraska Ave ELI 9 Approved MUC 12/4/2019 16ENT-0118 Mixed Use 3030 Nebraska Ave market rate 174 Approved MUC 12/9/2019 19ENT-0425 3-Unit Condos 918 5th St market rate 3 Approved R2 12/19/2019 19ENT-0256 Mixed Office/SFR 1348 10th St market rate 1 Approved GC 1/15/2020 19ENT-0267 Condos 1432 17th St market rate 6 Approved R2 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St market rate 32 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St LI 14 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St SRO 79 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St ELI 9 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave SRO 35 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave market rate 14 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave LI 6 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave ELI 4 Approved TA 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St market rate 8 Approved NV 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St SRO 35 Approved NV 8.B.e Packet Pg. 399 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-51 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St Moderate 3 Approved NV 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St LI 6 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St ELI 3 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St market rate 35 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St SRO 8 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St LI 6 Approved NV 4/4/2020 20ENT-0020 100% Affordable Housing 1819 Pico Blvd LI 47 Approved NC 4/4/2020 20ENT-0020 100% Affordable Housing 1819 Pico Blvd market rate 1 Approved NC 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St VLI 10 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St Moderate 16 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St LI 14 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St ELI 10 Approved TA 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St Moderate 13 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St LI 10 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St VLI 7 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St ELI 7 Approved NV 4/15/2020 20BLD-1044 New Duplex 2409 28th St market rate 2 Approved R2 4/22/2020 18ENT-0229 Mixed Use (Performance Bicycles) 501 Broadway market rate 75 Approved TA 4/22/2020 18ENT-0229 Mixed Use (Performance Bicycles) 501 Broadway VLI 19 Approved TA 4/30/2020 19ENT-0085 Mixed Use 1448 7th St Moderate 1 Approved NV 4/30/2020 19ENT-0085 Mixed Use 1448 7th St LI 1 Approved NV 4/30/2020 19ENT-0085 Mixed Use 1448 7th St market rate 6 Approved NV 5/20/2020 20ENT-0063 3-Unit Condos 2425 20th St market rate 3 Approved R2 8.B.e Packet Pg. 400 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-52 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 5/30/2020 20ENT-0045 5-Unit Condos 1949 17th St LI 1 Approved R2 5/30/2020 20ENT-0045 5-Unit Condos 1949 17th St market rate 4 Approved R2 6/15/2020 20ARB-0138 duplex 2714 Highland market rate 2 Approved OP2 6/17/2020 20ENT-0073 3-Unit Condos 817 16th St market rate 3 Approved R2 7/20/2020 20ENT-0019 3-Unit Condos adjacent to Landmark 2501 2nd St market rate 3 Approved OP2 8/24/2020 20ENT-0079 100% Affordable Housing 1413 Michigan Ave VLI 57 Approved NC 8/24/2020 20ENT-0079 100% Affordable Housing 1413 Michigan Ave market rate 1 Approved NC 9/13/2020 11DEV-003 Miramar Hotel Project DA 1133 Ocean Ave market rate 60 Approved OT - ELS 10/21/2020 20ENT-0164 Condos 1510 Franklin St market rate 3 Approved R2 11/16/2020 20ENT-0011 Mixed Use 1512 Euclid St market rate 8 Approved MUBL 11/16/2020 20ENT-0011 Mixed Use 1512 Euclid St LI 2 Approved MUBL 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd market rate 24 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd VLI 1 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd LI 1 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd Moderate 3 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd ELI 1 Approved LT 12/14/2020 20ENT-0280 2-Unit Condos 1514 Princeton market rate 2 Approved R2 12/14/2020 18ENT-0243 remodel to 5 of 6 live/work condo 1643 12th St market rate 0 Approved IC 12/22/2020 20ARB-0213 Triplex addition to SFR 1902 Euclid St market rate 3 Approved R2 1/19/2021 20ENT-0238 100% affordable housing for Miramar 1127-1129 2nd St VLI 21 Approved WT 1/19/2021 20ENT-0238 100% affordable housing for Miramar 1127-1129 2nd St ELI 6 Approved WT 1/19/2021 20ENT-0238 100% affordable housing for Miramar 1127-1129 2nd St LI 15 Approved WT 1/20/2021 19ENT-0235 3-Unit Condos on Landmark property 1527 17th St market rate 3 Approved R2 8.B.e Packet Pg. 401 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-53 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 2/23/2021 20ENT-0293 6 unit condos 1319 Centinela Ave market rate 6 Approved R2 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway market rate 206 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway ELI 17 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway VLI 17 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway LI 26 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway Moderate 29 Approved TA 2/28/2013 13DEV004 Hotel/Mixed Use DA (Ocean Avenue Project) 101-129 Santa Monica Blvd market rate 82 Pending OT - ELS 2/28/2013 13DEV004 Hotel/Mixed Use DA (Ocean Avenue Project) 101-129 Santa Monica Blvd VLI 18 Pending OT - ELS 2/11/2021 21ENT-0035 Mixed-Use 1101 Wilshire Blvd VLI 11 Pending MUB 2/11/2021 21ENT-0035 Mixed-Use 1101 Wilshire Blvd market rate 82 Pending MUB 1/8/2013 13DEV001 Mixed Use 1431 Colorado Ave market rate 42 Pending MUBL 1/8/2013 13DEV001 Mixed Use 1431 Colorado Ave LI 8 Pending MUBL 5/22/2018 18ENT-0136 Mixed Use 1437 7th St VLI 13 Pending NV 5/22/2018 18ENT-0136 Mixed Use 1437 7th St market rate 52 Pending NV 4/13/2021 21ENT-0091 Mixed Use 1524 7th St affordable housing** 20 Pending TA 4/13/2021 21ENT-0091 Mixed Use 1524 7th St market rate 80 Pending TA 8/6/2020 20ENT-0196 Apartments 1546 9th St market rate 9 Pending R3 8/4/2016 16ENT-0112 3-Unit Condos 1665 Appian Way market rate 3 Pending OF 3/31/2020 20BLD-1218 New addition of 2 units 1958 20th St market rate 2 Pending R2 4/13/2021 21ENT-0093 Mixed Use 3025 Olympic Blvd market rate 307 Pending MUC 4/13/2021 21ENT-0093 Mixed Use 3025 Olympic Blvd affordable housing** 38 Pending MUC 11/27/2018 18ENT-0362 Mixed Use 525 Colorado Ave market rate 30 Pending TA 11/27/2018 18ENT-0362 Mixed Use 525 Colorado Ave VLI 10 Pending TA 1/8/2013 13DEV002 Mixed Use 603 Arizona Ave market rate 39 Pending NV 1/8/2013 13DEV002 Mixed Use 603 Arizona Ave VLI 8 Pending NV 8.B.e Packet Pg. 402 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-54 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 10/2/2020 20ENT-0234 3-Unit Condos 734 12th St market rate 3 Pending NC 9/12/2019 19ENT-0340 Mixed Use Building 825 Santa Monica Blvd market rate 41 Pending GC 9/12/2019 19ENT-0340 Mixed Use Building 825 Santa Monica Blvd VLI 7 Pending GC * Affordable units are required to be deed restricted for a term of at least 55 years. **Affordability level to be determined 8.B.e Packet Pg. 403 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-55 Table 2 - Approved and Pending Projects by Age of Building, Improvements Land Ratio (ILR), Existing Use Consolid ated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR A 18ENT-0244 4266001046 MUB 6522 parking lot for Aah's 0 0.000 A 18ENT-0244 3223 WILSHIRE BLVD 4266001045 MUB 13063 one-story Aah's retail store 1955 0.108 AA 1431 LINCOLN BLVD 4282027019 LT 7512 one-story comic book store 1983 0.130 AA 20ENT-0163 1427 LINCOLN BLVD 4282027020 LT 7501 one-story comic book store 1956 0.024 AC 22ENT-0037 1527 LINCOLN BLVD 4282028019 LT 7494 former tile store; vacant retail building 1945 0.310 AC 22ENT-0037 1533 LINCOLN BLVD 4282028018 LT 7510 former tile store; vacant retail building 1952 0.429 AM 4289019022 MUBL 5601 vacant one story bowling alley 0 0.000 AM 216 PICO BLVD 4289019023 MUBL 5613 vacant one story bowling alley 1962 0.057 AM 228 PICO BLVD 4289019021 MUBL 5621 vacant one story bowling alley 0 0.000 AM 248 PICO BLVD 4289019017 MUBL 5590 vacant one story bowling alley 0 0.000 AM 254 PICO BLVD 4289019016 MUBL 5611 vacant one story bowling alley 0 0.000 AM 21ENT-0219 234 PICO BLVD 4289019019 MUBL 28008 vacant one story bowling alley 1959 0.096 AO 19ENT-0041 1342 5TH ST 4291011019 NV 7509 parking lot 0 0.000 AO 19ENT-0041 1342 5TH ST 4291011020 NV 7485 parking lot 0 0.000 AR 19ENT-0039 1445 5TH ST 4291019016 TA 7498 vacant one-story multitenant retail building 1946 0.016 AR 19ENT-0039 1445 5TH ST 4291019017 TA 7511 parking lot next to vacant retail 0 0.002 AT (blank) 4291021009 LT 3751 parking lot 0 0.000 AT 1438 LINCOLN BLVD 4291021008 LT 3752 parking lot 0 0.000 AT 1444 LINCOLN BLVD 4291021010 LT 7491 parking lot 0 0.000 AT 15ENT-0266 1430 LINCOLN BLVD 4291021006 LT 7507 parking lot 0 0.000 AT 15ENT-0266 1432 LINCOLN BLVD 4291021007 LT 7492 parking lot 0 0.000 AU 1500 LINCOLN BLVD 4291022003 LT 7500 one-story Von's with parking lot 0 0.003 AU 1500 LINCOLN BLVD 4291022025 LT 22450 one-story Von's with parking lot 0 0.003 AU 1518 LINCOLN BLVD 4291022004 LT 7500 one-story Von's with parking lot 0 0.003 AU 1526 LINCOLN BLVD 4291022005 LT 7500 one-story Von's with parking lot 0 0.003 AU 1534 LINCOLN BLVD 4291022006 LT 7500 one-story Von's with parking lot 0 0.003 AU 20ENT-0241 710 BROADWAY 4291022026 TA 52450 one-story Von's with parking lot 1995 0.179 AX 22ENT-0011 1553 4TH ST 4291025028 TA 7474 Vacant bank site across DT station 0 0.001 AX 22ENT-0011 1555 4TH ST 4291025012 TA 7497 Vacant bank site across DT station 1973 0.013 AY 20ENT-0238 1127 2ND ST 4292021010 WT 7517 parking lot 0 0.003 8.B.e Packet Pg. 404 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-56 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR AY 20ENT-0238 1129 2ND ST 4292021009 WT 7490 parking lot 0 0.003 BG 22ENT-0006 1152 21ST ST 4276007021 MUB 3491 rear parking lot for NOMA sushi and Veggie grill (2025 wilshire) 0 0.019 BG 22ENT-0006 2025 WILSHIRE BLVD 4276007027 MUB 14987 one story Veggie grill 1969 0.096 BL 1115 WILSHIRE BLVD REAR 4281020029 MUB 13949 rear parking lot 1927 0.181 BL 21ENT-0035 1101 WILSHIRE BLVD 4281020012 MUB 8559 one-story JP bar 1922 0.191 BN 1819 SANTA MONICA BLVD 4276029011 GC 14986 Honda auto inventory lot 0 0.000 BN 21ENT-0227 1350 19TH ST 4276029010 GC 7495 Honda auto inventory lot 0 0.001 BN 21ENT-0229 1342 19TH ST 4276029009 R2 8991 Honda auto inventory lot 0 0.001 BO 2911 SANTA MONICA BLVD 4267011022 MUBL 6501 one story retail building 1926 0.200 BO 16ADM-0050 1347 YALE ST 4267011021 MUBL 3266 one-story retail building 1926 0.248 BO 16ADM-0050 1349 YALE ST 4267011020 MUBL 9368 one story multitenant retail building, two story apartment building w parking lot 1923 0.111 BP 1543 LINCOLN BLVD 4282028010 LT 7497 one story vacant auto repair 1947 0.128 BP 1547 LINCOLN BLVD 4282028009 LT 7499 one story vacant auto repair 1999 0.435 BP 22ENT-0037 1537 LINCOLN BLVD 4282028011 LT 7496 one story vacant auto repair 1945 0.245 BS 15ENT-0310 2002 21ST ST 4274026001 R2 7533 one-story apartments 0 0.101 BS 15ENT-0310 2008 21ST ST 4274026003 R2 7130 one-story apartments 0 0.107 BT 19ENT-0328 1840 14TH ST 4283030018 NC 7524 100% affordable housing under construction 1962 0.258 BT 19ENT-0328 1844 14TH ST 4283030017 NC 7485 100% affordable housing under construction 1922 0.496 BT 19ENT-0328 1848 14TH ST 4283030016 NC 7525 100% affordable housing under construction 1968 0.003 BU 19ENT-0042 1415 5TH ST 4291019021 TA 7494 two story multitenant retail building 1980 0.000 BU 19ENT-0042 1423 5TH ST 4291019020 TA 7525 two story multitenant retail building 1966 0.000 BV 18ENT-0210 1543 7TH ST 4291022014 TA 7500 parking lot 1990 1.725 BV 18ENT-0210 1547 7TH ST 4291022013 TA 7500 parking lot 0 0.000 BW 1547 6TH ST 4291023011 TA 7505 one-story multi-tenant building, restaurant, office 1986 0.000 BW 18ENT-0199 609 COLORADO AVE 4291023010 TA 14982 one-story multi-tenant building, restaurant, office 1984 0.167 BX 16ENT-0115 601 WILSHIRE BLVD 4292005029 WT 10010 vacant one and two story buildings 1977 0.071 BX 16ENT-0115 611 WILSHIRE BLVD 4292005026 WT 4997 vacant one and two story buildings 1922 0.143 BY 11DEV014 1650 LINCOLN BLVD 4290002008 LT 16220 one-story retail, boxing fitness building 1954 0.000 BY 11DEV014 1660 LINCOLN BLVD 4290002006 LT 7570 one-story retail, boxing fitness building 1954 0.000 BZ 16ENT-0098 1437 LINCOLN BLVD 4282027018 LT 7485 one-story retail building 1949 0.000 BZ 16ENT-0098 1443 LINCOLN BLVD 4282027028 LT 7510 one-story retail 1959 0.000 8.B.e Packet Pg. 405 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-57 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR C 22ENT-0007 2501 WILSHIRE BLVD 4276001026 MUB 14319 one-story commercial building with multiple retailers; corner parcel; with rear residential parking lot 1951 0.138 C 22ENT-0007 2515 WILSHIRE BLVD 4276001025 MUB 6164 one-story multi-tenant commercial building 1941 0.486 C 22ENT-0007 2525 WILSHIRE BLVD 4276001027 MUB 10347 one-story commercial building, Starbucks, Urgent Care, Postal Store; common ownership; corner parcel with rear residential parking 1970 0.435 CA 16ENT-0143 1313 6TH ST 4291009021 NV 15010 parking lot 0 0.000 CA 18ENT-0283 1323 5TH ST 4291010029 NV 7512 parking lot 0 0.000 CH 22ENT-0014 1902 WILSHIRE BLVD 4276013020 MUB 4989 one story retail/restaurant building (Thai dishes, salon, medical office) 1939 0.328 CH 22ENT-0014 1908 WILSHIRE BLVD 4276013030 MUB 24993 one-story retail/restaurant building (Thai dishes, salon, medical office) 1925 0.201 CI 21ENT-0228 1921 WILSHIRE BLVD 4276008014 MUB 15015 one-story retail building (GAP) 1975 0.406 CI 21ENT-0228 1933 WILSHIRE BLVD 4276008015 MUB 10520 one-story retail building (GAP) 1958 0.333 E 20ENT-0311 2906 SANTA MONICA BLVD 4267018026 MUBL 21314 vacant two story office 1969 0.792 E 20ENT-0311 2918 SANTA MONICA BLVD 4267018003 MUBL 7021 vacant parking lot 1965 0.117 P 21ENT-0226 1347 18TH ST 4276029026 GC 7512 Honda dealership with surface inventory 1969 0.001 P 21ENT-0226 1801 SANTA MONICA BLVD 4276029048 GC 14984 Honda dealership with surface inventory 1953 0.018 S 825 SANTA MONICA BLVD 4282010012 GC 7505 Toyota dealership 0 0.000 S 21ENT-0261 825 SANTA MONICA BLVD 4282010013 GC 7491 Toyota dealership 1951 0.010 S 21ENT-0261 825 SANTA MONICA BLVD 4282010014 GC 7502 Toyota dealership 1951 0.002 05TM-009 1211 12TH ST 4282005053 R3 15008 one story apartment buildings 0 0.000 09FIM003 1434 14TH ST 4282022027 R3 7500 (blank) 1925 0.221 10FIM002 1021 GRANT ST 4284015017 R2 6491 (blank) 1928 0.421 11DEV-003 1133 OCEAN AVE 4292028001 OT 190963 Miramar Hotel 1938 0.532 13DEV001 1431 COLORADO AVE 4282034009 MUBL 22485 one-story marble store 1923 0.009 13DEV004 129 SANTA MONICA BLVD 4291014024 BC 30000 parking lot 1871 0.019 15ARB-0038 610 CALIFORNIA AVE 4292005022 R2 5002 (blank) 1912 0.209 15ENT-0297 4289025005 OF 23222 vacant parking lot next to Casa del mar hotel 0 0.000 15ENT-0300 4290020045 OF 45314 parking lot 0 0.002 16ENT-0011 1840 17TH ST 4283032008 R2 7490 (blank) 1955 0.250 16ENT-0041 1121 22ND ST 4276005022 R2 6114 (blank) 1924 0.029 16ENT-0060 (blank) 4275006026 HMU 6242 parking lot owned by Saint John's 0 0.003 16ENT-0102 1318 LINCOLN BLVD 4291008025 LT 15003 parking lot 0 0.000 8.B.e Packet Pg. 406 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-58 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR 16ENT-0112 1665 APPIAN WAY 4290018018 R3 4430 residential 1914 0.375 16ENT-0118 (blank) 4268010017 MUC 64297 one-story light industrial/creative office 0 0.002 16ENT-0205 2102 5TH ST 4289010006 OP2 5661 (blank) 1911 0.024 17ARB-0043 1754 10TH ST 4283018002 R2 7511 (blank) 1922 0.250 17ENT-0027 1649 CENTINELA AVE 4268006016 R2 6313 single family dwelling 1948 0.250 17ENT-0048 436 PIER AVE 4287027065 OP2 7480 (blank) 1911 0.250 17ENT-0105 1900 20TH ST 4274019056 R2 7575 single family dwelling 0 0.000 17ENT-0286 4287003017 OP2 7973 (blank) 0 0.000 17ENT-0297 1707 CLOVERFIELD BLVD 4268014013 BTV 76562 parking lot of Extra Space sotrage 1955 0.658 18ARB-0221 1342 BERKELEY ST 4267012009 R2 7858 Vacant lot 0 0.000 18ENT-0077 1443 18TH ST 4275010016 MUBL 7500 Vacant lot 1957 0.004 18ENT-0129 711 COLORADO AVE 4291022012 TA 7500 construction staging site 0 0.000 18ENT-0136 1437 7TH ST 4291021029 NV 14991 three story office building 1983 1.223 18ENT-0182 1618 STANFORD ST 4268002005 MUC 20016 one story office building 1950 0.201 18ENT-0200 1238 7TH ST 4291006006 NV 7500 one-story office 1912 0.001 18ENT-0206 1557 7TH ST 4291022021 TA 7500 one story brick office building 1959 0.028 18ENT-0211 1427 5TH ST 4291019019 TA 15007 one-story vacant retail building 1954 0.000 18ENT-0212 1514 7TH ST 4291023002 TA 7504 construction staging parking site 0 0.000 18ENT-0229 501 BROADWAY 4291019027 TA 15007 one-story vacant retailer (Black tux) 0 0.000 18ENT-0362 525 COLORADO AVE 4291024014 TA 7483 one-story creative office 1960 0.000 19ENT-0039 1437 5TH ST 4291019018 TA 7484 parking lot 0 0.000 19ENT-0040 1437 6TH ST 4291020016 NV 7497 one story residence 0 0.000 19ENT-0235 1527 17TH ST 4275012020 R2 7500 single dwelling unit 1923 0.053 19ENT-0258 949 10TH ST 4281025014 R2 7484 (blank) 1916 0.250 19ENT-0267 1432 17TH ST 4282019007 R2 7504 (blank) 1959 0.083 19ENT-0425 918 5TH ST 4292015004 R2 7520 (blank) 1910 0.250 20ARB-0138 2714 HIGHLAND AVE 4287019012 OP2 4708 (blank) 1912 0.273 20ARB-0213 1902 EUCLID ST 4283028010 R2 7499 (blank) 1940 0.228 20BLD-1044 2409 28TH ST 4270004017 R2 9005 (blank) 1937 0.125 20BLD-1218 1958 20TH ST 4274019001 R2 7609 (blank) 0 0.133 20ENT-0011 1512 EUCLID ST 4282032003 MUBL 7500 vacant single family home 0 0.250 8.B.e Packet Pg. 407 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-59 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR 20ENT-0019 2501 2ND ST 4287010011 OP2 6478 (blank) 0 0.077 20ENT-0020 1819 PICO BLVD 4274017019 NC 13510 parking lot for religious institution 1950 0.383 20ENT-0045 1949 17TH ST 4274015020 R2 7747 Vacant lot 0 0.000 20ENT-0063 2425 20TH ST 4273019001 R2 6746 one story single family unit 1928 0.331 20ENT-0073 817 16TH ST 4281001021 R2 7481 one story single family dwelling 0 0.403 20ENT-0079 1413 MICHIGAN AVE 4283013024 NC 17992 Vacant lot 1905 0.069 20ENT-0164 1510 FRANKLIN ST 4267027057 R2 8118 two story single family unit 1924 0.310 20ENT-0234 734 12TH ST 4280025015 NC 4802 one story single family dwelling 1926 0.250 20ENT-0280 1514 PRINCETON ST 4267022010 R2 4999 one story single family dwelling 1940 0.250 20ENT-0293 1319 CENTINELA AVE 4267014026 R2 9274 two story single family unit 1929 0.488 21ENT-0027 1448 7TH ST 4291020008 NV 7498 two story apartment buildings w parking lot 1952 0.067 21ENT-0143 1546 9TH ST 4282028007 R3 7503 one story single family unit 1909 0.250 22ENT-0002 1302 6TH ST 4291010027 NV 18521 two story office 1978 0.129 22ENT-0012 2537 LINCOLN BLVD 4284008016 GC 19239 closed car wash 1965 0.167 22ENT-0013 2601 LINCOLN BLVD 4285001030 MUBL 203990 one story Gelsons shopping center; multiple tenants 1956 0.349 22ENT-0047 1333 7TH ST 4291008018 NV 7510 small site; single dental tenant; long standing owner/tenant 1978 1.333 8.B.e Packet Pg. 408 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-60 Attachment 2 - FAR and Size of Sites for Past and Current Housing Projects HCD states that a parcel smaller than 0.5 acre (21,780 sf) is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible. The City of Santa Monica is a small, compact city with parcel sizes that range across the City. Parcels in the Bergamot Plan area, Office Campus districts, and Industrial Conservation zones are generally larger (more than 30,000 sf). On the main commercial corridors, sites range between 10,000 sf to 15,000 sf. However, in the Downtown area, parcels are as small as 7,500 sf. As shown in the Table below, past and current multifamily housing projects (including 100% affordable housing projects) on mixed use and commercially zoned sites that are 15,000 sf are common. Generally, only in the Downtown have multi-unit housing projects occurred on sites less than 7,500 sf. As shown in the table, past and current housing projects in these commercial and mixed use zones generally propose the maximum FAR or greater (through a development agreement). Therefore, the below development trends for housing projects demonstrate that development of housing affordable to lower income households on smaller commercial and mixed use sites within Santa Monica is typical, realistic, and feasible. PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 20ENT-0238 100% Affordable Housing 1127-1129 2nd St WT 14.984 2.75 2.75 100% 5 - 42 42 122 18ENT-0200 100% Affordable Housing 1238 7th St NV 7.486 3.50 3.50 100% 6 - 37 37 215 18ENT-0212 100% Affordable 1514 7th St TA 7.493 4.00 4.00 100% 8 - 50 50 291 18ENT-0357 100% Affordable 1445-1453 10th St MUBL 13.495 2.00 2.00 100% 4 1 39 40 129 18ENT-0105 100% Affordable 1820-1826 14th St NC 15 1.75 1.75 100% 3 - 39 39 113 19ENT-0328 100% Affordable 1834-1848 14th St NC 30.06 1.75 1.75 100% 4 1 72 73 106 12AA-002 100% Affordable Housing 520 Colorado Ave TA 6.26 1.90 2.00 95% 5 - 34 34 237 18ENT-0129 100% Affordable 711 Colorado Ave TA 7.48 4.00 4.00 100% 7 - 56 56 326 19ENT-0014 100% Affordable 2120 Lincoln Blvd GC 14.16 2.00 2.00 100% 4 1 36 37 114 07AA-007 100% Affordable 1447 Lincoln Blvd LT 23 1.8 (1.3 +0.5) 1.80 100% 5 - 97 97 188 8.B.e Packet Pg. 409 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-61 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 15ENT-0306 100% Affordable 1626 Lincoln Blvd MUB 27.808 1.78 2.75 65% 5 - 64 64 100 20ENT-0020 100% Affordable 1819 Pico Blvd NC 21.524 1.99 2.00 100% 4 1 47 48 97 09AA-007 100% Affordable 2802 Pico Blvd NC 16.2 1.50 1.5 (NC) + 3 units (R2) 100% 4 0 33 33 89 22ENT-0001 100% Affordable 1211-1215 19th St MUB 7.5 2.81 2.25 125% 6 - 34 34 197 22ENT-003 100% Affordable 1333 7th St NV 7.5 5.06 4 127% 8 - 38 38 221 21ENT-0269 100% Affordable 1634 20th IC 19.8 3.95 2.25 176% 7 - 78 78 172 12DEV001 Market Rate 1318-1324 2nd St BC 15 3.10 1.77 / 2.0 155% 4 45 10 55 160 17ENT-0275 Market Rate 1235 5th St NV 7.35 3.50 3.50 100% 5 18 5 23 136 18ENT-0283 Market Rate 1323 5th St NV 7.496 3.50 3.50 100% 6 43 9 52 302 19ENT-0041 Market Rate 1338-1342 5th St NV 14.985 3.50 3.50 100% 6 100 20 120 349 19ENT-0042 Market Rate 1415-1423 5th St TA 14.961 4.00 4.00 100% 8 111 23 134 390 18ENT-0211 Market Rate 1425-1427 5th St TA 15 4.00 4.00 100% 8 92 - 92 267 19ENT-0039 Market Rate 1437 5th St TA 7.489 4.00 4.00 100% 8 52 11 63 366 16ENT-0143 Market Rate 1313-1325 6th St NV 15 3.10 3.50 89% 6 64 - 64 186 19ENT-0040 Market Rate 1437 6th St NV 7.5 3.50 3.50 100% 6 43 9 52 302 18ENT-0200 1238 7th St NV 7.486 3.50 3.50 100% 6 37 215 11DEV008 Market Rate 1317 7th St NV 15 3.57 1.6 / 2.0 (3.75 DA) 179% 5 51 6 57 166 05AA-015 Market Rate 1427 7th St NV 15 1.87 2.00 94% 5 43 5 48 139 18ENT-0136 Market Rate 1437 7th St NV 14.991 NA 2.0 - 6 52 13 65 189 8.B.e Packet Pg. 410 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-62 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 19ENT- 008521ENT- 0027 Market Rate 1448 7th St NV 7.5 3.50 3.50 100% 5 15 5 820 46116 18ENT-0212 1514 7th St TA 7.493 4.00 4.00 100% 8 50 291 18ENT-0210 Market Rate 1543-1547 7th St TA 14.962 4.00 4.00 100% 8 75 25 100 291 18ENT-0206 Market Rate 701 Colorado Ave TA 7.481 4.00 4.00 100% 8 49 10 59 344 18ENT-0357 1445-1453 10th St MUBL 13.495 2.00 2.00 100% 4 40 129 18ENT-0105 1820-1826 14th St NC 15 1.75 1.75 100% 3 39 113 19ENT-0328 1834-1848 14th St NC 30.06 1.75 1.75 100% 4 73 106 14AA-001 Market Rate 1347 19th St GC (C4) 7.5 1.00 0.80 125% 2 3 - 3 17 11DEV007 Market Rate 702 Arizona Ave NV 15 3.00 3.0 (DA) 100% 4 40 5 45 131 13DEV-008 Market Rate 500 Broadway TA 67.5 4.00 4.00 100% 7 249 - 249 161 18ENT-0229 Market Rate 501 Broadway TA 14.975 4.00 4.00 100% 8 75 19 94 273 06DR-003 Market Rate 525 Broadway TA 37.5 1.90 2.00 95% 6 115 10 125 145 20ENT-0241 Market Rate 710 Broadway TA 108.5 2.75 / 4.0 2.75 / 4.0 (split zone) 100% 8 206 89 295 118 17ENT-0095 Market Rate 2225 Broadway MUBL 9.7 1.75 1.75 100% 3 13 2 15 67 12AA-002 520 Colorado Ave TA 6.26 1.90 2.00 95% 5 34 237 18ENT-0362 Market Rate 525 Colorado Ave TA 7.5 5.4 4.00 137% 8 30 10 40 232 18ENT-0199 Market Rate 601-609 Colorado Ave TA 22.5 4.00 4.00 100% 8 104 36 140 271 18ENT-0129 711 Colorado Ave TA 7.48 4.00 4.00 100% 7 56 326 13DEV001 Market Rate 1431 Colorado Ave TA 22.6 1.99 4.00 50% 42 8 50 96 07DEV-005 Market Rate 2930 Colorado Ave MUC 148.966 2.20 2.20 (DA) 100% 5 318 38 356 104 8.B.e Packet Pg. 411 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-63 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 17ENT-0096 Market Rate 1450 Cloverfield MUBL 19.6 1.75 1.75 100% 3 32 3 35 78 17ENT-0297 Market Rate 1707 Cloverfield BTV 74.065 1.85 2.00 92% 4 58 5 63 37 20ENT-0011 Market Rate 1512 Euclid St MUBL 7.5 1.45 1.50 97% 3 8 2 10 58 16ENT-0102 Market Rate 1318 Lincoln Blvd MUB 14.982 2.25 2.75 82% 5 39 4 43 125 20ENT-0163 Market Rate 1427-31 Lincoln Blvd LT 15 2.25 2.25 100% 5 24 6 30 87 15ENT-0266 Market Rate 1430-1444 Lincoln Blvd MUB 30 2.75 2.75 100% 5 100 - 100 145 16ENT-0098 Market Rate 1437-1443 Lincoln Blvd MUB 15.044 2.25 2.75 82% 5 34 6 40 116 07AA-007 1447 Lincoln Blvd LT 23 1.8 (1.3 +0.5) 1.80 100% 5 97 188 12DEV017 Market Rate 1560 Lincoln Blvd MUB 37.5 2.73 2.75 (DA) 100% 5 80 20 100 116 12DEV011 Market Rate 1601 Lincoln Blvd MUB 33.154 2.34 2.25 (DA) 104% 5 71 19 90 118 16ENT-0036 Market Rate 1613-1637 Lincoln Blvd MUB 69.096 2.25 2.25 100% 5 176 15 191 120 15ENT-0306 1626 Lincoln Blvd MUB 27.808 1.78 2.75 65% 5 64 100 16ENT-0058 Market Rate 1641-1645 Lincoln Blvd MUB 20.905 2.25 2.25 100% 5 61 5 66 138 11DEV014 Market Rate 1650-1660 Lincoln Blvd MUB 31.065 2.25 2.25 (DA) 100% 5 90 8 98 137 19ENT-0014 2120 Lincoln Blvd GC 14.16 2.00 2.00 100% 4 37 114 16ENT-0035 Market Rate 2903-2931 Lincoln Blvd GC 32.277 1.84 2.00 92% 4 43 4 47 63 20ENT-0079 Market Rate 1413 Michigan Ave NC 18 2.06 (w/SDB) 1.75 118% 4 1 57 58 140 16ENT-0118 Market Rate 3030 Nebraska Ave MUC 74.185 1.42 1.50 95% 4 174 9 183 107 15ENT-0300 Market Rate 1828 Ocean Ave OF 45.12 1.81 2.0 91% 4 67 16 83 80 8.B.e Packet Pg. 412 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-64 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 15ENT-0297 Market Rate 1921 Ocean Front Walk OF 23.258 1.7 2.0 83% 4 22 - 22 41 18ENT-0005 Market Rate 216-234 Pico Blvd MUBL 55.689 1.75 1.75 100% 3 93 12 105 82 20ENT-0020 1819 Pico Blvd NC 21.524 1.99 2.00 100% 4 48 97 09AA-007 2802 Pico Blvd NC 16.2 1.50 1.5 (NC) + 3 units (R2) 100% 33 89 08AA-002 Market Rate 519 Santa Monica Blvd NV 14.9 1.90 2.00 95% 5 36 4 40 12116 19ENT-0340 Market Rate 825 Santa Monica Blvd GC 1522.5 1.50 2.001.50 75125% 3 52 4 4856 139108 18ENT-0038 Market Rate 2822 Santa Monica Blvd MUBL 28.487 1.75 1.75 100% 3 46 4 50 76 16ADM-0050 Market Rate 2901-2907 Santa Monica Blvd MUBL 19.122 1.50 1.50 100% 3 44 7 51 116 17ENT-0298 Market Rate 2906-2918 Santa Monica Blvd MUBL 28.309 1.68 1.75 96% 3 42 4 46 71 15ENT-0313 Market Rate 3008 Santa Monica Blvd MUBL 14.307 1.74 1.75 100% 3 22 4 26 79 18ENT-0182 Market Rate 1618 Stanford MUC 19.969 1.70 1.70 100% 5 43 4 47 103 16ENT-0115 Market Rate 601-611 Wilshire Blvd MUB 14.952 2.25 2.25 100% 4 37 3 40 117 06DR-020 Market Rate 2300 Wilshire Blvd C6 40.6 1.48 1.50 99% 3 30 - 30 32 19ENT-0028 Market Rate 2729 Wilshire Blvd MUB 7.5 1.25 1.25 100% 2 8 1 9 52 18ENT-0244 Market Rate 3223 Wilshire Blvd MUB 19.5 2.25 2.25 100% 4 49 4 53 118 21ENT-0035 Market Rate 1101 Wilshire Blvd MUB 22.489 3.03 (SDB) 2.25 135% 6 82 11 93 180 22ENT-0011 Market Rate 1553-1555 4th St TA 14.997 2.87 2.25 128% 5 54 6 60 174 22ENT-002 Market Rate 1302 6th St NV 18.4 3.50 3.5 100% 6 73 7 80 189 21ENT-0091 Market Rate 1524 7th St TA 15 4.00 2.25 178% 8 80 20 100 290 8.B.e Packet Pg. 413 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-65 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 21ENT-0217 Market Rate 528 Arizona Ave NV 18.5 3.50 3.50 100% 6 73 7 80 188 22ENT-0037 Market Rate 1527-1547 Lincoln Blvd LT 37.455 2.25 2.25 100% 5 106 8 114 133 22ENT-0012 Market Rate 2537 Lincoln Blvd GC 19.2 2.25 1.50 150% 4 44 5 49 111 22ENT-0013 Market Rate 2601-2645 Lincoln Blvd MUBL 203.25 2.25 1.50 150% 5 468 53 521 112 21ENT-0226 Market Rate 1801 Santa Monica Blvd GC 22.49 1.50 1.50 100% 3 41 - 41 79 21ENT-0227 Market Rate 1819 Santa Monica Blvd GC 22.5 1.50 1.50 100% 3 41 - 41 79 22ENT-0005 Market Rate 1902 Wilshire Blvd MUB 22.5 2.25 2.25 100% 5 71 - 71 137 21ENT-0228 Market Rate 1931 Wilshire Blvd MUB 25.5 2.25 2.25 100% 5 60 - 60 102 22ENT-0006 Market Rate 2025 Wilshire Blvd MUB 18.5 2.25 2.25 100% 4 46 - 46 108 22ENT-0007 Market Rate 2501 Wilshire Blvd MUB 30.8 2.25 2.25 100% 4 78 - 78 110 8.B.e Packet Pg. 414 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-66 Attachment 3 - Environmental and Infrastructure Constraints Government Code Section 65583.2(b)(4) requires a general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the jurisdiction. This information need not be identified on a site- specific basis. Below is a summary of the analysis of potential environmental and infrastructure constraints: 1. Environmental Constraints a. Fire The City is highly urbanized and does not include any areas designated as a High or Very High Fire Hazard Severity Zone (FHSZ). The nearest wildfire zones are to the north of the City associated with the Santa Monica Mountains and as such, wildfire risk is very limited within City boundaries. The primary fire hazard risks are man-made and are most likely to occur in commercial and industrial areas where industrial chemicals are used, stored, or transported. These potential fire risks, however, are mitigated by stringent enforcement of State and Federal regulations related to hazardous materials storage and transport. Fire risks are not considered constraints to housing development since there are existing regulations and plans in place to address such risk. b. Flooding FEMA recently updated the City’s flood maps to account for flooding due to climate change and rising ocean levels. Based on the new maps, 85 beach front properties along Pacific Coast Highway in the City are now within a FEMA defined Special Flood Hazard Area (SFHA), which is an area subject to a one percent or greater chance of flooding in any given year. To ensure compliance with FEMA, the City amended Santa Monica Municipal Code Chapter 7.68 (Floodplain Management Regulations) on March 3, 2021. The amended regulations require new construction in the special flood zones to obtain a floodplain development permit and implement safety requirements addressing flood risks. Inundation by tsunami can also affect the low-lying beach front properties of the City. In the event of a tsunami, the City has designated tsunami evacuation routes and has also adopted a Multi Hazard Functional Emergency Plan to reduce risk and prevent loss from large scale emergencies, including tsunamis. Location in a flood zone or tsunami zone are not considered constraints to housing development since there are existing regulations and plans in place to address such risk. c. Fault Rupture and Seismic Hazards The City of Santa Monica is located in a seismically active area. The closest known fault in the City is the Santa Monica Fault, which is comprised of various segments with several strands that cross through the northeastern portion of the City. The Santa Monica Fault zone was designated in 2018 as an active fault by the California Geological Survey (CGS). A number of SSI sites identified on the eastern end of Wilshire Boulevard and Santa Monica Boulevard are located within this fault zone. The State does not prohibit housing in an active fault zone, but instead 8.B.e Packet Pg. 415 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-67 requires that structures built for human occupancy be assessed for potential fault rupture risks. Consistent with State requirements, the City’s Building and Safety Division requires the submittal of a Fault Rupture Study to assess potential fault rupture risks and implement measures as necessary to mitigate such risks. Additionally, the design and construction of new buildings are required to be engineered to withstand the seismic ground acceleration that may occur during an earthquake, pursuant to the Santa Monica Building Code which incorporates applicable provisions of the California Building Code (CBC). The City also requires new buildings to submit a Design-Level Geotechnical Report prior to building permit issuance in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design to minimize seismic hazards. Fault rupture risks and seismic hazards are not considered constraints to housing development since there are existing regulations and plans in place to address such risks. d. Liquefaction Liquefaction occurs when ground shaking transforms granular material from a solid state to a liquefied state due to earthquake. These soils may acquire a high degree of mobility and lead to structurally damaging deformations. Liquefaction begins below the water table, but after liquefaction has developed, the groundwater table will rise and cause the overlying soil to mobilize. Liquefaction typically occurs in areas where the groundwater is less than 30 feet from the surface and where the soils are composed of poorly consolidated fine to medium sand. The CGS Seismic Hazard Zone Map that covers the City of Santa Monica identifies the beach front areas and a small eastern portion of the City between Olympic Boulevard and Pearl Street as having liquefaction risk. However, according to the City’s Safety Element Geologic Hazards map, the City has varying potential for liquefaction:  Along the beach  From the beach, inland to the southwest corner of the city to Marine Park following the lowlands along Lincoln Boulevard  In the northern industrial corridor Liquefaction risks are addressed through the City’s building permit process. The design and construction of new buildings are required to be engineered to address potential liquefaction risks, pursuant to the Santa Monica Building Code which incorporates applicable provisions of the California Building Code (CBC). Additionally, the City requires developers of new buildings to submit a Design-Level Geotechnical Report in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. The Geotechnical Report is required to include a site- specific soils investigation to determine liquefaction potential on the site. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design prior to building permit issuance to minimize liquefaction risks. As such, liquefaction is not considered to be a constraint to housing development since there are existing regulations and plans in place to address this environmental concern. 8.B.e Packet Pg. 416 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-68 e. Landslides The main areas of landslide concern within the City are confined to the areas along Highway 1/Pacific Coast Highway (Hwy 1) below the Palisades bluffs, at the southwestern edge of the City. The City has implemented a number of projects in the past decade to reduce landslide risks and soil instability at the bluffs including the California Incline Bridge Replacement Project and the Santa Monica Palisades Bluff Stabilization Project. The geotechnical reports for these two projects were submitted to the California Coastal Commission, Caltrans, and the City of Santa Monica and each agency concluded that the planned construction improvements on the bluff would be safe and not cause or contribute to erosion or degradation of geologic stability. In addition, several slope stabilization and dewatering measures have been implemented by the City which has decreased rate of erosion and improved the stability of the bluffs. As a result of these measures, landslide risks below the bluffs are considered low. The properties in the northern portion of the City (near the Santa Monica Mountains) and in the Bryn Mawr Avenue residential area near Marine Park are characterized by steeper slopes. The design and construction of new buildings are required to be engineered to minimize landslide risks and soil instability, pursuant to the Santa Monica Building Code which incorporates the applicable provisions of the California Building Code (CBC). The City also requires new buildings to submit a Design-Level Geotechnical Report prior to building permit issuance in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design to minimize landslide and soil collapse hazards. Landslide risks are not considered to be constraints to housing development since there are existing regulations and plans in place to address such concerns. f. Former Claypit/Landfill Areas Beginning in the early 1900s, clay mining operations took place in the east central portion of the City (near the City Yards and the Bergamot Plan area). After clay quarries were depleted, some clay pit areas were used as municipal landfills by the City from the mid-1940s until December 1970. After the landfills closed, structures were built over the landfills and remediation efforts have taken place including the installation of methane probes at the City Yards. Future housing projects occurring in these former claypit/landfill areas would require detailed Phase I environmental Site Assessments and subsurface investigations (Phase II) as necessary to address human health hazards. Any clean up recommendations and remediation measures in Phase I and Phase II site assessments are required to be implemented under the oversight of the appropriate clean up agency (Department of Toxic Substances Control, State Water Resources Control Board, Santa Monica Fire Department, etc.). The former claypit/landfill areas are not considered to be constraints to housing development since there are existing regulations and plans in place to address such concerns on a case-by-case basis. g. Santa Monica Airport The Santa Monica Municipal Airport, located in the southeastern area of the City, covers approximately 215 acres of land generally bounded by Bundy Drive to the east, Santa Monica Business Park and Ocean Park Boulevard to the north, 23rd Street to the west, and Dewey Street 8.B.e Packet Pg. 417 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-69 in the City of Los Angeles to the south. The Santa Monica Municipal Airport is a general aviation airport that primarily caters to personal aircraft and flight schools and contains a number of non-aviation uses primarily located in the area south of the runways, including the Santa Monica College Bundy Campus. This airport is currently subject to a settlement agreement with the FAA and Consent Decree that require the City to maintain airport operations through December 31, 2028, and to also Santa Monica Measure LC, which governs use of the entire airport site should the City elect to close its airport at any time after December 31, 2028, as authorized by the Consent Decree. The Los Angeles County Airport Land Use Commission (ALUC) is responsible for airport land use compatibility planning for Los Angeles County. Local actions, including rezoning and new housing projects located within an Airport Influence Areas (AIA) must be submitted to the ALUC for review. None of the sites identified in the SSI are located in Santa Monica’s AIA. The other potential environmental issue associated with the airport relates to operational noise. In general, residential uses should be sited outside of an airport’s 65 dBA CNEL (decibels, Community Noise Equivalent Level) noise contour. None of the sites identified in the SSI are located within the Santa Monica Airport’s 60, 65, and 70 CNEL noise contours. Therefore, the presence of the Santa Monica Airport is not considered to be a constraint to housing development. h. Biological Resources The City is mostly urbanized, with few areas of native wildlife habitat occurring within the City limits. The nearest wildlife habitat occurs along the coast at Santa Monica State Beach. Substantial forested open space occurs in the Santa Monica Mountains, located approximately 3.5 miles to the north. The majority of the City of Santa Monica has been developed, paved, or landscaped, and is generally devoid of large expanses of habitat that support sensitive species. No major regional wildlife migration corridors are known to exist within the City limits. No native riparian habitat, blueline streams, wetlands, or sensitive natural communities are located in the City limits. The beach areas of the City do provide foraging and roosting opportunities for several special status species (e.g., least terns. Snowy plovers). The City is not recognized as an existing or proposed Significant Ecological Area (SEA) that links wildlife populations. Biological resources are not considered to be constraints to housing development. 2. Infrastructure Constraints As an urbanized community with well established residential neighborhoods and commercial districts, Santa Monica has a comprehensive backbone infrastructure which includes existing sewer and water lines, and storm drains. Based on existing and planned capacity, the City has sufficient infrastructure (water, sewer, and storm drain) capacity to accommodate the RHNA at all income levels. a. Sewer System 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. Sewer pipes have a flow capacity based on the diameter of the pipe 8.B.e Packet Pg. 418 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-70 and the slope of the pipeline. Increased wastewater flows from construction of up to 8,895 units in the next 8 years under the RHNA is projected to result in impacts to existing sewer pipes, incrementally triggering the need for expansion or replacement of individual sewer line segments. The City’s Public Works Department anticipates that an increase in the Capital Facilities Fee would be necessary to finance the capital improvements necessary to accommodate the increase in housing. While an increase in sewage capacity will be required to serve future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The City does not budget or pay for improvements that are necessary to support individual private development projects, which includes affordable housing projects. If it is shown that infrastructure capacity will be exceeded by a project, private developers are generally responsible for the cost of upsizing the mains needed to support the demand generated by the project. Housing projects would not be constrained by sewer capacity issues. b. Water System The City of Santa Monica Water Resources Division is a retail water agency providing water service throughout the City, including single- and multi-unit residential, commercial, and industrial customers, and landscape and fire protection supply. 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). Nevertheless, water demand from construction of new housing is expected to increase, which could trigger the need for additional water distribution pumps if there is insufficient water pressure. While an increase in water system capacity will be required to serve future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The City does not budget or pay for improvements that are necessary to support individual private development projects, which includes affordable housing projects. If it is shown that infrastructure capacity will be exceeded by a project, private developers are generally responsible for the cost of upsizing the mains needed to support the demand generated by the project. Housing projects would not be constrained by water system capacity issues. c. Water Supply The City water supply consists of local groundwater, imported water from Metropolitan Water District of Southern California (MWD), and urban treated runoff water from the Santa Monica Urban Runoff Recycling Facility (SMURRF). 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. 8.B.e Packet Pg. 419 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-71 d. Storm Drains The overall drainage pattern of the City of Santa Monica is to the southwest. An underground storm drain system intercepts surface runoff through a series of catch basins, connector pipes and mainlines and carries the majority of the storm water to the Santa Monica Bay portion of the Pacific Ocean. The storm drain system is comprised principally of pipes and channels owned by two separate entities: the City of Santa Monica and the County of Los Angeles. Additionally, a few drainage facilities within the right-of-way of Interstate 10 are under Caltrans jurisdiction. The storm drain pipes/channels in the city range from 16 inches to 11 feet in diameter. The conduits are mainly constructed of reinforced concrete pipe (RCP) or reinforced concrete (RC). A few of the structures are brick arch drains, or corrugated metal pipes (CMP). 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, about 1,050 are owned and maintained by the County; 70 by the City of Santa Monica, and 100 by Caltrans. The City has constructed an Urban Runoff Recycling Facility (SMURRF) to treat the dry weather storm drain discharges from excess irrigation, spills, construction sites, pool draining, car washing and other activities that would otherwise drain into the Santa Monica Bay and recycle it for irrigation and dual plumbed building purposes. All projects on sites over 15,000 sf would be subject to the City’s Runoff Conservation and Sustainable Management Ordinance requirements. This would include preparation and implementation of a Runoff Mitigation Plan to minimize polluted runoff in accordance with the City’s Ordinance. In addition, the projects would be required to store and use (for non-potable purposes), infiltrate, or evapotranspire project-generated runoff during a 0.75-inch storm event, or alternatively, pay the City an urban runoff-reduction fee. Therefore, storm drains do not pose a constraint to housing development. 8.B.e Packet Pg. 420 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-72 Attachment 4 – Letter of Intent from SMMUSD 8.B.e Packet Pg. 421 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-73 Attachment 5 – Suitable Sites Inventory Table 8.B.e Packet Pg. 422 Attachment: Appendix F SSI Report Redline June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-61 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 3223 WILSHIRE BLVD 90403 4266001046 Mixed Use Boulevard MUB 0.15 parking lot for Aah's No Address 4268010017 Mixed Use Creative MUC 1.48 one-story light industrial/creative office 2207 BROADWAY 4275006026 Healthcare Mixed Use HMU 0.14 parking lot owned by Saint John's No Address 4287003017 Low Density Housing OP2 0.18 (blank) No Address 90405 4289019022 Mixed Use Boulevard Low MUBL 0.13 vacant bowling alley No Address 90405 4289025005 Oceanfront OF 0.53 vacant parking lot next to Casa del mar hotel No Address 4290020045 Oceanfront OF 1.04 parking lot No Address 4291021009 Downtown Core LT 0.09 parking lot 1021 GRANT ST 90405-1411 4284015017 Low Density Housing R2 0.15 (blank) 1101 WILSHIRE BLVD 90401-2011 4281020012 Mixed Use Boulevard MUB 0.2 one-story JP bar 1121 22ND ST 90403-5721 4276005022 Low Density Housing R2 0.14 (blank) 1127 2ND ST 90403-5003 4292021010 Downtown Core WT 0.17 parking lot 1129 2ND ST 90403-5003 4292021009 Downtown Core WT 0.17 parking lot 1133 OCEAN AVE 90403-3503 4292028001 Downtown Core OT 4.38 Miramar Hotel 1211 12TH ST 90403 4282005053 Medium Density Housing R3 0.34 (blank) 1238 7TH ST 90401-1606 4291006006 Downtown Core NV 0.17 one-story office 129 SANTA MONICA BLVD 90401-2201 4291014024 Downtown Core BC 0.69 parking lot 1313 6TH ST 90401-1603 4291009021 Downtown Core NV 0.34 parking lot 1318 LINCOLN BLVD 90401-1706 4291008025 Downtown Core LT 0.34 parking lot 1319 CENTINELA AVE 90404-2602 4267014026 Low Density Housing R2 0.21 (blank) 1323 5TH ST 90401 4291010029 Downtown Core NV 0.17 parking lot 1342 5TH ST 90401 4291011019 Downtown Core NV 0.17 parking lot 1342 5TH ST 90401-1415 4291011020 Downtown Core NV 0.17 parking lot 1342 BERKELEY ST 90404-2504 4267012009 Low Density Housing R2 0.18 (blank) 1347 YALE ST 90404-2411 4267011021 Mixed Use Boulevard Low MUBL 0.07 one-story retail building 1413 MICHIGAN AVE 90404-4303 4283013024 Neighborhood Commercial NC 0.41 Vacant lot 1415 5TH ST 90401-2401 4291019021 Downtown Core TA 0.17 two story multitenant retail building 1423 5TH ST 90401-2401 4291019020 Downtown Core TA 0.17 two story multitenant retail building 1427 5TH ST 90401-2401 4291019019 Downtown Core TA 0.34 one-story vacant retail building 1427 LINCOLN BLVD 90401-2770 4282027020 Downtown Core LT 0.17 one-story comic book store 1430 LINCOLN BLVD 90401-2733 4291021006 Downtown Core LT 0.17 parking lot 1431 COLORADO AVE 90404-3314 4282034009 Mixed Use Boulevard Low MUBL 0.52 one-story marble store 1431 LINCOLN BLVD 90401-2732 4282027019 Downtown Core LT 0.17 one-story comic book store 1432 17TH ST 90404-2802 4282019007 Low Density Housing R2 0.17 (blank) 1432 LINCOLN BLVD 90401-2733 4291021007 Downtown Core LT 0.17 parking lot 1434 14TH ST 90404-2704 4282022027 Medium Density Housing R3 0.17 (blank) 1437 5TH ST 90401-2401 4291019018 Downtown Core TA 0.17 parking lot 1437 6TH ST 90401-2509 4291020016 Downtown Core NV 0.17 one story residence 1437 7TH ST 90401-2633 4291021029 Downtown Core NV 0.34 office 8.B.f Packet Pg. 423 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-62 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1437 LINCOLN BLVD 90401-2732 4282027018 Downtown Core LT 0.17 one-story retail building 1438 LINCOLN BLVD 90401-2733 4291021008 Downtown Core LT 0.09 parking lot 1443 18TH ST 90404-2803 4275010016 Mixed Use Boulevard Low MUBL 0.17 Vacant lot 1443 LINCOLN BLVD 90401-2732 4282027028 Downtown Core LT 0.17 one-story retail 1444 LINCOLN BLVD 90401-2733 4291021010 Downtown Core LT 0.17 parking lot 1445 5TH ST 90401 4291019017 Downtown Core TA 0.17 parking lot behind black tux 1445 5TH ST 90401-2401 4291019016 Downtown Core TA 0.17 vacant one-story building 1448 7TH ST 90401-2659 4291020008 Downtown Core NV 0.17 residential 1500 LINCOLN BLVD 90401 4291022003 Downtown Core LT 0.17 Von's 1500 LINCOLN BLVD 90401-2735 4291022025 Downtown Core LT 0.52 Von's 1510 FRANKLIN ST 90404-3208 4267027057 Low Density Housing R2 0.19 (blank) 1512 EUCLID ST 90404-3307 4282032003 Mixed Use Boulevard Low MUBL 0.17 vacant single family home 1514 7TH ST 90401-2606 4291023002 Downtown Core TA 0.17 construction staging site 1514 PRINCETON ST 90404-3510 4267022010 Low Density Housing R2 0.11 single family dwelling 1518 LINCOLN BLVD 90401-2735 4291022004 Downtown Core LT 0.17 Von's 1526 LINCOLN BLVD 90401-2735 4291022005 Downtown Core LT 0.17 Von's 1527 17TH ST 90404-3401 4275012020 Low Density Housing R2 0.17 single dwelling unit 1534 LINCOLN BLVD 90401-2735 4291022006 Downtown Core LT 0.17 Von's 1543 7TH ST 90401-2644 4291022014 Downtown Core TA 0.17 parking lot 1546 9TH ST 90401-2709 4282028007 Medium Density Housing R3 0.17 (blank) 1547 6TH ST 90401-2505 4291023011 Downtown Core TA 0.17 one-story multi-tenant building, restaurant, office 1547 7TH ST 90401-2605 4291022013 Downtown Core TA 0.17 parking lot 1618 STANFORD ST 90404-4121 4268002005 Mixed Use Creative MUC 0.46 one story office 1649 CENTINELA AVE 90404-4201 4268006016 Low Density Housing R2 0.14 single family dwelling 1650 LINCOLN BLVD 90404-3712 4290002008 Downtown Core LT 0.37 one-story retail, boxing fitness building 1660 LINCOLN BLVD 90404-3712 4290002006 Downtown Core LT 0.17 one-story retail, boxing fitness building 1665 APPIAN WAY 90401-3258 4290018018 Medium Density Housing R3 0.1 residential 1754 10TH ST 90404-4346 4283018002 Low Density Housing R2 0.17 (blank) 1819 PICO BLVD 90405-1626 4274017019 Neighborhood Commercial NC 0.31 parking lot for religious institution 1840 14TH ST 90404-4606 4283030018 Neighborhood Commercial NC 0.17 100% affordable housing under construction 1840 17TH ST 90404-4412 4283032008 Low Density Housing R2 0.17 (blank) 1844 14TH ST 90404-4606 4283030017 Neighborhood Commercial NC 0.17 100% affordable housing under construction 1848 14TH ST 90404-4606 4283030016 Neighborhood Commercial NC 0.17 100% affordable housing under construction 1900 20TH ST 90404 4274019056 Low Density Housing R2 0.17 single family dwelling 1902 EUCLID ST 90404-4610 4283028010 Low Density Housing R2 0.17 (blank) 1949 17TH ST 90404-4701 4274015020 Low Density Housing R2 0.18 Vacant lot 1958 20TH ST 90404-4718 4274019001 Low Density Housing R2 0.17 (blank) 2002 21ST ST 90404-4874 4274026001 Low Density Housing R2 0.17 one-story apartments 2008 21ST ST 90404-4875 4274026003 Low Density Housing R2 0.16 one-story apartments 2102 5TH ST 90405-1204 4289010006 Low Density Housing OP2 0.13 (blank) 216 PICO BLVD 90405-1078 4289019023 Mixed Use Boulevard Low MUBL 0.13 vacant bowling alley 8.B.f Packet Pg. 424 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-63 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 228 PICO BLVD 90405 4289019021 Mixed Use Boulevard Low MUBL 0.13 vacant bowling alley 234 PICO BLVD 90405-1020 4289019019 Mixed Use Boulevard Low MUBL 0.64 vacant bowling alley 2409 28TH ST 90405-1926 4270004017 Low Density Housing R2 0.21 (blank) 2425 20TH ST 90405-2703 4273019001 Low Density Housing R2 0.15 (blank) 248 PICO BLVD 90405-1020 4289019017 Mixed Use Boulevard Low MUBL 0.13 vacant bowling alley 2501 2ND ST 90405-3513 4287010011 Low Density Housing OP2 0.15 (blank) 254 PICO BLVD 90405 4289019016 Mixed Use Boulevard Low MUBL 0.13 vacant bowling alley 2714 HIGHLAND AVE 90405-4408 4287019012 Low Density Housing OP2 0.11 (blank) 2906 SANTA MONICA BLVD 90404-2449 4267018026 Mixed Use Boulevard Low MUBL 0.49 vacant two story office 2918 SANTA MONICA BLVD 90404-2437 4267018003 Mixed Use Boulevard Low MUBL 0.16 vacant parking lot 2923 WILSHIRE BLVD 90403-4903 4266009020 Mixed Use Boulevard MUB 0.37 parking lot 3223 WILSHIRE BLVD 90403-2332 4266001045 Mixed Use Boulevard MUB 0.3 one-story Aah's retail store 436 PIER AVE 90405-5510 4287027065 Low Density Housing OP2 0.17 (blank) 501 BROADWAY 90401-2405 4291019027 Downtown Core TA 0.34 one-story vacant retailer (Black tux) 525 COLORADO AVE 90401-2407 4291024014 Downtown Core TA 0.17 one-story creative office 601 WILSHIRE BLVD 90401-1501 4292005029 Downtown Core WT 0.23 vacant one and two story buildings 609 COLORADO AVE 90401-2507 4291023010 Downtown Core TA 0.34 one-story multi-tenant building, restaurant, office 610 CALIFORNIA AVE 90403-3912 4292005022 Low Density Housing R2 0.11 (blank) 611 WILSHIRE BLVD 90401-1501 4292005026 Downtown Core WT 0.11 vacant one and two story buildings 710 BROADWAY 90401-2605 4291022026 Downtown Core TA 1.2 Von's 711 COLORADO AVE 90401-2609 4291022012 Downtown Core TA 0.17 construction staging site 734 12TH ST 90402-2912 4280025015 Neighborhood Commercial NC 0.11 single dwelling unit 817 16TH ST 90403-1803 4281001021 Low Density Housing R2 0.17 single dwelling unit 825 SANTA MONICA BLVD 90401 4282010012 General Commercial GC 0.17 Toyota dealership 825 SANTA MONICA BLVD 90401-2702 4282010013 General Commercial GC 0.17 Toyota dealership 825 SANTA MONICA BLVD 90401-2702 4282010014 General Commercial GC 0.17 Toyota dealership 918 5TH ST 90403-2610 4292015004 Low Density Housing R2 0.17 (blank) 949 10TH ST 90403-2901 4281025014 Low Density Housing R2 0.17 (blank) 1244 7TH ST 90401-1648 4291006007 Downtown Core NV 0.17 Office building 1301 4TH ST 90401-1301 4291011909 Downtown Core BC 0.74 Bank of America; Chase bank; parking lot 1301 WILSHIRE BLVD 90403-5410 4281012022 Mixed Use Boulevard MUB 1.38 Von's 1311 5TH ST 90401-1414 4291010019 Downtown Core NV 0.17 one-story retail building 1313 5TH ST 90401-1414 4291010020 Downtown Core NV 0.17 one-story retail building 1317 WILSHIRE BLVD 90403-5410 4281012025 Mixed Use Boulevard MUB 0.52 Rite Aid 1327 5TH ST 90401-1414 4291010017 Downtown Core NV 0.17 one-story retail building 1353 OLYMPIC BLVD 90404-3725 4283008001 Mixed Use Boulevard Low MUBL 0.23 Synder Diamond 1401 WILSHIRE BLVD 90403-5412 4281011028 Mixed Use Boulevard MUB 0.49 one-story US Bank Building 1407 7TH ST 90401-2603 4291021027 Downtown Core NV 0.34 one-story retail 1501 WILSHIRE BLVD 90403-5505 4281005026 Mixed Use Boulevard MUB 0.75 One story vacant retail formerly Santa Monica Town Car 1519 COLORADO AVE 90404-3316 4282035010 Mixed Use Boulevard Low MUBL 0.52 Creative Office 1654 14TH ST 90404-3702 4283008004 Mixed Use Boulevard Low MUBL 0.34 Synder Diamond 8.B.f Packet Pg. 425 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-64 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1660 14TH ST 90404-3702 4283008018 Mixed Use Boulevard Low MUBL 0.49 Synder Diamond 2225 COLORADO AVE 90404-3505 4275016021 Mixed Use Boulevard Low MUBL 0.83 one-story R&D (Kite Pharma) building 2723 LINCOLN BLVD 90405-4621 4285001032 Mixed Use Boulevard Low MUBL 0.47 34 Degrees North Fitness 2848 COLORADO AVE 90404-3637 4268002012 Mixed Use Creative MUC 0.27 one-story light industrial 2878 COLORADO AVE 90404-3637 4268002011 Mixed Use Creative MUC 0.41 one-story light industrial 2902 COLORADO AVE 90404-3650 4268002013 Mixed Use Creative MUC 1.89 one-story light industrial 2912 COLORADO AVE 90404-3642 4268002003 Mixed Use Creative MUC 0.22 one-story light industrial 3025 OLYMPIC BLVD 90404 4268010018 Mixed Use Creative MUC 1.25 one-story creative office/light industrial building 625 ARIZONA AVE 90401-1609 4291006027 Downtown Core NV 0.52 Office building 626 WILSHIRE BLVD 90401-1502 4291006001 Downtown Core NV 0.34 711 strip mall 631 COLORADO AVE 90401-2507 4291023009 Downtown Core TA 0.34 one-story Bay Films building 1237 LINCOLN BLVD 90401-1703 4282009027 Downtown Core LT 0.17 Motel 1243 LINCOLN BLVD 90401-1703 4282009014 Downtown Core LT 0.17 Motel 1410 LINCOLN BLVD 90401-2733 4291021002 Downtown Core LT 0.17 parking lot 1527 LINCOLN BLVD 90401-2734 4282028019 Downtown Core LT 0.17 former tile store; vacant retail building 1533 LINCOLN BLVD 90401-2734 4282028018 Downtown Core LT 0.17 former tile store; vacant retail building 1537 LINCOLN BLVD 90401-2734 4282028011 Downtown Core LT 0.17 auto repair 1543 LINCOLN BLVD 90401-2734 4282028010 Downtown Core LT 0.17 auto repair 1553 4TH ST 90019-3469 4291025028 Downtown Core TA 0.17 Vacant bank site across DT station 1555 4TH ST 90401-2310 4291025012 Downtown Core TA 0.17 Vacant bank site across DT station 603 ARIZONA AVE 90401-1609 4291006029 Downtown Core NV 0.17 one-story office building 700 COLORADO AVE 90401-2610 4290001016 Downtown Core TA 0.46 One-story vacant warehouse 718 COLORADO AVE 90401-2610 4290001023 Downtown Core LT 0.5 former Fisher lumber site vacant 718 SANTA MONICA BLVD 90401-2602 4291021001 Downtown Core LT 0.17 commercial building; balloon place and common ownership 2525 MICHIGAN AVE 90404 4268013919 Bergamot Transit Village CAC 9.41 Bergamot Arts Center 2525 MICHIGAN AVE 90404 4268014900 Bergamot Transit Village CAC 0.01 Bergamot Arts Center 1146 16th STREET 90404 4281005900 Low Density Residential R2 0.17 Public parking lot 8 behind café zella 1211 14TH ST 90404-1806 4282003901 Medium Density Housing R3 0.17 public parking lot 12 behind Petco 121 7 EUCLID ST 90401-2734 4282004900 Medium Density Housing R3 0.34 public parking lot 7 behind LaMonarca Bakery No Address 90401-2735 4288009900 High Density Housing R4 0.29 City parking lot on main No Address 90401-2734 4288009901 High Density Housing R4 0.11 City parking lot on main No Address 90404-3303 4288010900 High Density Housing R4 0.38 City parking lot on main No Address 90404-3304 4288010901 High Density Housing R4 0.15 City parking lot on main No Address 90401-2644 4288011900 Medium Density Housing R3 0.53 City parking lot on main No Address 90401-2734 4288011901 Medium Density Housing R3 0.2 City parking lot on main No Address 90404-3303 4288012902 Medium Density Housing R3 0.62 City parking lot on main No Address 90401-2709 4288013905 Medium Density Housing R3 0.6 City parking lot on main No Address 90404-3507 4288015901 Medium Density Housing R3 1.15 City parking lot on main 1217 14TH ST 90401-2505 4282003900 Medium Density Housing R3 0.17 public parking lot 12 behind petco 1318 4TH ST 90401-2605 4291012900 Downtown Core BC 0.52 Parking Structure 3 1320 4TH STREET 90019-3469 4291012901 Downtown Core BC 0.17 Parking Structure 3 8.B.f Packet Pg. 426 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-65 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1324 5TH ST 90401-2310 4291011900 Downtown Core NV 0.21 Bank of America; Chase bank; parking lot 1324 5TH ST 90403-5507 4291011901 Downtown Core NV 0.14 Bank of America; Chase bank; parking lot 1324 5TH ST 90404-3810 4291011902 Downtown Core NV 0.17 Bank of America; Chase bank; parking lot 1324 5TH ST 90404-4121 4291011903 Downtown Core NV 0.17 Bank of America; Chase bank; parking lot 1324 5TH ST 90404-1807 4291011904 Downtown Core NV 0.17 Bank of America; Chase bank; parking lot 1326 5TH ST 90404-1807 4291011905 Downtown Core NV 0.17 Bank of America; Chase bank; parking lot 1333 4TH ST 90404-3712 4291011910 Downtown Core BC 0.46 Bank of America; Chase bank; parking lot 1334 5TH ST 90404-3818 4291011908 Downtown Core NV 0.17 Bank of America; Chase bank; parking lot 2624 WILSHIRE BLVD 90404-4201 4267007003 Mixed Use Boulevard MUB 0.1 New Balance store parking lot 26TH STRET AND OLYMPIC BLVD 90404-3712 4268001038 Bergamot Transit Village BTV 0.88 Lionsgate parking lot 1455 19th ST 90404-3702 4275009012 Mixed Use Boulevard Low MUBL 0.17 parking lot for one-story building with iron gym and creative office tenants 1522 BROADWAY 90404-3712 4282035002 Mixed Use Boulevard Low MUBL 0.17 parking lot for automotive service center building 1522-1530 Broadway 1625 17TH STREEET 90401-3258 4283010001 Mixed Use Boulevard Low MUBL 0.17 parking lot with vacant office building 1214 SANTA MONICA BLVD 90403-5509 4282023022 General Commercial GC 0.06 parking lot for vacant auto repair 1218 SANTA MONICA BLVD 90405-4901 4282023021 General Commercial GC 0.17 parking lot for vacant auto repair 1348 14TH ST 90404-1907 4282015011 General Commercial GC 0.17 parking lot for truxtons 1421 LINCOLN BLVD 90404-4105 4282027021 Downtown Core LT 0.17 parking lot for CVS pharmacy 1453 25TH ST 90404-1906 4275001013 Mixed Use Boulevard Low MUBL 0.16 parking lot for Helen's cycles 1541 15TH ST 90404-4163 4282035014 Mixed Use Boulevard Low MUBL 0.17 parking lot for SM Conservatory 1547 26TH ST 90404-1907 4267022018 Office Campus OC 0.19 one story commercial building parking lot 1716 BERKELEY ST 90404-4116 4268009019 Bergamot Transit Village CCS 0.27 parking lot serving underparked industrial uses 2306 SANTA MONICA BLVD 90404-4346 4275005002 Mixed Use Boulevard Low MUBL 0.16 parking lot for 2300 santa monica (cynergy) 2439 SANTA MONICA BLVD 90404 4276022001 Mixed Use Boulevard Low MUBL 0.12 Parking lot for laundromat 2447 SANTA MONICA BLVD 90404 4276022004 Mixed Use Boulevard Low MUBL 0.12 Parking lot for auto repair 2615 COLORADO AVE 90404-2809 4267022015 Office Campus OC 0.14 one story commercial building parking lot 2616 WILSHIRE BLVD 90405-1626 4267007002 Mixed Use Boulevard MUB 0.1 New Balance store parking lot 3101 LINCOLN BLVD 90404-1938 4285036002 General Commercial GC 0.11 parking lot for georges burgers 3125 PICO BLVD 90404-4210 4274034023 Neighborhood Commercial NC 0.11 parking for Valentinos restaurant 907 SANTA MONICA BLVD 90405 4282011033 General Commercial GC 0.06 Small parking lot for Tuesday Morning No Address 90404-4606 4282032002 Mixed Use Boulevard Low MUBL 0.17 Ford auto storage lot 1222 BROADWAY 90404-4412 4282033018 Mixed Use Boulevard Low MUBL 0.11 Ford auto storage lot No Address 90404-4606 4282033020 Mixed Use Boulevard Low MUBL 0.11 Ford auto storage lot 1201 SANTA MONICA BLVD 90404-4606 4282014026 General Commercial GC 0.52 BMW auto storage 1222 BROADWAY 90404 4282032001 Mixed Use Boulevard Low MUBL 0.17 Ford auto storage lot 1308 SANTA MONICA BLVD 90403-5605 4282022024 General Commercial GC 0.22 offsite auto storage lot for Suburu 1310 BROADWAY 90404-4610 4282033019 Mixed Use Boulevard Low MUBL 0.11 Ford auto storage lot 1335 LINCOLN BLVD 90403-5606 4282010019 Downtown Core LT 0.17 Toyota service repair lot 1337 12TH ST 90403-5605 4282014016 General Commercial GC 0.34 BMW auto storage 1339 LINCOLN BLVD 90403-5606 4282010018 Downtown Core LT 0.17 Toyota auto storage - service center lot 1347 18TH ST 90405-1109 4276029026 General Commercial GC 0.17 Honda auto storage 8.B.f Packet Pg. 427 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-66 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1348 18TH ST 90403-5605 4276030010 General Commercial GC 0.17 Honda auto storage 1350 19TH ST 90404-2811 4276029010 General Commercial GC 0.17 Honda auto storage 1411 17TH ST 90403-5605 4275011023 General Commercial GC 0.17 off-site parking lot for auto storage 1415 12TH ST 90404-4701 4282023025 General Commercial GC 0.86 offsite overflow Ford service & repair auto storage lot 1415 EUCLID ST 90404-4718 4282022023 General Commercial GC 0.17 offsite auto storage lot for Suburu 1418 16TH ST 90404-4874 4282020004 General Commercial GC 0.17 Lexus parking lot - used car lot/service lot 1447 18TH ST 90404-4875 4275010015 Mixed Use Boulevard Low MUBL 0.17 parking lot for Herman's auto repair 1530 SANTA MONICA BLVD 90405 4282020001 General Commercial GC 0.17 Lexus parking lot - used car lot/service lot 1530 SANTA MONICA BLVD 90405-1716 4282020002 General Commercial GC 0.17 Lexus parking lot - used car lot/service lot 1544 14TH ST 90405-1716 4282033010 Mixed Use Boulevard Low MUBL 0.17 Paint and body shop auto storage (see 1538 14th st) 1807 BROADWAY 90403-5608 4275010013 Mixed Use Boulevard Low MUBL 0.17 parking lot for Herman's auto repair 1819 SANTA MONICA BLVD 90405-1204 4276029011 General Commercial GC 0.34 auto inventory lot 2700 LINCOLN BLVD 90404-2914 4287017043 General Commercial GC 0.13 parking lot for Big Q's auto repair - common ownership to 3 adjacent parcels 3204 LINCOLN BLVD 90404-3505 4287032015 General Commercial GC 0.05 auto repair shop parking lot 3204 LINCOLN BLVD 90404-2914 4287032016 General Commercial GC 0.03 auto repair shop parking lot 832 SANTA MONICA BLVD 4282027003 General Commercial GC 0.17 Toyota auto storage 1302 6TH ST 90404-2008 4291010027 Downtown Core NV 0.43 two story office 1450 20TH ST 90404-2916 4275009009 Mixed Use Boulevard Low MUBL 0.52 Part of Big Jos burgers 1457 19TH ST 90404-2008 4275009011 Mixed Use Boulevard Low MUBL 0.34 one story iron gym and creative office with parking lot (common ownership) 1619 1/2 SANTA MONICA BLVD 90405-2530 4282018010 General Commercial GC 0.07 car sales lot; recently sold 1619 SANTA MONICA BLVD 90405-1020 4282018012 General Commercial GC 0.1 car sales lot; recently sold 1634 20TH ST 90405-1926 4275025002 Industrial Conservation IC 0.45 two-story office building 1703 OCEAN PARK BLVD 90405-1826 4273023032 Neighborhood Commercial NC 0.32 one-story Burger restaurant and laundrymat 1801 SANTA MONICA BLVD 90405-2703 4276029048 General Commercial GC 0.34 Honda dealership with surface inventory 1901 WILSHIRE BLVD 90404-2038 4276008010 Mixed Use Boulevard MUB 0.24 one-story vacant House of Billiards building 1902 WILSHIRE BLVD 90404-2039 4276013020 Mixed Use Boulevard MUB 0.11 one story retail/restaurant building (Thai dishes, salon, medical office) 1908 WILSHIRE BLVD 90404-2038 4276013030 Mixed Use Boulevard MUB 0.57 one-story retail/restaurant building (Thai dishes, salon, medical office) 1925 BROADWAY 90404-2039 4275009010 Mixed Use Boulevard Low MUBL 0.17 parking lot for Big Jos burger 2316 LINCOLN BLVD 90403-5823 4289001007 General Commercial GC 0.32 one-story retail (recliner sales) building 2510 PICO BLVD 90405-1020 4270001023 Neighborhood Commercial NC 0.42 car wash 2537 LINCOLN BLVD 90405-3513 4284008016 General Commercial GC 0.44 closed car wash 2720 LINCOLN BLVD 90405-1829 4287017044 General Commercial GC 0.18 Big Q's auto repair 3018 PICO BLVD 90404-2012 4270006041 Neighborhood Commercial NC 0.14 one-story retail building 3024 PICO BLVD 90405-3803 4270006042 Neighborhood Commercial NC 0.13 apartment building 3026 PICO BLVD 90405 4270006043 Neighborhood Commercial NC 0.13 two story commercial retail building 3113 PICO BLVD 90404-3518 4274034027 Neighborhood Commercial NC 0.06 single tenant restaurant 3307 PICO BLVD 90403-4622 4274036002 Neighborhood Commercial NC 0.12 one story retail 3311 PICO BLVD 90404-3518 4274036003 Neighborhood Commercial NC 0.06 one story retail 3317 PICO BLVD 90404-3518 4274036027 Neighborhood Commercial NC 0.16 auto repair shop 1810 COLORADO BLVD 90403-4622 4275022016 Mixed Use Boulevard Low MUBL 0.56 industrial concrete yard Bourgeot Bros 1020 WILSHIRE BLVD 90403-4623 4282007025 Mixed Use Boulevard MUB 0.4 one-story Belcampo restaurant building 8.B.f Packet Pg. 428 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-67 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1025 WILSHIRE BLVD 90403-4623 4281027033 Mixed Use Boulevard MUB 0.52 one-story El Cholo restaurant 1100 SANTA MONICA BLVD 90403-4623 4282024026 General Commercial GC 0.34 Toyota preowned center 1102 BROADWAY 90403-4623 4282031032 Mixed Use Boulevard Low MUBL 0.52 small one story office tenants; appears mostly vacant 1224 5TH ST 90403 4291004016 Downtown Core NV 0.34 one story office building 1234 WILSHIRE BLVD 90403-4706 4282005001 Mixed Use Boulevard MUB 0.34 one-story Ulta building 1323 COLORADO AVE 90403-4705 4282033011 Mixed Use Boulevard Low MUBL 0.52 autobody shop 1411 LINCOLN BLVD 90405-4408 4282027029 Downtown Core LT 0.34 CVS pharmacy 1420 WILSHIRE BLVD 90405-4622 4282003001 Mixed Use Boulevard MUB 0.69 one-story Audio and Video center and Bank of America 1453 14TH ST 90405-4621 4282021013 Mixed Use Boulevard Low MUBL 0.52 one-story building with 3 tenants, Paint lab and small creative office 1518 7TH ST 90404-2408 4291023003 Downtown Core TA 0.17 two story residential 1612 19TH ST 90404-2410 4275022017 Mixed Use Boulevard Low MUBL 0.78 industrial concrete yard Bourgeot Bros 1624 LINCOLN BLVD 90403-4802 4290001012 Downtown Core LT 0.51 car wash 1651 16th ST 90404 4283010900 Mixed Use Boulevard Low MUBL 3.7 Vacant SMMUSD headquarters 1701 WILSHIRE BLVD 90404-3637 4276010035 Mixed Use Boulevard MUB 0.31 one-story Mens Warehouse 1907 WILSHIRE BLVD 90404-3637 4276008023 Mixed Use Boulevard MUB 0.34 one-story restaurant (Chandi) 1921 WILSHIRE BLVD 90404-3650 4276008014 Mixed Use Boulevard MUB 0.34 one-story retail building (GAP) 2020 WILSHIRE BLVD 90404-2449 4276014025 Mixed Use Boulevard MUB 0.45 one-story restaurant and nightclub (Opaque Restaurant and Senator Jones club) 2202 BROADWAY 90404-3642 4275016007 Mixed Use Boulevard Low MUBL 0.83 one-story Ferguson plumbing and lighting 2218 BROADWAY 90403-4904 4275016005 Mixed Use Boulevard Low MUBL 0.45 one-story Ferguson plumbing and lighting 2230 BROADWAY 90404-2437 4275016024 Mixed Use Boulevard Low MUBL 0.5 creative office building 2308 BROADWAY 90403-4903 4275016028 Mixed Use Boulevard Low MUBL 0.64 creative office building 2411 PICO BLVD 90404-2413 4274006023 Mixed Use Boulevard Low MUBL 0.41 auto repair shop 2520 SANTA MONICA BLVD 90404-2555 4275001024 Mixed Use Boulevard Low MUBL 0.48 one-story Goodwill building 2601 WILSHIRE BLVD 90404-2534 4266016054 Mixed Use Boulevard MUB 0.35 76 gas station 2711 WILSHIRE BLVD 90405-2048 4266016100 Mixed Use Boulevard MUB 0.66 Chase bank building with rear parking 2730 SANTA MONICA BLVD 90405 4267020026 Mixed Use Boulevard Low MUBL 0.66 one-story AAA building 2802 SANTA MONICA BLVD 90405-2004 4267019028 Mixed Use Boulevard Low MUBL 0.33 one-story roque and mark office building 2828 WILSHIRE BLVD 90405 4267005009 Mixed Use Boulevard MUB 0.67 one-story commercial building, Vitamin Store and Kimuya restaurant 2914 WILSHIRE BLVD 90405-5743 4267004015 Mixed Use Boulevard MUB 0.59 one-story LA mattress store 2933 SANTA MONICA BLVD 90405-2005 4267011025 Mixed Use Boulevard Low MUBL 0.44 one story Wine Expo 1724 STANFORD ST 90404-4212 4268003003 Mixed Use Creative MUC 0.72 one story light industrial 1740 STANFORD ST 90405-2005 4268003002 Mixed Use Creative MUC 0.67 one story creative office 1832 FRANKLIN ST 90405 4268011006 Mixed Use Creative MUC 0.41 one story creative office 2800 LINCOLN BLVD 4287017045 General Commercial GC 0.49 car wash on Lincoln 3122 NEBRASKA AVE 90405-5739 4268011004 Mixed Use Creative MUC 0.46 one story light industrial 901 SANTA MONICA BLVD 90403-2332 4282011034 General Commercial GC 0.34 one-story Tuesday Morning store 1200 SANTA MONICA 90404 4282023023 General Commercial GC 0.11 Parking lot 1323 SANTA MONICA BLVD 90404-2606 4282015013 General Commercial GC 0.11 one-story Truxton restaurant 1414 18TH ST 90405-2115 4275011002 General Commercial GC 0.17 parking for Honda service repair 1449 18TH ST 90405-2115 4275010014 Mixed Use Boulevard Low MUBL 0.17 parking lot for Herman's auto repair 1457 25TH ST 90405-2115 4275001012 Mixed Use Boulevard Low MUBL 0.16 one-story Helen's cycle 8.B.f Packet Pg. 429 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-68 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1520 BROADWAY 90405-5510 4282035001 Mixed Use Boulevard Low MUBL 0.17 one-story auto parts building 1530 SANTA MONICA BLVD 90401-2405 4282020003 General Commercial GC 0.17 Lexus auto storage 1538 14TH ST 90401-1408 4282033009 Mixed Use Boulevard Low MUBL 0.17 Paint and body shop 1710 SANTA MONICA BLVD 90401-2407 4275011025 General Commercial GC 0.23 two-story vacant building 1719 SANTA MONICA BLVD 90401-1501 4276030011 General Commercial GC 0.34 Honda dealership with surface inventory 1726 SANTA MONICA BLVD 90401-1609 4275011001 General Commercial GC 0.34 one-story vacant Honda service center 1933 WILSHIRE BLVD 90403-3912 4276008015 Mixed Use Boulevard MUB 0.24 one-story retail building (GAP) 2008 PICO BLVD 90401-1501 4273003002 Neighborhood Commercial NC 0.06 one-story campos taco with lot 2008 PICO BLVD 90401-1609 4273003001 Neighborhood Commercial NC 0.11 one-story campos taco with lot 2010 PICO BLVD 90401-1502 4273003003 Neighborhood Commercial NC 0.15 one-story campos taco with lot 2312 SANTA MONICA BLVD 90401-2507 4275005020 Mixed Use Boulevard Low MUBL 0.13 one-story retail store - cynergy cycle 2439 SANTA MONICA BLVD 90401-2610 4276022002 Mixed Use Boulevard Low MUBL 0.12 4 adjacent parcels - common ownership 2445 SANTA MONICA BLVD 90401-2605 4276022003 Mixed Use Boulevard Low MUBL 0.12 4 adjacent parcels - common ownership 2601 COLORADO AVE 90401-2609 4267022017 Office Campus OC 0.14 one story office building 2615 COLORADO AVE 90401-2610 4267022016 Office Campus OC 0.14 one-story vacant office building 2615 WILSHIRE BLVD 90401-2602 4266016055 Mixed Use Boulevard MUB 0.13 one story bar Sonny Mcleans 2624 WILSHIRE BLVD 90402-2912 4267007004 Mixed Use Boulevard MUB 0.1 one-story restaurant 2628 WILSHIRE BLVD 90405-4512 4267007005 Mixed Use Boulevard MUB 0.1 one-story mathnasium and salon 2636 WILSHIRE BLVD 90403-1803 4267007006 Mixed Use Boulevard MUB 0.13 one-story mathnasium and salon 3011 SANTA MONICA BLVD 90401 4267012003 Mixed Use Boulevard Low MUBL 0.16 small one story dentist 3017 SANTA MONICA BLVD 90401-2702 4267012004 Mixed Use Boulevard Low MUBL 0.17 two story office 3101 LINCOLN BLVD 90401-2702 4285036001 General Commercial GC 0.11 one-story Georges burgers restaurant 3115 PICO BLVD 90401 4274034031 Neighborhood Commercial NC 0.17 Valentino's restaurant 3204 LINCOLN BLVD 90401-2704 4287032014 General Commercial GC 0.05 auto repair shop 3232 SANTA MONICA BLVD 90401-2704 4267015027 Mixed Use Boulevard Low MUBL 0.32 one story keyboard store 911 SANTA MONICA 90401 4282011015 General Commercial GC 0.11 Part of Tuesday Morning site 801 WASHINGTON AVE 90403-4013 4281033024 Low Density Housing R2 0.52 parking lot for Saint Pauls Lutheran Church 929 CALIFORNIA AVE 90403-4108 4281029011 Low Density Housing R2 0.98 Vintage Church trinity house parking lot 925 CALIFORNIA AVE 90403-4108 4281029012 Low Density Housing R2 0.12 Vintage Church trinity house parking lot 1140 7TH ST 90403-5204 4292005007 Low Density Housing R2 0.11 St Monica Church parking lot 1257 CENTINELA AVE 90404-1611 4267001016 Low Density Housing R2 0.34 Church of Jesus Christ parking lot 1343 OCEAN PARK BLVD 90405-4719 4284025028 Medium Density Housing R3 0.17 Mt Olive Church with large parking 3114 3RD ST 90405-5412 4287038027 Low Density Housing OP2 1.18 St Clement Church parking (blank) 4287017018 Low Density Housing OP2 0.13 parking lot for car wash on lincoln (blank) 4276012027 Low Density Housing R2 0.13 large parking lot for multi-tenant retail (blank) 4282010011 Medium Density Housing R3 0.5 parking lot for Toyota 1418 9TH ST 90401 4282027004 Medium Density Housing R3 0.17 Parking lot for Toyota 1424 9TH ST 90401 4282027005 Medium Density Housing R3 0.17 Parking lot for Toyota 528 SAN VICENTE BLVD 90402-1803 4293004010 Low Density Housing R2 0.16 vacant lot 1135 PRINCETON ST 90403-4703 4266016045 Low Density Housing R2 0.15 Chase Bank parking lot 1122 14TH ST 90403-5409 4281012024 Low Density Housing R2 0.17 Rite aid parking lot off Wilshire 8.B.f Packet Pg. 430 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-69 Site Address / Intersection 5 Digit ZIP Code Assessor Parcel Number General Plan Designation (Current) Zoning Designation (Current) Parcel Size (Acres) Existing Use / Vacancy 1143 19TH ST 90403-5601 4276008009 Low Density Housing R2 0.17 parking lot 1215 17TH ST 90404-1203 4276011018 Low Density Housing R2 0.17 guest parking for dealership lot 1223 18TH ST 90404-1205 4276012018 Low Density Housing R2 0.17 large parking lot for multi-tenant retail 1215 26TH ST 90404-1403 4267007030 Low Density Housing R2 0.52 parking lot for New balance store 1219 PRINCETON ST 90404-1412 4267006012 Low Density Housing R2 0.21 parking lot for multi tenant retail 1342 19TH ST 90404-1941 4276029009 Low Density Housing R2 0.86 parking lot for dealership 1544 19TH ST 90404-3406 4275013010 Low Density Housing R2 0.14 parking lot for one story office 1847 16TH ST 90404-4403 4283032024 Low Density Housing R2 0.25 vacant lot 621 PACIFIC ST 90405-2411 4289005013 Low Density Housing OP2 0.17 vacant lot Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 A 3223 WILSHIRE BLVD 4266001046 MUB 6,522 parking lot for Aah's 0.00 approved project - part of 3223 wilshire 1 A 3223 WILSHIRE BLVD 4266001045 MUB 13,063 one-story Aah's retail store 1955 0.11 approved 54 unit project 1 AA 1431 LINCOLN BLVD 4282027019 LT 7,512 one-story comic book store 1983 0.13 approved 100 unit project (1427-1431 Lincoln) 1 AA 1427 LINCOLN BLVD 4282027020 LT 7,501 one-story comic book store 1956 0.02 approved 100 unit project (1427-1431 Lincoln) 1 AC 1527 LINCOLN BLVD 4282028019 LT 7,494 former tile store; vacant retail building 1945 0.31 common ownership; in Downtown; single tenant building 1 AC 1533 LINCOLN BLVD 4282028018 LT 7,510 former tile store; vacant retail building 1952 0.43 common ownership; in Downtown; single tenant building 1 AM 3RD STREET/PICO BLVD 4289019022 MUBL 5,601 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 216 PICO BLVD 4289019023 MUBL 5,613 vacant one story bowling alley 1962 0.06 SB330 application; 199 units/ 19 affordable 1 AM 228 PICO BLVD 4289019021 MUBL 5,621 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 248 PICO BLVD 4289019017 MUBL 5,590 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 254 PICO BLVD 4289019016 MUBL 5,611 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 234 PICO BLVD 4289019019 MUBL 28,008 vacant one story bowling alley 1959 0.10 SB330 application; 199 units/ 19 affordable 1 AO 1342 5TH ST 4291011019 NV 7,509 parking lot 0.00 approved 120 unit w SRO project (1338-1342 5th St) 1 AO 1342 5TH ST 4291011020 NV 7,485 parking lot 0.00 approved 120 unit w SRO project (1338-1342 5th St) 1 AR 1445 5TH ST 4291019016 TA 7,498 vacant one-story multitenant retail building 1946 0.02 approved project w SRO 1437-1445 project (63 units) 1 AR 1445 5TH ST 4291019017 TA 7,511 parking lot next to vacant retail 0.00 approved project w SRO 1437-1445 project (63 units) 1 AT LINCOLN BLVD/SANTA MONICA BLVD 4291021009 LT 3,751 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1438 LINCOLN BLVD 4291021008 LT 3,752 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1444 LINCOLN BLVD 4291021010 LT 7,491 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1430 LINCOLN BLVD 4291021006 LT 7,507 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1432 LINCOLN BLVD 4291021007 LT 7,492 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AU 1500 LINCOLN BLVD 4291022003 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1500 LINCOLN BLVD 4291022025 LT 22,450 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1518 LINCOLN BLVD 4291022004 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1526 LINCOLN BLVD 4291022005 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1534 LINCOLN BLVD 4291022006 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 8.B.f Packet Pg. 431 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-70 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 AU 710 BROADWAY 4291022026 TA 52,450 one-story Von's with parking lot 1995 0.18 approved 300 unit project (710 Broadway) 1 AX 1553 4TH ST 4291025028 TA 7,474 Vacant bank site across DT station 0.00 common ownership; vacant building in DT 1 AX 1555 4TH ST 4291025012 TA 7,497 Vacant bank site across DT station 1973 0.01 common ownership; vacant building in DT 1 AY 1127 2ND ST 4292021010 WT 7,517 parking lot 0.00 approved 100% affordable housing - 42 units 1 AY 1129 2ND ST 4292021009 WT 7,490 parking lot 0.00 approved 100% affordable housing - 42 units 1 BG 1152 21ST ST 4276007021 MUB 3,491 rear parking lot for NOMA sushi and Veggie grill (2025 wilshire) 0.02 SB330 application; 46 units w/ offsite affordable at 1211-1215 19th 1 BG 2025 WILSHIRE BLVD 4276007027 MUB 14,987 one story Veggie grill 1969 0.10 SB330 application; 46 units w/ offsite affordable at 1211-1215 19th 1 BL 1115 WILSHIRE BLVD REAR 4281020029 MUB 13,949 rear parking lot 1927 0.18 (blank) 1 BL 1101 WILSHIRE BLVD 4281020012 MUB 8,559 one-story JP bar 1922 0.19 SB330 application; pending project (93 units) 1 BN 1819 SANTA MONICA BLVD 4276029011 GC 14,986 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BN 1350 19TH ST 4276029010 GC 7,495 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BN 1342 19TH ST 4276029009 R2 8,991 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BO 2911 SANTA MONICA BLVD 4267011022 MUBL 6,501 one story retail building 1926 0.20 approved 53 unit project (2901-2907 Santa Monica project) 1 BO 1347 YALE ST 4267011021 MUBL 3,266 one-story retail building 1926 0.25 approved 53 unit project (2901-2907 Santa Monica project) 1 BO 1349 YALE ST 4267011020 MUBL 9,368 one story multitenant retail building, two story apartment building w parking lot 1923 0.11 approved 53 unit project ( 2901-2907 Santa Monica project) 1 BP 1543 LINCOLN BLVD 4282028010 LT 7,497 one story vacant auto repair 1947 0.13 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BP 1547 LINCOLN BLVD 4282028009 LT 7,499 one story vacant auto repair 1999 0.43 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BP 1537 LINCOLN BLVD 4282028011 LT 7,496 one story vacant auto repair 1945 0.25 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BS 2002 21ST ST 4274026001 R2 7,533 one-story apartments 1949 0.10 approved Park Virginia Townhomes 19 units 1 BS 2008 21ST ST 4274026003 R2 7,130 one-story apartments 1953 0.11 approved Park Virginia Townhomes 19 units 1 BT 1840 14TH ST 4283030018 NC 7,524 100% affordable housing under construction 1962 0.26 approved affordable housing project 73 units 1 BT 1844 14TH ST 4283030017 NC 7,485 100% affordable housing under construction 1922 0.50 approved affordable housing project 73 units 1 BT 1848 14TH ST 4283030016 NC 7,525 100% affordable housing under construction 1968 0.00 approved affordable housing project 73 units 1 BU 1415 5TH ST 4291019021 TA 7,494 two story multitenant retail building 1980 0.00 approved 111 unit project (1415-1423 5th St) 1 BU 1423 5TH ST 4291019020 TA 7,525 two story multitenant retail building 1966 0.00 approved 111 unit project (1415-1423 5th St) 1 BV 1543 7TH ST 4291022014 TA 7,500 parking lot 1990 1.73 approved 100 unit project (1543-1547 7th St) 1 BV 1547 7TH ST 4291022013 TA 7,500 parking lot 0.00 approved 100 unit project (1543-1547 7th St) 1 BW 1547 6TH ST 4291023011 TA 7,505 one-story multi-tenant building, restaurant, office 1986 0.00 approved 140 unit project (part of 609 Colorado project) 1 BW 609 COLORADO AVE 4291023010 TA 14,982 one-story multi-tenant building, restaurant, office 1984 0.17 approved 140 unit project (part of 609 Colorado project) 1 BX 601 WILSHIRE BLVD 4292005029 WT 10,010 vacant one and two story buildings 1977 0.07 approved 40 units w/ 3 affordable (601-611 Wilshire) 1 BX 611 WILSHIRE BLVD 4292005026 WT 4,997 vacant one and two story buildings 1922 0.14 approved 40 units w/ 3 affordable (601-611 Wilshire) 1 BY 1650 LINCOLN BLVD 4290002008 LT 16,220 one-story retail, boxing fitness building 1954 0.00 approved 98 Units (1650-1660 Lincoln) 1 BY 1660 LINCOLN BLVD 4290002006 LT 7,570 one-story retail, boxing fitness building 1954 0.00 approved 98 Units (1650-1660 Lincoln) 1 BZ 1437 LINCOLN BLVD 4282027018 LT 7,485 one-story retail building 1949 0.00 approved 40 unit project (1437-1443 Lincoln) 1 BZ 1443 LINCOLN BLVD 4282027028 LT 7,510 one-story retail 1959 0.00 approved 40 unit project (1437-1443 Lincoln) 1 C 2501 WILSHIRE BLVD 4276001026 MUB 14,319 one-story commercial building with multiple retailers; corner parcel; with rear residential parking lot 1951 0.14 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 C 2515 WILSHIRE BLVD 4276001025 MUB 6,164 one-story multi-tenant commercial building 1941 0.49 SB330 application; 78 units w/ offsite affordable at 1215 19th 8.B.f Packet Pg. 432 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-71 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 C 2525 WILSHIRE BLVD 4276001027 MUB 10,347 one-story commercial building, Starbucks, Urgent Care, Postal Store; common ownership; corner parcel with rear residential parking 1970 0.44 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 CA 1313 6TH ST 4291009021 NV 15,010 parking lot 0.00 approved 64 unit project (1313-1325 6th St) 1 CA 1323 5TH ST 4291010029 NV 7,512 parking lot 0.00 approved 43 unit project 1 CH 1902 WILSHIRE BLVD 4276013020 MUB 4,989 one story retail/restaurant building (Thai dishes, salon, medical office) 1939 0.33 SB330 application; 71 units w/ offsite affordable in rear 1 CH 1908 WILSHIRE BLVD 4276013030 MUB 24,993 one-story retail/restaurant building (Thai dishes, salon, medical office) 1925 0.20 SB330 application; 34 affordable units; lot has been split with 100% affordable in rear 1 CI 1921 WILSHIRE BLVD 4276008014 MUB 15,015 one-story retail building (GAP) 1975 0.41 SB330 application; 60 units w/ 9 affordable 1 CI 1933 WILSHIRE BLVD 4276008015 MUB 10,520 one-story retail building (GAP) 1958 0.33 SB330 application; 60 units w/ 9 affordable 1 E 2906 SANTA MONICA BLVD 4267018026 MUBL 21,314 vacant two story office 1969 0.79 approved 46 unit project (2906-2918 Santa Monica Blvd) 1 E 2918 SANTA MONICA BLVD 4267018003 MUBL 7,021 vacant parking lot 1965 0.12 approved 46 unit project (2906-2918 Santa Monica Blvd) 1 P 1347 18TH ST 4276029026 GC 7,512 Honda dealership with surface inventory 1969 0.00 SB330 application; 41 units w/ 7 affordable 1 P 1801 SANTA MONICA BLVD 4276029048 GC 14,984 Honda dealership with surface inventory 1953 0.02 SB330 application; 41 units w/ 7 affordable 1 S 825 SANTA MONICA BLVD 4282010012 GC 7,505 Toyota dealership 0.00 pending project 48 units (825 Santa Monica) 1 S 825 SANTA MONICA BLVD 4282010013 GC 7,491 Toyota dealership 1951 0.01 pending project 48 units (825 Santa Monica) 1 S 825 SANTA MONICA BLVD 4282010014 GC 7,502 Toyota dealership 1951 0.00 pending project 48 units (825 Santa Monica) 1 1211 12TH ST 4282005053 R3 15,008 one story apartment buildings 0.00 approved 13 units 1 1434 14TH ST 4282022027 R3 7,500 1925 0.22 approved 6 unit condos 1 1021 GRANT ST 4284015017 R2 6,491 1928 0.42 approved 2 units 1 1133 OCEAN AVE 4292028001 OT 190,963 Miramar Hotel 1938 0.53 approved Miramar Project - 60 condo units 1 1431 COLORADO AVE 4282034009 MUBL 22,485 one-story marble store 1923 0.01 pending 50 unit project 1 129 SANTA MONICA BLVD 4291014024 BC 30,000 parking lot 1871 0.02 pending Ocean Avenue project - 100 units 1 610 CALIFORNIA AVE 4292005022 R2 5,002 1912 0.21 approved 3 condo units 1 OCEAN FRONT WALK/BAY STREET 4289025005 OF 23,222 vacant parking lot next to Casa del mar hotel 0.00 approved with 1828 ocean ave; formerly 1921 OFW (22 units) 1 OCEAN FRONT WALK/PICO BLVD 4290020045 OF 45,314 parking lot 0.00 approved 83 unit project 1 1840 17TH ST 4283032008 R2 7,490 1955 0.25 5 unit condos 1 1121 22ND ST 4276005022 R2 6,114 1924 0.03 approved 3 townhomes 1 SANTA MONICA BLVD/23RD STREET 4275006026 HMU 6,242 parking lot owned by Saint John's 0.00 pending Providence Saint John's Master Plan - 10 Units 1 1318 LINCOLN BLVD 4291008025 LT 15,003 parking lot 0.00 approved 43 unit project 1 1665 APPIAN WAY 4290018018 R3 4,430 residential 1914 0.37 pending 3 Unit townhome project 1 4268010017 MUC 64,297 one-story light industrial/creative office 0.00 approved 183 unit project - WS project 1 2102 5TH ST 4289010006 OP2 5,661 1911 0.02 3 unit condos 1 1754 10TH ST 4283018002 R2 7,511 1922 0.25 approved 3 apartment units 1 1649 CENTINELA AVE 4268006016 R2 6,313 single family dwelling 1948 0.25 approved 3 condo units 1 436 PIER AVE 4287027065 OP2 7,480 1911 0.25 3 unit condos 1 1900 20TH ST 4274019056 R2 7,575 single family dwelling 0.00 approved 3 condo units 8.B.f Packet Pg. 433 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-72 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 4287003017 OP2 7,973 0.00 3 unit condos 1 1707 CLOVERFIELD BLVD 4268014013 BTV 76,562 parking lot of Extra Space sotrage 1955 0.66 approved 63 units w/ 5 affordable 1 1342 BERKELEY ST 4267012009 R2 7,858 Vacant lot 0.00 100% affordable housing project w/ 8 units 1 1443 18TH ST 4275010016 MUBL 7,500 Vacant lot 1957 0.00 approved 11 condo units 1 711 COLORADO AVE 4291022012 TA 7,500 construction staging site 0.00 approved 100% affordable housing 1 1437 7TH ST 4291021029 NV 14,991 three story office building 1983 1.22 approved 65 unit project 1 1618 STANFORD ST 4268002005 MUC 20,016 one story office building 1950 0.20 approved 47 unit project 1 1238 7TH ST 4291006006 NV 7,500 one-story office 1912 0.00 approved 37 unit project 1 1557 7TH ST 4291022021 TA 7,500 one story brick office building 1959 0.03 approved AA project for 59 unit project 1 1427 5TH ST 4291019019 TA 15,007 one-story vacant retail building 1954 0.00 approved 92 unit project 1 1514 7TH ST 4291023002 TA 7,504 construction staging parking site 0.00 approved 100% affordable housing - 50 units 1 501 BROADWAY 4291019027 TA 15,007 one-story vacant retailer (Black tux) 0.00 approved 94 unit project 1 525 COLORADO AVE 4291024014 TA 7,483 one-story creative office 1960 0.00 approved 40 unit project 1 1437 5TH ST 4291019018 TA 7,484 parking lot 0.00 approved 52 unit project 1 1437 6TH ST 4291020016 NV 7,497 one story residence 0.00 approved 51 unit project 1 1527 17TH ST 4275012020 R2 7,500 single dwelling unit 1923 0.05 approved 3 condo units addition 1 949 10TH ST 4281025014 R2 7,484 1916 0.25 approved 3 condo units 1 1432 17TH ST 4282019007 R2 7,504 1959 0.08 approved 6 unit condos 1 918 5TH ST 4292015004 R2 7,520 1910 0.25 approved 3 condo units 1 2714 HIGHLAND AVE 4287019012 OP2 4,708 1912 0.27 approved duplex 1 1902 EUCLID ST 4283028010 R2 7,499 1940 0.23 approved triplex addition 1 2409 28TH ST 4270004017 R2 9,005 1937 0.13 approved duplex 1 1958 20TH ST 4274019001 R2 7,609 0.13 approved addition of 2 units 1 1512 EUCLID ST 4282032003 MUBL 7,500 vacant single family home 0.25 pending 10 unit project 1 2501 2ND ST 4287010011 OP2 6,478 0.08 approved 3 unit condos addition 1 1819 PICO BLVD 4274017019 NC 13,510 parking lot for religious institution 1950 0.38 approved 100% affordable housing 48 units 1 1949 17TH ST 4274015020 R2 7,747 Vacant lot 0.00 approved 5 condo units 1 2425 20TH ST 4273019001 R2 6,746 one story single family unit 1928 0.33 approved 3 condo units 1 817 16TH ST 4281001021 R2 7,481 one story single family dwelling 0.40 approved 3 condo units 1 1413 MICHIGAN AVE 4283013024 NC 17,992 Vacant lot 1905 0.07 approved 100% affordable housing (58 units) 1 1510 FRANKLIN ST 4267027057 R2 8,118 two story single family unit 1924 0.31 approved 3 unit condos 1 734 12TH ST 4280025015 NC 4,802 one story single family dwelling 1926 0.25 approved 3 condo units 1 1514 PRINCETON ST 4267022010 R2 4,999 one story single family dwelling 1940 0.25 approved 2 condo units 1 1319 CENTINELA AVE 4267014026 R2 9,274 two story single family unit 1929 0.49 approved 6 unit condos 1 1448 7TH ST 4291020008 NV 7,498 two story apartment buildings w parking lot 1952 0.07 approved 8 unit project 1 1518 7TH ST 4291030003 NV 7,489 two story residential 1957 0.72 Pending 100 unit project 1 1546 9TH ST 4282028007 R3 7,503 one story single family unit 1909 0.25 pending 9 unit apartments 1 1302 6TH ST 4291010027 NV 18,521 two story office 1978 0.13 SB330 application; 80 units w/ offsite at 1333 7th 1 2537 LINCOLN BLVD 4284008016 GC 19,239 closed car wash 1965 0.17 SB330 application; 49 units w/ 5 affordable 1 2601 LINCOLN BLVD 4285001030 MUBL 203,990 one story Gelsons shopping center; multiple tenants 1956 0.35 SB330 application; 521 units w/ 53 affordable 1 1333 7TH ST 4291008018 NV 7,510 small site; single dental tenant; long standing owner/tenant 1978 1.33 SB330 application; 100% affordable receiver site of 38 units 8.B.f Packet Pg. 434 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-73 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 1407 7TH ST 4291021027 NV 15,000 One story retail building 1923 0.128 pending project 60 units with 3KSF 2 AH 1353 OLYMPIC BLVD 4283008001 MUBL 10,144 Synder Diamond parking lot 0.02 expressed past interest; prominent corner 2 AH 1654 14TH ST 4283008004 MUBL 15,011 Synder Diamond 1975 0.31 expressed past interest; prominent corner 2 AH 1660 14TH ST 4283008018 MUBL 21,369 Synder Diamond 1925 1.17 expressed past interest; prominent corner 2 AN 1311 5TH ST 4291010019 NV 7,498 parking lot for retail building 1939 0.68 low scale old building Downtown; common ownership 2 AN 1313 5TH ST 4291010020 NV 7,510 one-story retail building 0.02 low scale old building Downtown; common ownership 2 BI 1519 COLORADO AVE 4282035010 MUBL 22,498 one-story creative office 1957 0.48 high potential with across st access to expo; adjacent parcel at 1544 16th St is parking lot with common ownership 2 CC 1317 WILSHIRE BLVD 4281012025 MUB 22,535 Rite Aid 1940 0.15 high potential with parking lot; underutilized site; single tenant 2 G 2848 COLORADO AVE 4268002012 MUC 11,927 one-story light industrial 1952 0.13 prior residential project withdrawn due to DA process 2 G 2878 COLORADO AVE 4268002011 MUC 18,020 one-story light industrial 1959 0.24 prior residential project withdrawn due to DA process 2 G 2902 COLORADO AVE 4268002013 MUC 82,310 one-story light industrial 1938 0.23 prior residential project withdrawn due to DA process 2 G 2912 COLORADO AVE 4268002003 MUC 9,597 one-story light industrial 1963 0.86 prior residential project withdrawn due to DA process 1 H 3025 OLYMPIC BLVD 4268010018 MUC 54,556 one-story creative office/light industrial building 0.00 adjacent to approved development; owned by known residential developer; pending application for residential 345 units 2 1244 7TH ST 4291006007 NV 7,500 Office building with dental tenants 0.83 low scale office Downtown with parking in rear; adjacent to approved residential project on same size lot 2 1301 WILSHIRE BLVD 4281012022 MUB 60,051 Von's 1966 0.15 high potential parking; has expressed interest in past; single tenant 2 1327 5TH ST 4291010017 NV 7,497 one-story retail building 1930 0.62 low scale retail Downtown across 4th/5th Arizona; owned by housing provider; adjacent to approved residential project on same size lot 2 1401 WILSHIRE BLVD 4281011028 MUB 21,271 one-story US Bank Building with rear parking lot 1931 0.45 adjacent parking lot; not on HRI; one story single tenant bank with high potential 2 1501 WILSHIRE BLVD 4281005026 MUB 32,561 One story vacant retail formerly Santa Monica Town Car with large rear parking lot 1932 0.35 underutilized parking lot; fronting Wilshire Blvd with access; vacant building 2 2723 LINCOLN BLVD 4285001032 MUBL 20,599 34 Degrees North Fitness and one-story auto repair 1955 0.41 lots of parking; single story 2 625 ARIZONA AVE 4291006027 NV 22,500 one-story office building 1938 0.54 low scale office Downtown; corner lot; prior development inquiry 2 626 WILSHIRE BLVD 4291006001 NV 15,000 711 strip mall 1959 0.09 High; location on corner; with parking lot 2 2225 COLORADO AVE 4275016021 MUBL 35,990 one-story R&D (Kite Pharma) building with parking lot 1972 1.02 one-story R&D underdeveloped; kitepharma looking for new space 2 631 COLORADO AVE 4291023009 TA 14,982 one-story Bay Films building 1937 0.36 low scale office Downtown; previous inquiries about redevelopment opportunities; access to Expo makes it high potential; demolition permit for existing building applied for 3 AS 1410 LINCOLN BLVD 4291021002 LT 7,508 parking lot 0.01 common ownership to 720 Santa Monica Blvd; owned by commercial investment company 3 AS 718 SANTA MONICA BLVD 4291021001 LT 7,497 commercial building; balloon place and common ownership 1924 0.52 low scale building at edge of DT; in proximity to other residential development; common ownership; owned by commercial investment firm 3 R 1237 LINCOLN BLVD 4282009027 LT 7,514 Motel 1907 0.13 old motel; tenant does not appear to have longetivity 3 R 1243 LINCOLN BLVD 4282009014 LT 7,502 Motel 1949 0.48 old motel; tenant does not appear to have longetivity 3 700 COLORADO AVE 4290001016 TA 20,139 One-story warehouse building 1962 0.48 Recently for sale; vacant building; large site in downtown 3 718 COLORADO AVE 4290001023 LT 21,881 former Fisher lumber site vacant 1965 0.08 vacant building; site for sale 3 1640 5TH ST 4290011017 TA 21,973 Three story office building 1976 0.82 Comma building; developer has expressed past interest in development 8.B.f Packet Pg. 435 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-74 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288009900 R4 12,477 City parking lot on main south of Ashland 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288010900 R4 16,469 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288011900 R3 23,118 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288012902 R3 26,951 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288013905 R3 26,348 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288014901 R3 40,256 City parking lot on main (approximately 11.8 Ksf) rest is affordable housing 1947 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288015901 R3 50,158 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AP 1301 4TH ST 4291011909 BC 32,245 Bank of America; Chase bank; parking lot 1959 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011900 NV 8,977 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011901 NV 5,989 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011902 NV 7,520 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011903 NV 7,480 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011904 NV 7,520 Bank of America; Chase bank; parking lot 2013 0.00 4th/Arizona withdrawn project 4 AP 1326 5TH ST 4291011905 NV 7,481 Bank of America; Chase bank; parking lot 2013 0.00 4th/Arizona withdrawn project 4 AP 1333 4TH ST 4291011910 BC 20,244 Bank of America; Chase bank; parking lot 1961 0.00 4th/Arizona withdrawn project 4 AP 1334 5TH ST 4291011908 NV 7,508 Bank of America; Chase bank; parking lot 2013 0.00 4th/Arizona withdrawn project 4 AQ 1318 4TH ST 4291012900 BC 22,484 Parking Structure 3 0.00 RFP for affordable housing issued 4 AQ 1320 4TH STREET 4291012901 BC 7,504 Parking Structure 3 0.00 RFP for affordable housing issued 4 BQ 1217 14TH ST 4282003901 R3 7,510 public parking lot 12 behind petco 0.00 city owned parking lot - no leases with outside parties 4 BQ 1217 14TH ST 4282003900 R3 7,497 public parking lot 12 behind petco 0.00 city owned parking lot - no leases with outside parties 4 I 26TH STREET/OLYMPIC BLVD 4268014900 CAC 540 Bergamot Arts Center 0.00 existing Bergamot Arts Center; lease agreement with arts uses; must replace groundfloor arts uses 4 I 26TH STREET/OLYMPIC BLVD 4268013919 CAC 409,713 Bergamot Arts Center 0.00 existing Bergamot Arts Center; lease agreement with arts uses; must replace groundfloor arts uses 4 1146 16TH STREET 4281005900 R2 7,499 public parking lot 8 behind Café Zella (city owned) 0.00 city owned parking lot - no leases with outside parties 4 1217 EUCLID STREET 4282004900 R3 14,994 public parking lot 7 behind LaMonarca Bakery 0.00 city owned parking lot - no leases with outside parties 5 AB 1421 LINCOLN BLVD 4282027021 LT 7,516 parking lot for CVS pharmacy 0.00 common ownership to adjacent parcel 5 AG 4282035002 MUBL 7,482 parking lot for automotive service center building 1522-1530 Broadway 0.02 common ownership with adjacent parcel 5 AJ 3101 LINCOLN BLVD 4285036002 GC 4,820 parking lot for georges burgers 0.00 single tenant; underutilized parcel with common ownership 5 B 4267007003 MUB 4,394 New Balance store parking lot 0.00 past interest in development; common ownership with adjacent parcels 5 B 2616 WILSHIRE BLVD 4267007002 MUB 4,393 New Balance store parking lot 0.00 past interest in development; common ownership with adjacent parcels 5 BR 907 SANTA MONICA BLVD 4282011033 GC 2,494 small private parking lot for auto repair and Tuesday morning 0.00 common ownership- could be developed with Tuesday Morning site 5 CJ 1453 25TH ST 4275001013 MUBL 7,002 parking lot for Helen's cycles 0.00 common ownership see 1457 25th 8.B.f Packet Pg. 436 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-75 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 5 F 1547 26TH ST 4267022018 OC 8,107 parking lot for one story vacant commercial office building 0.00 common ownership - see 2601 Colorado 5 F 2615 COLORADO AVE 4267022015 OC 5,966 parking lot for one story vacant commercial office building 0.02 common ownership to 3 other parcels - see 2601 Colorado 5 K 3125 PICO BLVD 4274034023 NC 5,005 parking for closed Valentinos restaurant 0.00 common ownership with adjacent parcel; vacant building 5 M 2306 SANTA MONICA BLVD 4275005002 MUBL 7,002 parking lot for 2300 santa monica (cynergy) 0.00 common ownership with adjacent parcel; single tenant 5 N 4275009012 MUBL 7,500 parking lot for one-story to two story building with iron gym and creative office tenants 0.01 recently sold building; location on Broadway near other residential uses make it likely it will turn over; common ownership (see 1457 19th street) 5 O 4276022001 MUBL 5,229 parking lot for laundromat 0.01 common ownership with 3 adjacent parcels; corner lot 5 O 4276022004 MUBL 5,196 parking lot for auto repair 0.09 common ownership with 3 adjacent parcels; corner lot 5 U 1348 14TH ST 4282015011 GC 7,515 parking lot for Truxtons restaurant and Bar 0.01 common ownership w/ adjacent parcels (1327-1333 Santa Monica Blvd) 5 Y 1214 SANTA MONICA BLVD 4282023022 GC 2,509 parking lot with vacant auto repair 1975 0.05 common ownership w/ adjacent parcel; underutilized; one story autorepair 5 Y 1218 SANTA MONICA BLVD 4282023021 GC 7,504 parking lot with vacant auto repair 1925 0.11 common ownership w/ adjacent parcel; underutilized; one story autorepair 5 4268001038 BTV 38,548 Lionsgate parking lot 0.00 SCAG Helpr tool classifies this as a vacant site; owned by separate owner than Lionsgate parcel; used as Lionsgate parking 5 4283010001 MUBL 7,495 parking lot for one story vacant office building 0.00 could be developed with adjacent vacant parcel on corner 5 1541 15TH ST 4282035014 MUBL 7,510 parking lot for SM Conservatory 0.00 property owner expressed interest in 100% affordable 5 1716 BERKELEY ST 4268009019 CCS 11,703 parking lot serving underparked industrial uses 0.05 underutilized lot; medium size could be developed for affordable housing; owned by housing provider 6 AD 12TH STREET AND BROADWAY 4282032002 MUBL 7,487 Ford auto storage parking lot 0.00 common ownership with adjacent parcel; southwest corner 6 AD 1222 BROADWAY 4282032001 MUBL 7,487 Ford auto storage parking lot 1956 0.02 common ownership with adjacent parcel; southwest corner 6 AE 1544 14TH ST 4282033010 MUBL 7,484 Paint and body shop auto storage (see 1538 14th st) 1957 0.04 common ownership with adjacent parcel used as parking lot; one story service bays 6 AF 12TH STREET AND BROADWAY 4282033018 MUBL 4,986 Ford auto storage parking lot 0.08 common ownership with adjacent parcel; southeast corner 6 AF 12TH STREET AND BROADWAY 4282033020 MUBL 4,992 Ford auto storage parking lot 0.06 common ownership with adjacent parcel; southeast corner 6 AF 1310 BROADWAY 4282033019 MUBL 4,987 Ford auto storage parking lot 0.07 common ownership with adjacent parcel; southeast corner 6 AK 2700 LINCOLN BLVD 4287017043 GC 5,609 parking lot for Big Q's auto repair - common ownership to 3 adjacent parcels 1946 0.00 for sale property; advertised for redevelopment potential; common ownership to adjacent parcel 6 AZ 3204 LINCOLN BLVD 4287032015 GC 2,014 auto repair shop parking lot 0.00 adjacent common ownership (see 3204 lincoln); one story auto with parking lot 6 AZ 3204 LINCOLN BLVD 4287032016 GC 1,521 auto repair shop parking lot 1973 0.00 adjacent common ownership (see 3204 lincoln); one story auto with parking lot 6 BB 1348 18TH ST 4276030010 GC 7,506 Honda auto storage 1977 0.00 common ownership with adjacent 2 parcels used also as parking; comprises one of many surface lots for Honda 6 BF 832 SANTA MONICA BLVD 4282027003 GC 7,493 Toyota auto storage 1958 0.02 common ownership with adjacent 888 SM Blvd and R2 parcels (1418-1424 9th); offsite lot - main dealership across the street on Lincoln 6 BK 1411 17TH ST 4275011023 GC 7,500 off-site parking lot for auto storage 1921 0.25 for sale property; no common ownership but adjacent to vacant two story auto showroom building at 1710 Santa Monica 6 CB 1447 18TH ST 4275010015 MUBL 7,500 parking lot for Herman's auto repair 0.26 large site; auto storage; 3 adjacent parcels with common ownership (see 1449 18th) 6 CB 1807 BROADWAY 4275010013 MUBL 7,500 parking lot for Herman's auto repair 0.01 large site; auto storage; 3 adjacent parcels with common ownership (see 1449 18th) 6 T 1201 SANTA MONICA BLVD 4282014026 GC 22,473 BMW auto storage 1969 0.08 common ownership with adjacent parcel - large separte inventory lot; main dealership is across alley at 1187 Santa Monica Blvd 6 T 1337 12TH ST 4282014016 GC 14,994 BMW auto storage 1964 0.02 common ownership with adjacent parcel - large separte inventory lot; main dealership is across alley at 1187 Santa Monica Blvd 6 W 1418 16TH ST 4282020004 GC 7,494 Lexus parking lot - used car lot/service lot 1964 0.00 lot is used to sell used cars; Main Lexus dealership is at 1501 Santa Monica Blvd; dealership may consolidate its operations 8.B.f Packet Pg. 437 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-76 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 6 W 1530 SANTA MONICA BLVD 4282020001 GC 7,510 Lexus parking lot - used car lot/service lot 1952 0.00 lot is used to sell used cars; Main Lexus dealership is at 1501 Santa Monica Blvd; dealership may consolidate its operations 6 W 1530 SANTA MONICA BLVD 4282020002 GC 7,497 Lexus parking lot - used car lot/service lot 1952 0.00 lot is used to sell used cars; Main Lexus dealership is at 1501 Santa Monica Blvd; dealership may consolidate its operations 6 X 1308 SANTA MONICA BLVD 4282022024 GC 9,711 offsite auto storage lot for Suburu 1924 0.02 in 2020 was used for Mercedes Benz; currently used for Suburu; main dealership is at 1229 Santa Monica 6 X 1415 EUCLID ST 4282022023 GC 7,499 offsite auto storage lot for Suburu 1921 0.00 in 2020 was used for Mercedes Benz; currently used for Suburu; main dealership is at 1309 Santa Monica 6 Z 1335 LINCOLN BLVD 4282010019 LT 7,482 Toyota service repair lot 0.02 common ownership with adjacent parcel 6 Z 1339 LINCOLN BLVD 4282010018 LT 7,509 Toyota auto storage - service center lot 1913 0.03 common ownership with adjacent parcel 6 1415 12TH ST 4282023025 GC 37,478 offsite overflow Ford service & repair auto storage lot 1965 0.13 off-site overflow service and lot for Ford; large parcel; mostly surface parking with service bays; owned by Real estate developer 7 AI 1901 WILSHIRE BLVD 4276008010 MUB 10,498 one-story vacant House of Billiards building 1938 0.33 vacant space; corner parcel; for sale with 1141 19th St 7 AK 2720 LINCOLN BLVD 4287017044 GC 8,022 one story Big Q's auto repair 1969 0.21 active sales; advertised for redevelopment; Common ownership to 3 adjacent parcels - see 2700 lincoln 7 BC 3307 PICO BLVD 4274036002 NC 5,015 one story retail building 1938 0.48 5000 sf small parcel size; adjacent properties 3311, 3317 Pico also being sold concurrently 7 BC 3311 PICO BLVD 4274036003 NC 2,502 one story retail building 1948 0.58 small parcel size; adjacent sites 3307, 3317 Pico being sold concurrently 7 BC 3317 PICO BLVD 4274036027 NC 6,777 one-story auto repair shop 1974 0.16 small parcel size; adjacent parcels 3307, 3311 Pico being sold concurrently 7 BD 3018 PICO BLVD 4270006041 NC 5,958 one-story retail building 1950 0.68 all 3 adjacent parcels for sale (3018-3030 Pico) 7 BD 3024 PICO BLVD 4270006042 NC 5,775 two-story apartment building 1957 0.89 all 3 adjacent parcels for sale (3018-3030 Pico) 7 BD 3026 PICO BLVD 4270006043 NC 5,579 two story commercial retail building 1955 0.88 all 3 adjacent parcels for sale (3018-3030 Pico) 7 BE 1450 20TH ST 4275009009 MUBL 22,500 Part of Big Jos burgers 0.54 for sale property; with adjacent parcels; large underutilized site 7 BE 1925 BROADWAY 4275009010 MUBL 7,500 parking lot for Big Jos burger 1957 0.42 for sale property; very undertilized site with single story tenant and large lot; advertised for redevleopment opportunity 7 N 1457 19TH ST 4275009011 MUBL 15,000 one story iron gym and creative office with parking lot (common ownership) 1948 0.28 recently sold building; location on Broadway near other residential uses make it likely it will turn over; common ownership (see 1457 19th street) 7 V 1619 1/2 SANTA MONICA BLVD 4282018010 GC 3,212 vacant car sales lot; recently sold 1960 0.26 common ownership with adjacent parcel; recently sold 7 V 1619 SANTA MONICA BLVD 4282018012 GC 4,282 vacant car sales lot; recently sold 1977 0.26 common ownership with adjacent parcel; recently sold 7 1634 20TH ST 4275025002 IC 19,662 two-story office building 1925 0.05 older building; In IC north of Olympic Boulevard adjacent to bike path; proximity to existing residential; for sale; with preassessment for affordable housing already done 7 1703 OCEAN PARK BLVD 4273023032 NC 14,021 one-story Burger restaurant and laundrymat 1974 0.85 one-story multitenant retail building with large parking; corner large parcel; recently sold 7 2316 LINCOLN BLVD 4289001007 GC 14,104 one-story retail (recliner sales) building 1953 0.14 on Lincoln Boulevard with high development potential; larger parcel on corner 7 2510 PICO BLVD 4270001023 NC 18,171 car wash 1960 0.28 large parcel with access from side street; new owner indicate future residential development interest 8 AB 1411 LINCOLN BLVD 4282027029 LT 14,994 CVS pharmacy 1948 0.34 in DT; adajcent parcel is parking lot 8 AE 1323 COLORADO AVE 4282033011 MUBL 22,495 Paint and body shop 1952 0.09 location is ideal as it is located across from park; common ownership with adjacent parcels; one story service bays 8 AV 1719 WILSHIRE BLVD 4276010037 MUB 18,769 one story Enterprise car rental 0.13 one story with parking lot; common ownership with adjacent parcel at 1723 wilshire; large site 8 AW 2202 BROADWAY 4275016007 MUBL 35,989 one-story Ferguson plumbing and lighting 1950 0.28 one story single tenant light industrial; common ownership with adjacent parcel 8 AW 2218 BROADWAY 4275016005 MUBL 19,800 one-story Ferguson plumbing and lighting 1947 0.54 proximity to redeveloping residential parcels across; large sized lot 8 BF 888 SANTA MONICA BLVD 4282027032 GC 15,005 Toyota auto storage 0.57 common ownership with adjacent parcel 8 CD 2711 WILSHIRE BLVD 4266016100 MUB 28,663 Chase bank building with rear parking 1977 0.32 sheer size of lot may make this property desirable for redevelopment; adjacent rear parking lot see 1135 Princeton 8.B.f Packet Pg. 438 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-77 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 8 L 2601 WILSHIRE BLVD 4266016054 MUB 15,365 76 gas station 0.00 large size parcel; corner; access to alley; gas station may make it undesirable to sell; common ownership with Sonny Mclean 8 1020 WILSHIRE BLVD 4282007025 MUB 17,502 one-story Belcampo restaurant building 1960 0.46 single tenant; low scale; next to Apartments.com; large parcel; could be developed with 1018 Wilshire but no common ownership 8 1025 WILSHIRE BLVD 4281027033 MUB 22,517 one-story El Cholo restaurant 1932 0.15 large parcel small restaurant; lots of parking 8 1100 SANTA MONICA BLVD 4282024026 GC 14,992 Toyota preowned center 1942 0.26 large parcel; corner 8 1102 BROADWAY 4282031032 MUBL 22,486 small one story office tenants; appears mostly vacant 1975 0.45 large parcel on corner; includes parking 8 1224 5TH ST 4291004016 NV 14,986 one story office building 1962 0.20 doublewide lot 8 1234 WILSHIRE BLVD 4282005001 MUB 14,993 one-story Ulta building 1946 0.37 large lot; low scale; single tenant; corner parcel 8 1420 WILSHIRE BLVD 4282003001 MUB 29,976 one-story Audio and Video center and Bank of America 1953 0.67 corner parcel; two tenants; rear adjacent parking parcel owned by Bank of America 8 1453 14TH ST 4282021013 MUBL 22,518 one-story building with 3 tenants, Paint lab and small creative office 1925 0.43 low scale building; new development adjacent to north 8 1624 LINCOLN BLVD 4290001012 LT 22,288 car wash 1972 0.09 next to affordable housing; part of development trends occuring on Lincoln 8 1701 WILSHIRE BLVD 4276010035 MUB 13,497 one-story vacant Mens Warehouse 1961 0.49 single tenant is bankrupt; vacant building; alley access; corner 8 1907 WILSHIRE BLVD 4276008023 MUB 15,009 one-story restaurant (Chandi) 1966 0.31 prospective owners with interest to redevelop; single tenant; one story 8 2020 WILSHIRE BLVD 4276014025 MUB 19,574 one-story restaurant and nightclub (Opaque Restaurant and Senator Jones club) 1955 0.10 rear parcel is R2 parking lot; low scale; few tenants; could be developed in conjunction with 2030 Wilshire but no common ownership 8 2230 BROADWAY 4275016024 MUBL 21,600 one story creative office building 1948 0.41 vacant space; large parcel; single story 8 2308 BROADWAY 4275016028 MUBL 27,773 one story creative office building 1948 0.35 large lot; proximity to redeveloping residentail across 8 2411 PICO BLVD 4274006023 MUBL 17,664 one story auto repair shop 1966 0.14 large one story auto repair with parking; adjacent to residential; large parcel; single tenant 8 2520 SANTA MONICA BLVD 4275001024 MUBL 20,962 one-story Goodwill building 1962 1.17 large parcel on corner; single tenant 8 2730 SANTA MONICA BLVD 4267020026 MUBL 28,573 one-story AAA building 1965 0.33 access to side street; large parcel; underutilized with access to transit 8 2802 SANTA MONICA BLVD 4267019028 MUBL 14,451 one-story office (roque and mark) building 1965 0.43 two frontages with rear parking; doublelot on corner; access to alley; single tenant 8 2828 WILSHIRE BLVD 4267005009 MUB 29,264 one-story commercial building, Vitamin Store and vacant restaurant space 1949 0.25 big parcel; two frontages 8 2914 WILSHIRE BLVD 4267004015 MUB 25,528 two-story LA mattress store with office 1949 0.66 one story retail with office above; multiple tenants; rear parking; larger parcel 8 2933 SANTA MONICA BLVD 4267011025 MUBL 19,147 one story Wine Expo 1948 0.18 two frontages; single tenant 8 1651 16TH ST 4283010900 MUBL 161,263 vacant SMMUSD headquarters building 1976 0.00 SMMUSD indicated interest in redeveloping for worker housing 9 BA 2800 LINCOLN BLVD 4287017045 GC 21,519 one story car wash 1961 0.19 large parcel decent size; single tenant; common ownership with parcel 4287017018 9 BR 901 SANTA MONICA BLVD 4282011034 GC 15,006 one-story Tuesday Morning store 1976 0.17 large parcel; corner parcel; single tenant 9 CX 1832 FRANKLIN ST 4268011006 MUC 17,921 one story creative office 1951 0.12 owner inquiry on site history; demolition of existing building applied for recently; new ownership in LLC 9 CX 3122 NEBRASKA AVE 4268011004 MUC 20,010 one story light industrial 1950 0.32 large parcel; recently acquired with adjacent parcels with LLC 9 1724 STANFORD ST 4268003003 MUC 31,503 one story light industrial 1927 0.01 appears to be Volkswagen off site storage lot and service bays 9 1740 STANFORD ST 4268003002 MUC 29,308 one story creative office 1957 0.22 large parcel; acquired into LLC; ownership by developer 10 AE 1538 14TH ST 4282033009 MUBL 7,485 Paint and body shop 1955 0.00 common ownership with adjacent parcel; one story service bays 10 AG 1520 BROADWAY 4282035001 MUBL 7,510 one-story auto parts building 1976 0.49 common ownership with adjacent parking lot parcel; building seems to be used only for storage; corner parcel with alley access 10 AJ 3101 LINCOLN BLVD 4285036001 GC 4,749 one-story Georges burgers restaurant 1968 0.49 large parcel on corner; single tenant; common ownership with parking lot parcel 8.B.f Packet Pg. 439 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-78 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 10 AV 1723 WILSHIRE BLVD 4276010025 MUB 7,500 parking lot for Enterprise Rental 1976 0.06 recently sold with 1719 Wilshire; enterprise rental 10 AZ 3204 LINCOLN BLVD 4287032014 GC 1,988 one story auto repair shops 1960 0.15 adjacent common ownership (see 3204 lincoln); one story auto with parking lot 10 BB 1719 SANTA MONICA BLVD 4276030011 GC 14,986 Honda dealership with surface inventory 1977 0.07 common ownership with adjacent 2 parcels (1344-1348 18th St); main dealership at 1337 Euclid/1301 Santa Monica Blvd 10 BJ 2624 WILSHIRE BLVD 4267007004 MUB 4,405 one-story restaurant 1932 0.15 common ownership to adjacent 2 parcels 10 BJ 2628 WILSHIRE BLVD 4267007005 MUB 4,404 one-story mathnasium and salon 1959 0.29 common ownership to adjacent 2 parcels 10 BJ 2636 WILSHIRE BLVD 4267007006 MUB 5,481 one-story mathnasium and salon 1949 0.28 common ownership to adjacent 2 parcels 10 BK 1710 SANTA MONICA BLVD 4275011025 GC 10,000 two-story vacant building 1946 0.49 vacant auto showroom with parking lot; recently sold 10 BR 911 SANTA MONICA BLVD 4282011015 GC 5,004 part of Tuesday morning site 1963 0.25 common ownership to Tuesday morning parking lot site 10 CB 1449 18TH ST 4275010014 MUBL 7,500 parking lot for Herman's auto repair 0.00 large site; auto storage; 3 adjacent parcels with common ownership (see 1449 18th) 10 CJ 1457 25TH ST 4275001012 MUBL 7,002 one-story Helen's cycle 1963 0.40 one story; single tenant; with rear parking lot 10 D 3011 SANTA MONICA BLVD 4267012003 MUBL 7,187 small one story dentist 1953 0.16 common ownership with adjacent parcel developed with old office 10 D 3017 SANTA MONICA BLVD 4267012004 MUBL 7,214 two story office 1969 0.15 common ownership with adjacent parcel 10 F 2601 COLORADO AVE 4267022017 OC 6,066 one story vacant commercial building 1946 0.33 currently vacant; common ownership to 3 other adjacent parcels (see 2601 Colorado) 10 F 2615 COLORADO AVE 4267022016 OC 5,977 one-story vacant commercial building 0.35 vacant building, for lease; common ownership to 3 other parcels (see 2601 Colorado) 10 J 2008 PICO BLVD 4273003002 NC 2,497 one-story campos taco with lot 0.00 large lot with parking; common ownership; single tenant 10 J 2008 PICO BLVD 4273003001 NC 4,722 one-story campos taco with lot 1948 0.15 large lot with parking; common ownership; single tenant 10 J 2010 PICO BLVD 4273003003 NC 6,491 one-story campos taco with lot 1949 0.13 large lot with parking; common ownership; single tenant 10 K 3115 PICO BLVD 4274034031 NC 7,502 closed Valentino's restaurant 1945 0.32 common ownership with adjacent parcel; vacant building 10 L 2615 WILSHIRE BLVD 4266016055 MUB 5,508 one story bar Sonny Mcleans 1940 0.30 sonny mcleans; common ownership with adjacent 76 station 10 M 2312 SANTA MONICA BLVD 4275005020 MUBL 5,553 one-story retail store - cynergy cycle 1940 0.40 common ownership with adjacent parcel; single tenant 10 O 2439 SANTA MONICA BLVD 4276022002 MUBL 5,195 one story laundromat 1948 0.32 common ownership with 3 adjacent parcels; corner lot 10 O 2445 SANTA MONICA BLVD 4276022003 MUBL 5,207 one story auto repair 1946 0.28 common ownership with 3 adjacent parcels; corner lot 10 Q 1414 18TH ST 4275011002 GC 7,500 parking for vacant Honda service repair 0.27 formerly the Honda service center at 1726 Santa Monica Blvd which has since left; large site in combination with adjacent parcel 10 Q 1726 SANTA MONICA BLVD 4275011001 GC 15,000 two-story vacant Honda service center 1976 0.28 vacant; common ownership with 3 adjacent parcels 10 U 1323 SANTA MONICA BLVD 4282015013 GC 4,998 one-story Truxton restaurant and Bar 1923 0.10 common ownership with rear and adjacent parking parcel; two tenants on-site; corner parcel 10 W 1530 SANTA MONICA BLVD 4282020003 GC 7,509 Lexus auto storage 1952 0.00 auto storage for service center 10 Y 1200 SANTA MONICA BLVD 4282023023 GC 4,978 parking lot with vacant auto repair 1962 0.03 common ownership w/ adjacent parcel; underutilized; one story autorepair 10 3232 SANTA MONICA BLVD 4267015027 MUBL 13,878 one story retail building (keyboard store) 1968 0.42 single tenant; large parcel; corner lot; 11 1140 7TH ST 4292005007 R2 7,497 St Monica Church parking lot DA indicates that affordable housing shall be constructed as priority 11 1257 CENTINELA AVE 4267001016 R2 42,631 Church of Jesus Christ parking lot 1948 large parking lot 11 1343 OCEAN PARK BLVD 4284025028 R3 25,777 Mt Olive Church with large parking 1962 has express interest; half of site is parking lot 11 3114 3RD ST 4287038027 OP2 22,603 St Clement Church parking 1956 large separate parking 8.B.f Packet Pg. 440 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-79 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 11 801 WASHINGTON AVE 4281033024 R2 15,012 parking lot for Saint Pauls Lutheran Church (blank) 11 BH 925 CALIFORNIA AVE 4281029012 R2 4,993 Vintage Church trinity house parking lot 1967 double lot 11 BH 929 CALIFORNIA AVE 4281029011 R2 5,017 Vintage Church trinity house parking lot 1967 double lot 12 CN 4276012027 R2 22,500 large parking lot for Rite Aid off Pico existing parking lot in rear of retail diagonal across from Rite Aid; large size lot 12 S 4282010011 R3 7,493 parking lot for Toyota A-Lot; parking in rear of 825 SMB project 12 BA 4287017018 OP2 5,659 parking lot for car wash on lincoln 1961 common ownership to vacant car wash fronting Lincoln but zoned OP2 12 CC 1122 14TH ST 4281012024 R2 37,532 Rite aid parking lot off Wilshire common ownership to Rite Aid fronting Wilshire 12 CD 1135 PRINCETON ST 4266016045 R2 21,913 Chase Bank parking lot common ownership to Chase bank; large parcel 12 AI 1143 19TH ST 4276008009 R2 7,192 parking lot for sale; with 1901 Wilshire; common ownership 12 B 1215 26TH ST 4267007030 R2 6,377 parking lot for New balance store A-Lot; parking lot for New balance; common ownership 12 CM 1219 PRINCETON ST 4267006012 R2 6,983 parking lot for multi tenant retail A-Lot; common ownership to front wilshire parcel; Pacific Dining Car vacant restaurant 12 CN 1223 18TH ST 4276012018 R2 7,486 large parking lot for Rite Aid off Pico existing parking in rear of retail; large adjacent common ownership in front but riteaid may not leave 12 Q 1418 18TH ST 4275011003 R2 7,500 parking structure for former Honda service center service center appears to have moved; common ownership with adjacent two parcel 12 BF 1418 9TH ST 4282027004 R3 7,492 Toyota parking lot 1925 A-Lot; common ownership to 2 other parcels 12 1424 9TH ST 4282027005 R3 7,503 CVS parking lot A-Lot 12 1847 16TH ST 4283032024 R2 6,040 vacant lot undeveloped; no structures 12 528 SAN VICENTE BLVD 4293004010 R2 11,074 vacant lot undeveloped; no structures 12 621 PACIFIC ST 4289005013 OP2 5,865 vacant lot undeveloped; no structures 8.B.f Packet Pg. 441 Attachment: Appendix F SSI Table Redline June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.g Packet Pg. 442 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 1:Introduction 8.B.g Packet Pg. 443 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 3 City of Santa Monica | 2021 - 2029 Housing Element A. Santa Monica’s Housing Strategy Santa Monica’s 2021-2029 Housing Element represents the City’s longstanding commitment to affordable housing, tenant protection, housing and services for special needs groups, homeless services, sustainable development, and fair housing. With a renewed emphasis on equity and the mandate to Affirmatively Further Fair Housing, the housing plan augments the adopted Land Use and Circulation Element (LUCE) by enhancing housing mobility and expanding housing choice in high opportunity areas that have historically excluded diverse populations, which may be areas that are not immediately adjacent to major transportation systems. The Housing Element also reflects the City’s emergence from the COVID-19 pandemic and the socioeconomic inequities that have manifested in the lack of housing stability that disproportionately affected Black, Indigenous, and people of color (BIPOC) and lower-income households. This is an opportunity for the City to reflect and assess the City’s approach to housing and to take a leadership role in creating solutions to address affordable housing production and housing stability in line with Santa Monica’s values to secure livable and affordable housing opportunities for all. Chapter 1: Introduction This Housing Element is built around 4 key principles CorePrinciples Locate housing close to daily services and amenities like transportation, jobs, parks, and schools. Facilitate equitable housing access to all neighborhoods by expanding access to housing opportunities and overcoming patterns of segregation. Promote greater housing stability for existing residents at risk of displacement. Increase housing production for all, with an emphasis on affordable housing. 8.B.g Packet Pg. 444 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 4Chapter 1 | Introduction This Housing Plan continues to reinforce Santa Monica’s core values of supporting housing production, particularly affordable housing, but includes departures from the 2013-2021 Housing Element particularly with respect to where housing is incentivized in the City. While the LUCE established a strategy to encourage housing production around major transportation systems, it does not account for the state’s new Affirmatively Furthering Fair Housing mandate. Key LUCE policies to develop complete neighborhoods in mixed-use areas within easy access to transit opportunities and daily services remain but the updated Housing Plan is driven largely through an equity and inclusion lens. Ensuring equitable housing access and housing choice to all of Santa Monica’s neighborhoods and ensuring that affordable housing production is provided the highest levels of development and process incentives are the bedrock of this updated Housing Element. The programmatic approaches in this housing plan reflect both the City’s desire to continue to reinforce LUCE policies to develop complete neighborhoods in transit-adjacent mixed-use areas and significant changes in State of California Housing laws and events that have affected funding streams for affordable housing, including: • Changes in State housing laws (AB686) that mandate Affirmative Furthering Fair Housing, which requires that the cities…”take meaningful actions in addition to combating discrimination that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protective characteristics.” • Changes to the California Department of Housing and Community Development’s (HCD) Regional Housing Needs Allocation (RHNA) methodology that resulted in a significantly higher new housing unit allocation for Santa Monica due to accounting for existing unmet need. • The devastating economic impact from the COVID-19 pandemic which affected Santa Monica’s budget and funding that would otherwise have been allocated for affordable housing. Further, as the City continues on the road to economic recovery, the funding sources for affordable housing depend heavily on the sales tax revenue that will not recover quickly and likely will affect affordable housing production in the first half of this Housing Element cycle. LUCE Goals for Housing The 2010 LUCE set forth numerous goals and policies in support of conserving and developing appropriate housing in the City and providing services and amenities to support a walkable, accessible community for residents. For convenient reference, these goals have been gathered in Appendix C of this Housing Element. As the housing strategy has been updated to account for changes in State law, LUCE policies will be updated to support this strategy. 8.B.g Packet Pg. 445 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 5 City of Santa Monica | 2021 - 2029 Housing Element B. Community Context 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 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 the further growth of primarily single family homes.1 During the 1920s, the City 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. By the mid-1960s, most land in Santa Monica was developed. Since that time, growth has resulted principally from recycling lower-intensity land uses to higher-density uses. In recent years, the City experienced its most significant residential development in its commercial, mixed-use areas. This trend has been reinforced by the LUCE and Downtown Community Plan policies that incentivize increasing housing around the Metro E (Exposition) Light Rail transit stations. Today, the City’s existing housing stock of 52,269 units consists of a wide range of housing types, from single-unit dwellings on large lots, to small scale bungalows, courtyard apartments, condominiums and larger mixed-use apartments. This housing stock is located within distinct residential neighborhoods and commercial mixed-use districts. With its seaside location and mild, pleasant temperatures year-round, the City has become one of the most highly desirable places to live in the country. However, the opportunity to live in the City comes at a hefty cost. While it is generally recognized that Californians pay more for housing than the average American, Santa Monica’s housing costs are among the highest in the nation (see Appendix B). The lack of housing, particularly affordable housing, is consistently a top concern for many Santa Monica residents and workers. 1 Santa Monica Historic Context Statement, Architectural Resources Group and Historic Resources Group, March 2018. 8.B.g Packet Pg. 446 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 6Chapter 1 | Introduction There are a variety of negative effects caused by a lack of housing. With a greater share of household incomes spent on housing, households are left with less money available to spend on discretionary purchases, or even basic necessities. Having less money available for non-housing costs often means that low-income households will have less savings in the bank, putting those households at risk for poverty, or preventing them from rising out of it. Low-income residents also face extra pressure of displacement due to rising housing costs. With a lack of affordable housing, more and more people are crowding into existing housing units. In addition to public safety issues, there are quality of life impacts associated with overcrowding. High housing costs also impact wider economic growth and are becoming a major consideration for employers. With approximately 80,000 non-resident workers commuting into Santa Monica, employee retention for Santa Monica companies is an issue especially if workers can’t afford to live near their job and have to commute long distances to work. C. Creating an Equitable and Inclusive Community Santa Monica has a record of supporting social equity, housing affordability, and an inclusive community. For the past forty years, the City has enacted numerous policies to prevent resident displacement, including rent control, just-cause eviction, anti-tenant harassment, source of income protections, and anti-discrimination laws that afford protections beyond the federal Fair Housing Act and the California Fair Employment and Housing Act. The City has consistently prioritized the diversity of housing opportunities available to all household types and income levels. Santa Monica’s commitment to affirmatively furthering fair housing is evidenced by specific actions that the City has taken (see Chapter 2 for further discussion). In addition, for several decades, the City has implemented policies and programs to increase the supply of deed-restricted residences that are affordable to low- and moderate-income households. The strategy primarily involves three components: 1. Public financing to support the acquisition, rehabilitation, and deed restriction of existing housing; 2. Public financing to support the construction of new deed-restricted housing; 3. Deed-restricted housing developed by private, for-profit organizations pursuant to the AHPP or development agreements. These actions have resulted in a drastically expanded housing stock in the City. The City has preserved and produced a larger and more diverse supply of low- and moderate-income housing than otherwise would be possible if the City pursued a single strategy. Santa Monica has also facilitated affordable housing through the adoption of land use plans and administrative funding guidelines to support affordable housing preservation and production. In 2010, the Land Use and Circulation Element (LUCE) of the General Plan was adopted, and identifies affordable housing as a primary community benefit associated with new development. Additionally, the City has a Housing Trust Fund. These actions have resulted in a drastically expanded housing stock in the City. 8.B.g Packet Pg. 447 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 7 City of Santa Monica | 2021 - 2029 Housing Element 8.B.g Packet Pg. 448 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 8Chapter 1 | Introduction The City continues to promote and enforce programs to address its fair housing issues, including a Fair Housing Program that is implemented by the City Attorney’s Office Public Rights Division (see Chapter 2 for further discussion). To foster an inclusive and diverse community, it will be essential to continue to put greater emphasis on providing housing that meets the needs of everyone, including low-income households, seniors, BIPOC, multi-generational families, and households with children. The effects of the COVID-19 pandemic have highlighted the complex housing challenges that the City faces, including addressing barriers to housing opportunities, housing insecurity for existing residents, and homelessness. The pandemic has particularly highlighted equity issues in terms of how lack of housing affordability disproportionately affects BIPOC and the need to reexamine land use and zoning decisions to ensure that they do not perpetuate these inequities. This Housing Element presents an opportunity to reflect on, refine, and broaden the City’s approach to housing production – particularly affordable housing – to meet the needs of our most vulnerable community members. It is also an opportunity for the City to take a leadership role in creating solutions to increase affordable housing production and stability in line with Santa Monica’s values to provide secure, livable, and affordable housing opportunities for all. 8.B.g Packet Pg. 449 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 9 City of Santa Monica | 2021 - 2029 Housing Element D. Purpose and Statutory Authority The Housing Element is mandated by Sections 65580 to 65589 of the California Government Code. State Housing Element law requires that each City and County identify and analyze existing and projected housing needs within its jurisdiction every eight years. To that end, State law requires that the Housing Element: • Provide an analysis of existing and projected housing needs, including any special housing needs • Assess affordable units at risk of conversion to market rate • Analyze actual and potential constraints to housing • Assess and describe fair housing issues, including actions to affirmatively further fair housing • Identify adequately zoned sites suitable for housing • Analyze zoning for a variety of housing types • Identify goals and policies to meet housing needs • Identify a schedule of programs and actions to be undertaken to achieve the goals and policies • Identify a quantified objective that estimates the number of units likely to be constructed, rehabilitated, or conserved/preserved • Analyze performance of prior goals, policies, and programs from the last Housing Element cycle • Identify opportunities for energy conservation The 2021-2029 Housing Element updates Santa Monica’s 2013–2021 Element, adopted by the City Council on December 10, 2013 and certified by the State Department of Housing and Community Development (HCD) on January 29, 2014. In compliance with State law, the City of Santa Monica has prepared this Housing Element to be certified by HCD after adoption by the City Council by October 15, 2021. E. Relationship to Other General Plan Elements State law mandates the adoption of a general plan (Government Code Section 65300), which serves as the blueprint for how a particular city or county (e.g., the City of Santa Monica) will develop. A general plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private. Zoning ordinances, specific plans, development projects, capital improvements, and development agreements are required to conform to the general plan. Preparing, adopting, implementing, and maintaining the general plan serves to identify the community’s land use, circulation, environmental, economic, and social goals and policies as they relate to future growth and development. A general plan consists of individual sections ―or elements--that address a specific area of concern, but collectively, they make up an integrated 8.B.g Packet Pg. 450 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 10Chapter 1 | Introduction planning approach for the jurisdiction. State Law requires that general plans include seven elements: land use, transportation, conservation, noise, open space, safety, and housing. A city or county may choose to have additional elements as part of their general plan. Santa Monica’s General Plan consists of the 7 state-mandated elements: (1 & 2) Land Use and Circulation, (3) Conservation, (4) Housing, (5) Open Space, (6) Noise, (7) Safety, as well as a (8) Historic Preservation element. The City’s Land Use and Circulation Element (LUCE) was adopted in July 2010, and last amended in 2020. The LUCE provides guidance for the City’s overall development strategy, including where and how new land uses will be located in relation to the circulation system in the City through 2030. The LUCE established overarching policies and standards for new development based on land use designations for every property in the City. These policies and standards were further refined in the City’s Zoning Ordinance Update in 2015 and by the adoption of various area and specific plans, including the 2013 Bergamot Area Plan and the 2017 Downtown Community Plan. General Plan Safety OpenSpace Noise Housing Element LUCE HistoricPreservation Conservation To meet the City’s RHNA allocation of 8,895 new units over the next 8 years and to affirmatively further fair housing, the Housing Element includes actions and programs to amend adopted development standards and policies. As required by State law, elements of the General Plan should form an integrated, internally consistent plan, and inconsistencies cannot be remedied by a statement giving one element precedence over the others (Gov. Code § 65300.5; Sierra Club v. Board of Supervisors of Kern County (1981) 126 Cal.App.3d 698). Therefore, adoption of the Housing Element will require amendments to the LUCE and the City’s Zoning Ordinance, Bergamot Area Plan, and Downtown Community Plan to ensure internal consistency. 8.B.g Packet Pg. 451 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 11 City of Santa Monica | 2021 - 2029 Housing Element Adoption of this Housing Element will also trigger revision of the City’s Safety Element. The Safety Element was last updated and adopted in February 1995. Over 25 years have passed and since that time, and the State has established new requirements pertaining to Safety Element updates. Specifically, Senate Bill 1030 which was passed in 2018 establishes the following: • Requires the safety element to be revised to identify new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies applicable to the city or county that was not available during the previous revision of the safety element • Requires this revision to occur upon each revision of the housing element or Local Hazard Mitigation Plan (LHMP), but not less than every eight years. F. Housing Element Organization Santa Monica’s Housing Element is organized into the following chapters: 1. Introduction: This chapter discusses the City of Santa Monica’s housing strategy, statutory requirements of the Housing Element and relationship to other General Plan elements, changes to the Land Use and Circulation Element, and a summary of the outreach efforts. 2. Affirmatively Furthering Fair Housing: This chapter provides an assessment of fair housing including a description of segregation patterns, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, disproportionate housing needs, and a summary of actions to affirmatively further fair housing in the City. 3. Goals and Policies: This chapter provides the background for the City’s housing needs, and then establishes the goals and policies to address the housing issues identified. This section forms the framework of the programs in the Housing Element. 4. Land Available for Housing: This chapter summarizes the City’s State mandated RHNA and provides an analysis of suitable land available for residential development to meet the RHNA. 5. Programs and Schedule of Implementation: This chapter lays out the programs that the City will implement to achieve the goals and objectives. Each program includes specific actions to be undertaken by the City, a timeframe for implementation, the City departments/divisions responsible for implementation, and desired outcomes (where appropriate). 8.B.g Packet Pg. 452 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 12Chapter 1 | Introduction G. Community Engagement The City encourages and solicits the participation of the community and other local agencies in the process of identifying housing and community needs, and prioritizing expenditure of funds. Throughout the preparation of the Housing Element, the City conducted numerous outreach efforts to engage all segments of the community. Public Process Adapts to the COVID-19 Pandemic Due to the COVID-19 Pandemic and the resulting safer at home orders, the public outreach process was adapted to accommodate virtual participation. Staff held online roundtable discussions, workshops, questionnaires, and study sessions. The global pandemic not only shifted the way that public participation was performed, but also the way that Staff noticed outreach events. A project website was created and launched in August 2020 to document project progress with information on public outreach events, draft documents, the RHNA, and relevant links. (www. santamonica.gov/housing-element-update). In order to communicate upcoming engagement opportunities during a safer at home order, additional engagement strategies were needed, aside from the typical social media posts, newspaper notices, and email blasts. Two large-scale surveys were conducted at the launch of the project and when the draft concepts were released in order to gather input (see Appendix A). Non-digital communication strategies were employed, like the Rent Control Board newsletter and Seascape, a quarterly City publication mailed to every household in Santa Monica. Materials and notices were also distributed through stakeholders and community partners such as housing providers. While most materials were posted to the project website, printed versions and alternate language versions were available upon request. Community Input The two phases of public outreach conducted to get community input for the Plan included public outreach meetings and inter-department collaboration with other City divisions and departments. Outreach Meetings Figure 1-1 lists the meetings at which opportunities for public, City Council, and City commission input on the Housing Element were provided. As indicated, the City held public webinars, met with stakeholders virtually, and held numerous public hearings with the Planning Commission, City Council, Housing Commission, and Rent Control Board. City staff attended over 35 meetings and hearings throughout the course of the Housing Element preparation. 8.B.g Packet Pg. 453 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 13 City of Santa Monica | 2021 - 2029 Housing Element Figure 1-1: City Boards and Commissions Meeting Date Description Housing Element Update Public Webinar 11/12/20 (Morning) 11/12/20 (Evening) 11/14/20 Public webinars on the project launch Planning Commission 11/18/20 12/9/20 1/20/21 2/17/21 3/16/21 3/17/21 5/12/21 6/2/21 6/3/21 8/18/21 9/8/21 9/14/21 “Gathering Input for the Plan” presentations to City boards, commissions, and the City Council took place between November 2020 and April 2021. An initial study session with the City Council took place in December 2020. Presentations of the May 2021 Draft, which took place between May and June 2021, highlighted the proposed updates to the Housing Element for Commissions, Boards and neighborhood groups as requested. The meetings yielded direction on concepts to include in the draft Housing Element. City Council 12/10/19 12/15/20 3/9/21 3/30/21 6/15/21 Housing Commission 1/7/21 4/1/21 4/15/21 Rent Control Board 12/10/20 4/8/21 Housing Production Technical Working Group 12/3/20 12/17/20 1/22/21 2/19/21 Two technical working groups on Housing Production and Housing Stability were formed in November 2020. The groups were comprised of practitioners and interested community members. The two groups met four times each between December 2020 and February 2021. Housing Stability Technical Working Group 12/11/20 1/8/21 1/28/21 2/18/21 Affordable Housing Developer Round- table 2/25/21 The affordable housing stakeholders’ roundtable brought together affordable housing producers and advocates with particular knowledge and experience in housing issues. Participants included: Linc Housing, Community Corporation of Santa Monica (CCSM), Abode Communities, EAH Housing, Southern California Association of Nonprofit Housing – SCANPH, Step Up, and Amcal Multi-Housing Interfaith Council 4/28/21 Staff met with representatives of a variety of religious congregations through the Santa Monica Area Interfaith Council. The intent was to provide information regarding the possibility of in- creasing housing potential on parking lots of religious congregations. 8.B.g Packet Pg. 454 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 14Chapter 1 | Introduction The first public draft of the Housing Element was released in May 2021 and posted on the department and project website. The Planning Commission held a public hearing on June 2 and 3, 2021, followed by City Council on June 15, 2021. All City meetings are open to the public. The City provides the public with advance notice of the public hearing, on-line links and digital copies of all related materials with print and translated materials available upon request. Comments and direction provided at these meetings were incorporated into the May 2021 draft, which was posted on the website and submitted to the State of California Department of Housing and Community Development (HCD). The City also made use of its internal and external partners to maximize the noticing of hearings, events and the release of draft materials and concepts. This included working with affordable housing providers in the City, the rent control board, and the City’s communications team to reach affordable housing and rent control residents, and the City at large through the SaMo News email blast and City social media accounts. Community outreach for the Housing Element update started with three identical virtual workshops outlining the update process, objectives, and future engagement opportunities. Following the staff presentation, participants were given time to ask staff questions. A summary of each workshop, including the question and answer portion, was then posted to the project website. These workshops were held across several days and times, including the weekend, to allow for broad participation. In addition, an online survey was sent out to all neighborhood groups, stakeholders, and the City’s list of interested parties/groups. Additionally, two Technical Working Groups were established, one focused on housing production and the other on housing stability. The goal of these two groups was to bring together community members, practitioners, and experts to garner more specific feedback on the barriers to housing development and issues surrounding displacement. Attendees came from a broad range of stakeholder groups, including Abundant Housing LA, Community Corp of Santa Monica, NRDC, EAH Housing, various boards and commissions, several private architecture firms, and other various community groups. For a full list of member organization/affiliation, see the Figure 1-2 below. The working groups met four times each and discussed the past and future goals, policies, and programs of the Housing Element. The comments received were then used to develop draft concepts around housing production, location, stability, and equity. These concepts were posted to the website, in both English and Spanish, along with surveys to petition additional feedback form the community at large. 8.B.g Packet Pg. 455 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 15 City of Santa Monica | 2021 - 2029 Housing Element Figure 1-2: Technical Working Group Member Organization/Affiliation Stability TWG Production TWG NOMA KoningEizenberg Architecture Santa Monica Housing Commission RLB Architecture Pico Neighborhood Association KEA Black Agenda SREG Committee for Racial Justice Abundant Housing LA League of Women Voters L.A. Realty Partners NRDC Armbruster Goldsmith & Delvac LLP Community Corp of Santa Monica Community Corp of Santa Monica Harding Larmore Kutcher & Kozal Abundant Housing LA Disability Community Resource Center Moore Ruble Yudell Architects and Planners MAPS Realty Housing Commission PCG Santa Monicans for Renters’ Rights Cypress Equity Investments DFH Architects Morley Builders Architectural Review Board Santa Monica Architects for a Responsible Tomorrow Michael W. Folonis, Architects Housing Commission Yuguchi Architecture Planning Commission NRDC Interested Community Members Harding Larmore Kutcher & Kozal Santa Monica Housing Council Planning Commission Zinner Consultants EAH Inc. MAPS Realty Sustainable Homes of the Future, LLC Cypress Equity Investments Goldman Firth Rossi Architects Morley Builders Architect, member Building and Fire Life-Safety Commission Santa Monica Architects for a Responsible Tomorrow Housing Commission Interested Community Members 8.B.g Packet Pg. 456 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 16Chapter 1 | Introduction In an effort to gather more specific feedback around the barriers to affordable housing development, staff held a roundtable with affordable housing developers from across the Los Angeles area. Involved organizations included Linc Housing, Community Corporation of Santa Monica (CCSM), Abode Communities, EAH Housing, Southern California Association of Nonprofit Housing – SCANPH, Step Up, and Amcal Multi-Housing. Once draft concepts for the Housing Element were developed, they were posted online, in both English and Spanish, for a period of review by the community. The public were provided the opportunity to comment on the draft concepts via an on-line interactive survey. The comments received were then presented back to the Housing Commission, Rent Control Board, Planning Commission, and City Council. City Boards and Commissions Following each meeting held during the initial phase of the community outreach effort, comments were summarized and posted on the project webpage. These materials were made available in English and Spanish, upon request. Figure 1-3 summarizes comments by topics that were received from the community and indicates where issues have been addressed in this document. Individual meeting summaries can be found in Appendix D. 8.B.g Packet Pg. 457 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 17 City of Santa Monica | 2021 - 2029 Housing Element Figure 1-3: Comments Received During Phase I Community Outreach, by Topic General Comment Where Addressed Affordable Housing: There were many discussions that concurred that the cost of housing in Santa Monica is too high. To alleviate the demand for lower- cost housing, the Housing Element should encourage both 100% affordable developments and inclusionary units in market rate housing projects. Some concepts proposed to encourage additional affordable housing are: • Increasing the inclusionary requirements of the AHPP; • Building in additional flexibility for the off-site affordable housing requirement; • Changes to certain development standards to encourage housing production; • Further streamline the process for housing project approval; • Incorporate the SB1763 changes to the state density bonus law; • Increase the maximum allowable density and height to ensure housing feasibility and to support increased affordable housing production; • Right of first offer for non-profit housing developers Programs: 1.A, 1.B, 1.E, 1.F, 1.J, 2.B, 2C,2.D, 4.B Protect Existing Tenants: Concern was expressed that meeting the higher RHNA allocation would lead to the displacement of existing tenants. Community members advocated for additional protections for existing tenants to make sure that they can remain in place while also allowing additional housing units to be built. Some concepts proposed to protect existing residents are: • Expanding upon and adding to the existing programs that provide rental assistance, tenant protections, resident support services, and maintenance/ rehabilitation of housing units; • Protect existing rental units and require that protected units are replaced; • Maintain housing repair and rehabilitation programs; • Expand upon outreach and information for property owners and tenants regarding tenant rights and rehabilitation programs; • Protect low-income units at-risk of converting to market-rate units, as well as the naturally occurring affordable housing units. Programs: 2.G, 3.A, 3.B, 3.D, 3.E, 3.H, 5.A, 6.A, 6.B, 6.C, 6.D, 6.G, 6.H Additional Incentives for Accessory Dwelling Unit (ADU) Production: Ideas were proposed to explore ways to increase the development of ADUs. Since ADUs are typically additions to existing structures, the new units would help to contribute to the RHNA while maintaining neighborhood character and protecting existing residents. Some ideas proposed are: • Allow additional ADUs on single-dwelling unit parcels if they are deed restricted for affordable housing; • Develop an ADU accelerator program to simplify the ADU process and create pre-approved plan sets for ADUs. Programs: 1.G 8.B.g Packet Pg. 458 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 18Chapter 1 | Introduction Inter-Agency Review City Departments: An Interdepartmental Taskforce representing all City departments related to housing including the Community Development Department (encompassing City Planning, Housing, and Economic Development), Community Services Department, City Attorney’s Office and Rent Control Board met regularly over the past year to contribute to the development of the Housing Element, review draft documents, and keep the City’s relevant Boards and Commissions informed about the planning process and key policy issues. Water and Sewer Priority (Section 65589.7): As required by State Law, the Housing Element was shared with the City’s Water Resources Division (WRD), which has responsibility for water and sewer maintenance and development. Appendix F provides a summary of potential water and sewer infrastructure constraints for housing projects. As indicated, while increases in infrastructure capacity will be necessary to accommodate the sewer and water demands of future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The stormwater and sewer treatment facility at the Civic Center Lot, part of the City’s Sustainable Water Infrastructure Project (SWIP). 8.B.g Packet Pg. 459 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 19 City of Santa Monica | 2021 - 2029 Housing Element H. Summary Of Housing Programs For The 2021-2029 Housing Element This summary table is provided for convenient reference. More details regarding the programs, including program background can be found in Chapter 5. Program No Program Objective Timing GOAL 1 PROGRAMS 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. 1.A By-Right Approvals For Housing Projects The City shall make permanent amendments to the Zoning Ordinance that are currently interim and make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to allow, at a minimum: 1) 100% affordable housing projects; 2) non-Downtown housing projects that are code-compliant or are granted specified modifications/waivers to be established in the Zoning Ordinance; 3) Downtown housing projects that do not exceed Tier 2 maximums and are code-compliant or are granted specified modifications and waivers to be established in the Zoning Ordinance; and 4) housing projects that include at least 20% of units on-site as affordable to lower-income households [Government Code Section 65583.2(c)] , to be reviewed through a by-right process. . The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. Such by-right projects shall still be subject to design review, provided that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. The City shall extend interim zoning amendments for process thresholds pending the full implementation of this program. The City shall also develop written procedures to implement the streamlined review process for eligible projects under SB35. The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process. Provide certainty for housing providers by allowing a ministerial approval process based on objective standards for 100% affordable housing projects, housing projects that are code compliant or granted specified modifications, code- compliant Downtown housing projects that do not exceed Tier 2 maximums or are granted specified modifications, and housing projects eligible for by-right processing in accordance with State law. October 15, 2022 1.B Streamline The Architectural Review Process and Ensure Design Review Objectivity For Housing Projects The City shall adopt new streamlining procedures to allow staff level design review for smaller housing projects and expedited design review of larger housing projects by shifting the design review process to before or concurrently with entitlement issuance. This will reduce processing timelines and increase certainty for housing providers. These procedural changes would involve amending the Municipal Code to assure that design review cannot unreasonably delay a housing project approval by, for example, placing limits on number of hearings and maximum time limits for design review. The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency with SB35. Streamlined housing approvals. Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022 8.B.g Packet Pg. 460 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 20Chapter 1 | Introduction Program No Program Objective Timing 1.C Incentivize Housing Development On Surface Parking Lots in Residential Zones In order to provide new housing choices and affordability in high opportunity areas, the City shall adopt standards that incentivize housing production on surface parking lots in residential zones associated with existing commercial uses, including, but not limited to, removing density caps and commercial parking replacement restrictions, lot consolidation, street access to the project, and restoring underlying maximum allowable density. The City shall also adopt standards that incentivize housing production on surface parking lots associated with existing residential uses as long as the existing residential use is not removed. Incentivize housing production on underutilized sites that would not displace existing tenants. August 1, 2023 1.D Reduce Minimum Parking Requirements for Housing Projects The City shall reduce minimum parking requirements for all housing projects by applying Parking Overlay 1 rates. Lower the cost of housing production October 15, 2022 1.E Revise The Design Standards In The Bergamot Area Plan (BAP) For Easier Understanding And To Support Housing Production The City shall modify the design guidelines in the BAP to establish objective standards to support housing production by increasing certainty for housing providers. The revisions to design standards will address at minimum: 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 to support housing production. The BAP should also consider the special housing needs of artists, such as live-work units, to promote artist residents in the Bergamot area. Provide clarity in the regulatory environment for housing and incentivize housing production in the Bergamot area. By June 30, 2023 8.B.g Packet Pg. 461 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 21 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 1.F Revise the Downtown Community Plan Development Standards To Support Housing Projects The City shall modify the development standards in the DCP to ensure they are set at levels that can support the minimum AHPP requirements and to support feasible housing projects. The City shall also amend the development standards and AHPP requirements to ensure Tier 2 and Tier 3 Downtown housing projects are feasible. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. Any changes will promote housing and ensure that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR and height shown in the table below. The off-site affordability requirement will be greater than the on-site requirement. The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees, unit mix. and design standards such as restrictions on ground floor residential use, minimum/ maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Minimum Tier 1 FAR/Height with Rezoning Current Tier 2 FAR/Height Minimum Tier 2 FAR/Height with Rezoning Curent Tier 3 FAR/Height Minimum Tier 3 FAR/Height with Rezoning LT (East)12 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- LT (West)11 1.50/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- NV 31 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -4.0/84 ft BC (Promenade)12 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- BC (2nd/4th)25 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -- TA 52 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft 4.0/84 ft 4.0/84 ft OT 15 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- WT 6 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- Continue to encourage housing production in Downtown area. October 15, 2022 8.B.g Packet Pg. 462 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 22Chapter 1 | Introduction Program No Program Objective Timing 1.G Incentivize and Facilitate the Development 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 constructing ADUs throughout all neighborhoods 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 further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year. Additionally, the City will review and update its locally adopted ADU Ordinance for consistency with State law. Streamline approvals and facilitate development of ADUs. June 30, 2023 1.H Adaptive Reuse Of Existing Commercial Buildings For Permanent Residential Use As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to incentivize the adaptive reuse of existing commercial tenant space Citywide, for permanent residential use and also allow an adaptive reuse of existing ground floor commercial space for artists and live-work use. Changes to incentivize the conversion of existing commercial tenant space to residential use include but are not limited to, relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements. Increase flexibility for reuse of vacant commercial space to residential use. December 31, 2024 1.I Ensure That Local Regulations Support Innovations In Construction Technology To The Extent Technically Feasible The City shall support innovative lower-cost, efficient and environmentally sustainable construction techniques for housing. Program shall implement a streamlined building permit review process for housing projects utilizing innovative construction methods and technology, and project-based outcome- oriented permitting benchmarks. Remove impediments to innovation in housing construction. December 31, 2024 1.J Rezoning by Revising Development Standards to Ensure that Housing Projects are Feasible and Incentivized Over Commercial Development The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.0 to 3.25 with heights ranging from 55 feet to 65 feet. Any changes will promote housing to ensure overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR and height shown in the tables below. The off-site affordability requirement will be greater than the on-site requirement Support the production of affordable housing and encourage the equitable production of housing across the City. Octoer 15, 2022 8.B.g Packet Pg. 463 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 23 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Minimum FAR/Height with Rezoning MUBL – N of I-10 107 1.50/36 ft 1.75/36 ft 3.25/70 ft MUBL – Pico 15 1.50/36 ft 1.75/36 ft 2.00/45 ft MUBL – Pico (West of Lincoln) 4 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL – Main St 10 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL - Lincoln 107 1.50/36 ft 1.75/36 ft 2.50/55 ft MUB 59 1.50/39 ft 2.25/50 ft 3.25/70 ft GC (SMB)24 1.25/ -1.50/35 ft 3.25/70 ft GC (Lincoln)19 1.50/36 ft 2.00/36 ft 2.50/55 ft GC (Pico)4 1.50/36 ft 2.00/36 ft 2.00/45 ft NC 27 1.50/32 ft N/A 2.25/50 ft NC (Main)14 1.00/27 ft N/A 2.50/55 ft NC (Ocean Park)15 1.00/32 ft N/A 2.50/55 ft NC (Montana)15 1.00/32 ft N/A 2.50/55 ft IC 77 N/A N/A 3.00/65 ft OC 88 N/A N/A 2.75/60 ft HMU 39 1.50/45 ft 2.50/70 ft 2.50/70 ft 8.B.g Packet Pg. 464 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 24Chapter 1 | Introduction Program No Program Objective Timing Bergamot Area # Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Current Tier 3 FAR/Height Minimum FAR/Height with Rezoning BTV 35 1.75/32 ft 2.00/60 ft 2.50/75 ft 4.0/84 ft MUC – North of Pennsylvania Avenue parcel line between Stewart and Stanford; South of Expo Bike Path 31 1.50/32 ft 1.70/47 ft 2.20/57 ft 3.25/70 ft MUC - Remainder 36 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft CCS 8 1.50/32 ft N/A N/A 2.50/55 ft CAC 17 1.00/32 ft 1.00/60 ft 1.00/75 ft 2.50/55 ft The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix requirements, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. 8.B.g Packet Pg. 465 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 25 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 1.K Adequate Sites Program To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower incoe units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing 100 percent residential use and requiring residential use to occupy at least 50 percent of the floor area. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City comply with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations. Create opportunity to accommodate the City’s lower-income RHNA targets June 30, 2023 GOAL 2 PROGRAMS Housing production for all income categories including for the community’s workforce and most vulnerable communities. 2.A Establish A Moderate-Income Affordable Housing Overlay The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate- income (up to 120% AMI) housing projects in at leat three 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, 50% density bonus, up to four incentives and concessions, no minimum parking requirements, and flexibility in unit size/unit mix in exchange for additional common area amenities. Provide significant incentives for 100% affordable housing. June 30, 2023 2.B Right Of First Offer Ordinance For Nonprofit Affordable Housing Providers Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, the City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making nonprofit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildings through this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable. Support 100% affordable housing by assisting nonprofit affordable housing providers to be competitive in the land acquisition market. December 31, 2024 8.B.g Packet Pg. 466 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 26Chapter 1 | Introduction Program No Program Objective Timing 2.C Update The City’s Affordable Housing Production Program to Increase the Number of Affordable Housing Units at all Income Levels In order to increase the number of affordable housing units at all income levels such that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to maximize the contributions of the AHPP to achieving the RHNA affordable housing allocation and advancing the City’s affordable housing goals. Areas to be considered may include, but not be limited to: • Increase the threshold (to at least 6 units) at which projects are required to provide on-site or off-site affordable units; • Eliminate the current “menu” option of affordability requirements and instead establish a new base affordability percentage; • Re-evaluate the in-lieu fee option for applicants to pay a fee instead of constructing affordable units to ensure that the fee supports the funding and construction of new affordable housing throughout the City; and • Evaluate the possibility of a mixed-compliance option that would provide applicants more flexibility in meeting AHPP requirements. • Increase the minimum percentage of required off-site affordable units to be higher than the on-site option; • Allow projects to locate off-site affordable housing anywhere in the City that is not a disadvantaged area as defined by SB535, which includes socioeconomic and environmental metrics • Allow market-rate projects to comply with AHPP off-site option through acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Ensure that the AHPP provides housing developers viable options for compliance. By April 30, 2023 2.D Update Density Bonus Ordinance to Ensure Consistency With State Law And Integration Into The City’s Land Use System 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 AHPP. The ordinance will clarify how to apply State density bonus law in the City’s commercial and mixed- use districts that do not have maximum density controls, including application of State density bonuses to floor area dedicated to residential uses. The amendments to the Municipal Code shall also set forth a voluntary by-right menu of incentives & concessions that do not require following the process under Government Code Section 65915(d) for approval. Requests for “off-menu” incentives and concessions may be requested pursuant to Government Code Section 65915(d). Ensure consistency with State Law. October 15, 2022 8.B.g Packet Pg. 467 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 27 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 2.E Commit To The Production Of Affordable Housing On City-Owned/Publicly- Owned Land The City shall commit City-owned sites for the production of 100% affordable housing, with consideration of other community-serving purposes, including, but not limited, to green space, place making, and/or community-serving commercial and revenue generating uses. The City shall plan for a minimum of 1,880 affordable housing units across available City-owned sites, which are located throughout the City, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first RFP for a city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months. As has been done in the past, the City will use a variety of tools to facilitate 100% affordable housing development, including but not limited to: • Facilitate appropriate zoning and process to support 100% affordable housing • Substantially reduced or free ground rent, the City will • Providing funding through local housing trust fund • Support applications for other funding sources for affordable housing (e.g. low-income- housing tax credits, grants, State funding, Federal funding) • Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Further, 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. Prioritize affordable housing production on city-owned land. December 31, 2023 and Annual Ongoing 8.B.g Packet Pg. 468 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 28Chapter 1 | Introduction Program No Program Objective Timing 2.F New Affordable Housing Finance Programs To Enable Continued Provision Of Technical And Financial Assistance For Housing Production 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. The City has adopted policy on prioritizing our local funding through a Housing Trust Fund plan that includes spending commitments for affordable housing production and preservation for special needs and ELI households including exploring new funding for conversion to deed-restricted, multi-unit developments in areas of affluence. The plan outlines funding strategy for ELI households including seniors and persons living with disabilities. The City will continue to implement the policy and execute funding commitments to produce housing targeted to persons experiencing homelessness or at-risk of homelessness. Local funding through the Housing Trust Fund will also help support the production of at least 1,880 affordable housing units on City-owned/publicly owned land in accordance with Program 2E. On an ongoing basis, the City will continue to communicate with local affordable housing providers on potential housing projects based on funding availability. Financial and technical assistance shall be provided when resources are available and committed to nonprofit housing providers to the greatest extent possible to support the development of affordable housing, including special needs housing and arts housing. The City will research 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. Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Seek innovative affordable housing financing tools to increase production. Annual ongoing 2.G Expand Housing Choice by Facilitating The Development And MaintenanceOf Special Needs Housing The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle. This includes the provision of new programs, services, infrastructure and amenities that can help seniors who choose to live independently remain in their homes as long as possible. Within legal constraints, encourage or require housing providers to assign affordable housing units designed for persons with disabilities, including physical or developmental disabilities, for use by those who require those features. The City shall encourage barrier-free construction and adaptation. Through the 5-year Consolidated Plan process, the City shall continue to identify housing and supportive service gaps for various special needs groups and propose policy and priorities based on the analysis. Housing for individuals with special needs. Annual ongoing 2.H Maintain Proposition I Monitoring The City shall monitor utilization of Proposition I authority through annual reporting of new “low rent- housing projects.” Ensure the City continues to report on compliance with Proposition I. Annual ongoing 8.B.g Packet Pg. 469 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 29 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 2.I Zoning For A Variety Of Housing Types Including Special Needs Housing And Housing Acces For Persons With Disabilities The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law regarding special needs housing types and residential land use classifications. Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty. Ensure the City is compliant with all State laws for special needs housing types and residential land uses. December 31, 2023 and Annual Ongoing 2.J Program 2.J Prioritize Water And Sewer Service To Housing Projects With On-Site Affordable Units The City shall establish written procedures to grant priority to developments with on-site units affordable to lower-income households if availability of service is limited. Prioritize infrastructure service to developments with lower income units to support the production of affordable housing throughout the City December 31 2022 GOAL 3 PROGRAMS Preservation of the existing supply of housing and prevent displacement of existing tenants. 3.A Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are Replaced The City shall amend the Municipal Code to adopt local requirements that make permanent and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced. As required by Government Code Section 65583.2(g)(3), the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity’s valid exercise of its police power (approximately 27,484 units), or (3) within the past five years were occupied by low or very low income households, shall be required to replace all of those units as affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth Government Code Section 65915(c)(3). Protect existing residents by preserving existing rental housing stock; no net loss of units. Jine 30, 2023 8.B.g Packet Pg. 470 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 30Chapter 1 | Introduction Program No Program Objective Timing 3.B Develop Tenant and Landlord Programs To Address State And Federal Legislative Mandates Regarding Anti-Discrimination The City shall continue to implement programs throughout the City, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing in light of the loss of formerly affordable units due to vacancy de-control and Ellis withdrawals. The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles Develop programs to address State and Federal housing mandates. Annual ongoing 3.C Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing. There are approximately 770 affordable, deed-restricted units that are at-risk of conversion to market rate in the next 10 years. The City will continue to monitor over this Housing Element Cycle the status of of the approximately 770 affordable, deed-restricted at-risk units throughout the City, ensure that required notice is given to tenants, and advise property owners and tenants in advance of potential conversion dates, and assist in answering questions from residents of at-risk housing. As a part of the ongoing monitoring, the City will continue to provide information on maintaining long-term affordability and assist federally-funded housing properties with seeking funding assistance in applying for allocations of housing vouchers from the federal government to maintain housing affordability. On an ongoing basis, the City will continue to communicate with local affordable housing providers on conserving housing projects. The City will exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. Additionally, the City shall continue to report annually on non-covenant residential units such as the approximately 27,484 rent-controlled units. The City proactively monitors units at risk of conversion due to expiring covenants and takes actions to ensure their long-term affordability. Annual ongoing 3.D Maintain An Acquisition And Rehabilitation Program 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 for acquisition and rehabilitation throughout the city. As outlined in Program 2.B, the City shall adopt a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer to acquire existing private properties as they become available for purchase. Protect existing residents by acquiring and rehabilitating existing housing. Annual ongoing 3.E Maintain A Low Income Residential Repair Program The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the City.. Rehabilitate 38 multi-unit dwellings and provide 20 minor home repairs. 2024 8.B.g Packet Pg. 471 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 31 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 3.F Enhance Code Enforcement Response To Housing-Related Violations The City shall continue to respond to residential building code violation complaints throughout the City. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day. Require property owners to respond to Building Code violations and complete routine maintenance on their residential buildings. Annual ongoing 3.G Maintain A Mandatory Seismic Retrofit Program The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle. Protect existing residents by ensuring the safety and structural integrity of existing residential buildings. Annual ongoing 3.H Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units The City shall provide additional education and outreach to multi-unit property owners on available City programs and support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties. Inform property owners regarding proper maintenance of residential units. Annual ongoing 3.I Right To Counsel Program The City shall continue to implement a Right to Counsel pilot program and evaluate its overall effectiveness, program capacity, and long-term feasibility. Prevent the displacement of tenants by providing access to legal assistance and support for tenants facing eviction. Ongoing 3.J Restrict Conversion Of Existing Rental Housing To Condominiums The City shall continue to regulate condominium conversions pursuant to SMMC Section 9.24.040. The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory. Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data. Restrict loss of rental housing units to condominium conversions Ongoing 8.B.g Packet Pg. 472 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 32Chapter 1 | Introduction Program No Program Objective Timing GOAL 4 PROGRAMS A community that provides equitable housing access to all neighborhoods. 4.A Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Non-Residential Zones Where Not Currently Permitted 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 amended to add multi-unit housing as a permitted use in areas where it is currently prohibited. Land use regulations, FAR, and Height (as indicated in Program 1.I) will be revised to allow housing in the three areas that currently do not allow housing such as the Office Campus, Industrial Conservation, and Creative Conservation Sector zones. To promote fair and equitable housing opportunities throughout the City, the City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) including in areas that have historically not permitted or accommodated housing, to allow for higher maximum allowable FAR and height in the NC, IC, and OC zoning districts. For the purposes of addressing environmental health considerations, the City shall amend the Zoning Ordinance to specify locations in the City where housing projects are required to conduct an air quality assessment and implement recommendations from the assessment. Support the production of affordable housing and encourage the equitable production of housing across the City. October 15, 2023 4.B Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses 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 community assembly uses, including religious congregations including allowing not more than 50% market-rate units to support the affordable housing, unlimited density, no minimum parking requirements, an additional 33 feet of building height and allowance for the primary community assembly use and related ancillary use, for the support or expansion thereof, on or above the ground floor. Increase equitable access to all residential neighborhoods and not incentivize affordable housing in areas that have historically excluded diverse housing opportunities. June 30, 2023 4.C Provide New Housing Choices and Affordability in High Opportunity Areas Through Incentives for Additional ADUs in R1-Zone Neighborhoods The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with program 4.F. This would include allowing an additional ADU to be constructed if the ADU is deed restricted as a rental unit. As ADUs are naturally more affordable by design given their size, the program would help affirmatively further fair housing by helping to provide new housing choices and affordability in high opportunity areas of the City that are largely unaffordable to many people. Increase equitable access to all neighborhoods through nominal density increases that may lower the barrier to housing access in areas that have historically excluded diverse housing opportunities. June 30, 2023 8.B.g Packet Pg. 473 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 33 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 4.D Right to Return Program The City shall continue to implement a Right to Return Pilot Program and evaluate outreach strategies, applicant demand, the availability of historical documentation, verification processes, compliance with government legislation, and the administrative resources required to implement a broader long-term program. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. Address the historical displacement of Santa Monica households resulting from the development of the Civic Auditorium and I-10 freeway through the Pico neighborhood during the 1950s and 1960s that disproportionately impacted low-income communities and communities of color. Annual Ongoing 4.E Provide New Housing Choices and Affordability in High Opportunity Areas Through Incentives for SB9 Units in R1-Zone Neighborhoods The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. In addition, these SB9 units shall be required to be rented or sold. This will open up the possibility for property owners to construct up to 6 units through a multi-step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F. Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods. By June 30, 2023 4.F Establish Target to Increase Housing Production in R1 Zones and Include Mid-Cycle Monitoring The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. Increase the number of net new housing units in R1 zones Assess progress by December 31, 2025 8.B.g Packet Pg. 474 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 34Chapter 1 | Introduction Program No Program Objective Timing GOAL 5 PROGRAMS Housing for persons experiencing homelessness 5.A Reduce The Number Of Homeless Individuals Living On The Streets Of Santa Monica Through The Provision Of A Range Of Housing Options, With An Emphasis On Affordable, Permanent, Supportive Housing. The City shall continue to seek and leverage funds that contribute to the development of a range of permanent, supportive housing options, within and outside of Santa Monica. Focus case management and housing resources on the most chronic and vulnerable homeless individuals that have been identified on the City’s Homeless Service Registry. Continue to serve other priority homeless populations through City- funded programs. Continue strategies to reunite those not first-homeless in Santa Monica with family and friends in their home communities. Review City policies and practices that may contribute to homelessness. Continue to invest in and implement housing and supportive services to prevent and address the impacts of homelessness. Annual ongoing 5.B Low Barrier Navigation Centers As By-Right Use The City shall amend the Zoning Ordinance to allow Low Barrier Navigation Centers as a by-right permitted use in all non-residential zones permitting multi-unit uses. Ensure the City’s regulations and procedures are in conformance with State Law. December 31, 2023 GOAL 6 PROGRAMS 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. 6.A Enhance Housing Mobility By Maintaining Rental Housing Voucher Programs Throughout the City And Expand To Assist All Persons With Disabilities The City shall continue to operate strong rental housing voucher programs throughout the City and advocate for funding guidelines for Section 8 that are competitive for Santa Monica; and shall pursue additional funding to maintain and expand voucher programs, if possible. Review and update the Housing Authority Administrative Plan annually to ensure compliance with the latest HUD regulations and to provide flexibility to respond to tenants’ needs consistent with legal requirements. Utilize vouchers as a tool to prevent senior homelessness where eligible. When available funding opportunities are available, expand the rental housing voucher programs to fill the gap between income levels and the cost of housing for persons with permanent disabilities, including persons with Developmental Disabilities. Maintain voucher programs to ensure availability and choice of housing for households at all income levels. Annual ongoing 6.B Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance to for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle. Maintain housing stability for vulnerable individuals and households. Annual ongoing 8.B.g Packet Pg. 475 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 35 City of Santa Monica | 2021 - 2029 Housing Element Program No Program Objective Timing 6.C Maintain And Expand The Preserving Our Diversity (POD) Program The City shall continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. The program shall ensure that POD subsidies do not result in an increase in rents. The City intends the POD Program to serve at least 150 participants within this Housing Element cycle. Support measures that are not housing constraints to generate and allocate tax revenue for income assistance. Assist POD beneficiaries in achieving a basic needs budget. Annual ongoing 6.D Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources The City shall prioritize additional education and outreach to tenants and landlords throughout the City 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. The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational events per year. Raise awareness of housing assistance programs and tenant and landlord rights and responsibilities. Annual ongoing subject to available staffing resources 6.E Maintain A Community Development Grant Program The City shall continue to fund supportive services that serve the priority homeless populations, striking a balance between existing programs that have demonstrated effectiveness and national best practices that are consistent with the City’s adopted Action Plan to Address Homelessness in Santa Monica. Maintain funding for programs that service priority homeless populations, lower-income households, and special needs populations. Annual ongoing 6.F Provide Tenant Relocation Assistance The City shall continue to implement the Tenant Relocation Assistance program; periodically review existing City policies and ordinances and recommend modifications if deemed necessary, including but not limited to, additional support in locating new housing for displaced residents upon relocation. The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica. Provide displaced tenants with cash- based relocation assistance. Annual ongoing 6.G Maintain A Temporary Relocation Program The City shall continue the Temporary Relocation Program, including program oversight and enforcement, and coordination in providing accommodations to minimize impacts to residents including emergency hotel vouchers for tenants who have been ordered to vacate their units by the City for code violations, safety improvements, or maintenance. The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated. Provide temporary housing for tenants displaced from their units due to required maintenance. Annual ongoing 8.B.g Packet Pg. 476 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 36Chapter 1 | Introduction Program No Program Objective Timing 6.H Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing The City shall maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws. Provide regulatory relief to enable housing access for disabled persons. Annual ongoing GOAL 7 PROGRAMS 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. 7.A Maintain Fair Housing Enforcement and Outreach ProgramThe City shall continue to implement fair housing programs. The City shall educate landlords about discrimination and educate the real estate community on the necessity of ensuring that their practices meet the objectives of the fair housing laws. The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide tenant application assistance and support to special needs populations including seniors, persons with disabilities, and individuals transitioning from institutional settings and individuals who are at risk of institutionalization. Education of tenants and landlords of their rights and responsibilities under fair housing laws. Annual ongoing 7.B Provide Tenant/Landlord Mediation And Legal ServicesThe City shall continue to support tenant/landlord mediation and legal services assistance. Provide tenant/landlord dispute resolution services. Annual ongoing 7.C Maintain The Anti-Discrimination Tenant Protection Program The City shall continue to prevent discrimination, tenant harassment, and unlawful evictions through monitoring and enforcing of “just cause” eviction protections, and continue to provide fair housing services through the Public Rights Division of the Santa Monica City Attorney’s Office. The City shall review current laws and recommend any needed modifications to ensure protection of tenants to the maximum extent possible. Protect existing tenants from harassment and unlawful eviction. Annual ongoing 8.B.g Packet Pg. 477 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Image 8.B.g Packet Pg. 478 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Assessment of Fair Housing in the City 2: 8.B.g Packet Pg. 479 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 39 City of Santa Monica | 2021 - 2029 Housing Element Chapter 2: Assessment of Fair Housing in the City Housing is a human right – unfortunately though, many segments of our population do not have access to safe and affordable housing. Even when such housing is available, these units may not be located in areas that are in proximity to good jobs, easily accessible public transit, and other fundamental community features such as schools and open space. In recognition of the housing inequalities that endure to this day, the State legislature passed AB 636 (2018) to require cities and counties to advance social equity through meaningful actions that affirmatively further fair housing (AFFH). This chapter of the Housing Element provides an assessment of fair housing in the City as well as programs and policies to combat “discrimination, overcome patterns of segregation, and foster inclusive communities free from barriers that restrict access to opportunity based on protective characteristics.” The information provided in this chapter references and supplements the analysis in the City of Santa Monica’s Assessment of Fair Housing (AFH) that was prepared in accordance with U.S. Department of Housing and Urban Development requirements and adopted in April 2020. The Assessment of Fair Housing (AFH) which is attached as Appendix I is a thorough examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups protected from discrimination by the federal Fair Housing Act (FHA). Redlining The term “redlining” refers to the discriminatory policy instituted by the federal government to create color-coded maps of every metropolitan area in the country to indicate where it was safe to insure mortgage. These maps were based on racial composition, quality of housing stock, access to amenities, etc. and were color coded to identify best (green “A” grade), still desirable (blue “B” grade), definitely declining (yellow “C” grade), and hazardous (red “D” grade) neighborhoods. Areas of the City that were predominantly commercial/industrial were not color coded. 8.B.g Packet Pg. 480 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 40Chapter 2 | Assessment of Fair Housing in the City A. Historical Practices and Policies Leading to Segregation The established neighborhoods of the City today are largely the result of decades of structural racism deeply rooted in Federal, State, and local housing policies. In the early days of Santa Monica, the City had a sizeable population of Blacks/African Americans, who had moved into the City from the 1890s to the early 20th century, as part of larger westward migration patterns based in part on the prospect of new economic opportunities and community available in California. Additionally, beginning in 1904, the job opportunities at the City’s clay pit operations in the eastern portion of the City drew new Mexican immigrants. However, Blacks/African Americans, Mexicans, and other racial and ethnic groups, were met with racism from White residents in the City. In 1922, homeowners formed the Santa Monica Bay Protective League with an agenda of “eliminating all objectionable features or anything that now is or will prove a menace to the bay district ... or prove detrimental to our property values.” One of the ways that this was achieved was through racial covenants on deeds. Local government also contributed to the patterns of segregation through the adoption of exclusionary zoning. When Blacks/African Americans tried to build a Jazz Club in the Belmar area in the 1920s, City officials used zoning laws to block the project. Single-unit zoning was also seen as a way tool to economically separate the wealthier Whites from Blacks/African Americans and other racial and ethnic groups, including Italians, Japanese, Mexicans, Portuguese and, later Jews. Since many people of color could not afford or were unable to receive mortgages for owning homes, they were excluded from single-family zoned neighborhoods. Today approximately, 35% of all the land in the City is zoned for single-family homes, and very few people of color live in these zones (see Appendix B). This type of discrimination at the local level was bolstered by the federal policy of “redlining” that arose during the New Deal era (1930s). The color-coded maps were first used by the Home Owners’ Loan Corporation (HOLC) and then the Federal Housing Administration (FHA) and then adopted by the Veterans Administration (VA). This discriminatory practice of determining who could qualify for home mortgages based on race, ethnicity, religion, or immigrant status led to widespread segregated communities across the country, and prohibited Burning a derelict house on Belmar Place on July 1, 1953 Source: Santa Monica Public Library 8.B.g Packet Pg. 481 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 41 City of Santa Monica | 2021 - 2029 Housing Element people of color from buying homes. In Santa Monica, areas that were redlined included the Pico Neighborhood, portions of the Mid City neighborhood south of Santa Monica Boulevard, and Ocean Park. Areas that were color-coded green or blue generally consisted of the single- family zoned neighborhoods such as the North of Montana and Northeast neighborhoods (Map 2-1). Map 2-1: Formerly “Redlined” Areas and Single Family Zoning in the City of Santa Monica In the post-World War II era, the local and Federal government further intensified segregation through the systematic construction of government buildings and 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 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. Santa Monica government officials in the 1950s to 1960s also targeted multiethnic neighborhoods in their plans to modernize the City. The City’s Civic Center today sits atop the historic Belmar Triangle, (which encompassed the area bound by the former trolley line on the north and west [southern part of Main Street today], Fourth Street on the east, and Pico Boulevard on the south). Historically, 8.B.g Packet Pg. 482 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 42Chapter 2 | Assessment of Fair Housing in the City the Belmar Triangle was home to many African American families and other families of color who migrated to Santa Monica.1 Through eminent domain proceedings, the Belmar Triangle was razed to build the Santa Monica Civic Auditorium and part of the Los Angeles County Courthouse grounds. The City’s annual reports claimed that the Belmar area was “blighted” and that only substandard and dilapidated structures and dwellings were burned down and removed for health and safety reasons.2 Over the years, the development of lower-cost affordable housing has largely followed historic patterns of segregation. Map 2-2 shows the redlining boundaries overlaid with affordable housing that has been constructed or acquired/rehabilitated over the years. Of the affordable units that have been constructed over the years, 49% are in the City’s former redlined areas (which make up 24% of the City). Map 2-2: Affordable Housing and Formerly “Redlined” Areas in the City of Santa Monica 1 Alison Rose Jefferson, PH.D., The Erased African American Experience in Santa Monica’s History; https://alisonrosejefferson.com/wp-content/uploads/2021/02/Jefferson.ReconstructionAndReclamation.FINAL_.12.22.2020.pdf2 Ibid 8.B.g Packet Pg. 483 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 43 City of Santa Monica | 2021 - 2029 Housing Element B. Integration and Segregation Patterns and Trends 1. Race and Ethnicity The greater Los Angeles metropolitan area is a melting pot of different cultures, races, and backgrounds. Unlike the our larger, neighboring City of Los Angeles, Whites still make up the majority of the City of Santa Monica’s population. ESRI (an international supplier of geographic information system (GIS) software) tracks the shifting demographics of race and ethnicity of communities through its Diversity Index. The index shows the likelihood that two people, chosen at random from the same area, belong to different race or ethnic groups. The index ranges from 0 (no diversity) to 100 (complete diversity). For example, a diversity index of 59 means there is a 59 percent probability that two people randomly chosen would belong to different race or ethnic groups. As shown in Map 2-3, the City’s census tracts have lower diversity indices than most of the surrounding Los Angeles region. While the City is generally less diverse than the region as a whole, census data shows that the City’s racial makeup is becoming more diverse. As shown in Figure 2-1, Hispanics/Latinos make up the second largest racial group in the City, followed by Asians. In terms of the racial/ethnic makeup by census tract, there are more predominant populations of Hispanic/Latino residents in the Pico Neighborhood while the remaining areas of the City are predominantly White, Map 2-4 and Map 2-5. Defining Integration and Segregation Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area. Segregation generally means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area. 8.B.g Packet Pg. 484 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 44Chapter 2 | Assessment of Fair Housing in the City Figure 2-1: Santa Monica Population by Race and Ethnicity Category 2000 %2010 %2018 %2019 % White 60,482 71.9%62,917 70.1%59,197 64.3%59,200 64.3% Hispanic or Latino 11,304 13.4%11,716 13.1%14,613 15.9%14,097 15.3% Black or African American 3,081 3.7%3,364 3.7%3,950 4.3%3,995 4.3% Asian 6,043 7.2%7,960 8.9%9,004 9.8%9,018 9.8% Two or more races 2,584 3.1%3,174 3.5%4,782 5.2%4,571 5.0% Other 590 0.7%605 0.7%532 0.6%696 0.8% TOTAL 84,084 89,736 92,078 91,577 Map 2-3: Diversity Index 8.B.g Packet Pg. 485 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 45 City of Santa Monica | 2021 - 2029 Housing Element Map 2-4: Racial and Ethnic Majority by Census Tract Map 2-5: Population Distribution of Non-Whites 8.B.g Packet Pg. 486 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 46Chapter 2 | Assessment of Fair Housing in the City 2. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) and Affluence (RCAA) R/ECAPs R/ECAPs are geographic areas with significant concentrations of poverty and minority populations. HUD has developed a census-tract based definition of R/ECAPs. In terms of racial or ethnic concentration, R/ECAPs are areas with a non-White population of 50 percent or more. With regards to poverty, R/ECAPs are census tracts in which 40 percent or more of individuals are living at or below the poverty limit or that have a poverty rate three times the average poverty rate for the metropolitan area, whichever threshold is lower. Households within R/ECAP tracts frequently represent the most disadvantaged households within a community and often face a multitude of housing challenges. R/ ECAPs are meant to identify where residents may have historically faced discrimination and continue to be challenges by limited economic opportunity. Map 2-6: Racially or Ethnically Concentrated Areas of Poverty and Areas of High Segregation & Poverty 8.B.g Packet Pg. 487 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 47 City of Santa Monica | 2021 - 2029 Housing Element While there are no R/ECAPs within the City of Santa Monica (Map 2-6), the legacy of past racist planning and housing policies have shaped land use patterns in the City that we see today. There are census tracts in the City that have higher concentrations of non-Whites as well as higher concentrations of low income and moderate income population. In general, the patterns of non-White and lower income households continue to mirror the redline maps with more affluent Whites on the northern and southern ends of the City (Map 2-4) and non-Whites and lower income populations concentrated in the central city near the main transportation corridors (Map 2-7). Map 2-7: Low to Moderate Income Population by Census Tract This pattern of segregation is also true for renter versus ownership households. The 2020 AFH found that the location of renters and owners in Santa Monica very highly correlates with patterns of residential racial and ethnic segregation. The areas with the highest concentrations of homeownership, such as north of Montana, Ocean Park, and Sunset Park are also the areas that are predominantly White. The areas with the highest concentrations of renters, such as the Pico neighborhood and Downtown, are areas that contain high concentrations of minorities and/or those with Limited English Proficiency. The AFH also found that a major contributor to continued racial and ethnic segregation is the economics of high housing and land costs created by zoning, which particularly limits the feasibility of developing of affordable housing in certain areas of the City. 8.B.g Packet Pg. 488 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 48Chapter 2 | Assessment of Fair Housing in the City Map 2-8: Renter Households by Census Tract RCAA Racially or Ethnically Concentrated Areas of Affluence (RCAAs) are neighborhoods in which there are both high concentrations of non-Hispanic White households and high household income rates.3 Census tracts that have median income over $132,844 and have 80% of its households as non-Hispanic white are considered RCAAs. As discussed previously, non-Hispanic Whites are the predominant racial/ethnic group in the City, with more predominance in the northern and southern ends of the City. Additionally, the median household income in most census tracts throughout the City is lower than the RCAA income threshold. However, several census tracts have a median household income above $132,844 (Map 2-9). The three census tracts with median household income above $132,844 and have at least 80% of its households characterized by non-Hispanic Whites are located in Northeast area of the City, as shown in Map 2-10. 3 In response to the R/ECAPs utilized by HUD in its 2015 AFFH rule, scholars at the University of Minnesota Humphrey School of Public Affairs have created the Racially Concentrated Areas of Affluence (RCAAs) metric to more fully tell the story of segregation in the United States.64 Based on their research, RCAAs are defined as census tracts where 1) 80 percent or more of the population is white, and 2) the median household income is $125,000 or greater (slightly more than double the national the median household income in 2016). While this is a useful measure nationwide, HCD has adjusted the RCAA methodology to better reflect California’s relative diversity. 8.B.g Packet Pg. 489 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 49 City of Santa Monica | 2021 - 2029 Housing Element Map 2-9: Median Household Income Over $130,844 Map 2-10: Racially or Ethnically Concentrated Areas of Affluence 8.B.g Packet Pg. 490 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 50Chapter 2 | Assessment of Fair Housing in the City 3. Disability Status A “disability” is defined as a long-lasting physical, mental, or emotional condition. This can include those with vision, hearing, ambulatory, cognitive, self-care, and independent living disabilities. As further detailed in Appendix B, there are 8,841 Santa Monica residents with at least one disability in 2019. Map 2-11 shows the population of persons with a disability by census tract in the City. The map reveals a slightly higher concentration of residents with disabilities in Downtown and the census tracts to the north and east. This may indicate that persons with a disability have a slight preference for areas nearer to the beach – likely due to a combination of elderly housing sites, concentration of amenities including public transportation, and population density near the coast. As described in the 2020 AFH report, the primary option for affordable housing for people with disabilities is Housing Choice Vouchers, of which people with disabilities make up more than 50% of residents. In 2020, five hundred twenty-two (522) people with disabilities reside in units assisted with Housing Choice Vouchers in Santa Monica, but this does not represent a proxy for actual affordable, accessible units. Rather, Housing Choice Vouchers are a mechanism for bringing otherwise unaffordable housing, which may or may not be accessible, within reach of low-income people with disabilities. Map 2-11: Persons with a Disability 8.B.g Packet Pg. 491 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 51 City of Santa Monica | 2021 - 2029 Housing Element 4. Familial Status The Fair Housing Act (FHA) bans discrimination based on certain protected classes, including “familial status” which refers to households with at least one child under 18 years old. Appendix B indicates that in 2019, there were 7,750 family households with children under 18 years of age representing 17% of the City’s total households. Of this number, 5,716 are married couple family households, 1,381 are Female-Headed Households (no spouse), and 653 are Male-headed households (no spouse). Married couple families predominantly reside in the R-1 neighborhoods of the City as compared to single female headed families who are located in R-2 and R-3 neighborhoods. Map 2-12: Married Couple Family Households with Children Under 18 45,309 Households in the City 17% Family Households with Children Under 18 26% Family Households with Children are Single Parent (no spouse) 8.B.g Packet Pg. 492 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 52Chapter 2 | Assessment of Fair Housing in the City Map 2-13: Female Headed Households with Children Under 18 C. Disparities In Access To Opportunity Where a person lives greatly influences their life outcomes. Housing and neighborhood choice are cornerstones of measuring fair housing and resident stability. A person’s educational attainment, economic mobility, health and well-being, to name a few, are directly impacted by exposure to poverty, neighborhood condition, and access to key opportunities such as high quality schools, jobs, transportation, economic development, and a healthy physical environment. Several agencies, including HUD and HCD in coordination with the California Tax Credit Allocation Committee (TCAC), have developed methodologies to assess and measure geographic disparities in access to opportunity (including education, poverty, transportation, and employment, and environmentally healthy neighborhoods) for areas throughout California. HUD’s opportunity indices compare data indicators by race and ethnicity, for households below the poverty line, between jurisdictions and for the region overall. Figure 2-2 provides the City’s opportunity indices by census tracts or census block groups and Figure 2-3 provides indices by race. 8.B.g Packet Pg. 493 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 53 City of Santa Monica | 2021 - 2029 Housing Element Figure 2-2: Santa Monica Access to Opportunity Indices Census Tract Block Group School Proficiency Jobs Proficiency Labor Market Index Low Transportation Cost Environmental Health Low Poverty Index 701201 1 98 87 81 86 19 86 2 96 91 3 96 91 4 98 87 5 98 91 701202 1 96 92 97 74 7 7429893 701302 1 97 94 98 69 6 69 2 97 93 701304 1 99 88 97 70 0 7029891 3 99 92 4 97 93 701402 1 98 94 90 61 0 6129893 3 98 93 4 97 94 701501 1 96 94 96 77 4 7729895 3 97 94 701502 1 85 94 87 57 3 5728595 3 97 94 701601 1 66 93 95 93 8 9329693 3 96 93 4 96 93 701602 1 85 94 98 54 3 5428593 3 85 94 701701 1 85 94 73 64 3 6428594 3 85 94 701702 1 85 94 91 31 3 31 2 85 95 3 97 94 8.B.g Packet Pg. 494 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 54Chapter 2 | Assessment of Fair Housing in the City Census Tract Block Group School Proficiency Jobs Proficiency Labor Market Index Low Transportation Cost Environmental Health Low Poverty Index 701801 1 84 95 50 46 4 46 2 87 94 3 87 94 4 87 94 5 85 94 701802 1 84 94 44 40 5 4028494 3 71 94 4 73 95 701902 1 95 93 61 39 0 3929593 3 89 93 702002 1 48 93 87 55 0 5527692 3 76 93 4 76 93 702102 1 48 88 89 59 0 59 2 76 85 3 76 87 4 48 88 5 76 89 6 76 89 7 76 87 702201 1 90 92 92 71 8 7128591 3 85 93 4 71 93 5 71 91 702202 1 85 87 94 70 7 70 2 90 89 3 90 86 4 90 87 5 85 89 702300 1 93 93 84 65 4 65 2 70 89 3 93 92 4 93 93 5 93 93 8.B.g Packet Pg. 495 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure 2-3: Summary of the Opportunity Indicators by Race (Santa Monica, CA CDBG) Jurisdiction School Proficiency Index Labor Market Index Jobs Proximity Index Transit Index Low Transportation Cost Index Low Poverty Index Environmental Health Index Total Population White, Non-Hispanic 86.33 87.43 92.18 87.66 93.17 64.91 13.74 Black, Non-Hispanic 84.72 75.22 93.11 87.29 94.69 54.14 11.93 Hispanic 84.48 76.93 92.79 87.25 94.17 58.25 11.62 Asian or Pacific Islander, Non-Hispanic 86.66 83.66 92.59 87.15 93.36 63.72 12.73 Native American, Non-Hispanic 83.10 81.09 92.34 87.47 94.50 57.87 11.69 Population below federal poverty line White, Non-Hispanic 85.69 84.64 92.66 87.88 94.52 59.57 13.05 Black, Non-Hispanic 84.21 64.98 93.53 86.65 95.30 47.35 11.71 Hispanic 82.94 65.98 93.39 86.56 94.37 52.04 10.14 Asian or Pacific Islander, Non-Hispanic 84.85 83.21 92.67 86.81 93.67 57.06 10.83 Native American, Non-Hispanic 80.85 81.52 92.92 88.49 95.84 47.65 12.84 (Los Angeles-Long Beach-Anaheim, CA) Region Total Population White, Non-Hispanic 67.87 67.43 54.59 76.59 79.87 65.19 21.35 Black, Non-Hispanic 31.89 35.34 40.72 81.34 83.42 36.07 11.92 Hispanic 37.09 35.73 43.70 80.65 83.98 35.53 12.36 Asian or Pacific Islander, Non-Hispanic 62.18 57.64 51.11 78.82 82.35 55.03 13.13 Native American, Non-Hispanic 49.49 48.58 45.88 78.04 81.53 48.40 17.68 Population below federal poverty line White, Non-Hispanic 59.42 59.62 56.98 80.43 84.23 53.66 18.46 Black, Non-Hispanic 24.68 26.41 36.90 83.34 85.48 24.12 11.74 Hispanic 30.68 29.50 44.63 83.28 86.96 25.05 10.63 Asian or Pacific Islander, Non-Hispanic 57.18 51.41 52.88 82.27 86.69 45.45 11.05 Native American, Non-Hispanic 37.54 36.05 47.65 80.82 84.18 33.63 16.22 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; NATANote 2: To generate this table, index values were calculated for each census tract. These tract values were averaged and then weighted based on the distribution of people of different races and ethnicities within the CDBG jurisdiction, HOME jurisdiction, or CBSA to generate composite index values for each race and ethnicity. A similar process was applied to weight the data based on the distribution of people of different races and ethnicities who are living below the federal poverty line within the CDBG or HOME jurisdiction and CBSA. The population estimates are based on the 2010 Decennial Census at the census tract or block-group level, depending on the geographic level at which the index was originally calculated. Released June 2020 8.B.g Packet Pg. 496 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in 56Chapter 2 | Assessment of Fair Housing in the City TCAC has also prepared opportunity maps to identify areas with the highest and lowest resources. The high resource areas are those areas, according to research, that offer low-income children and adults the best chance at economic advancement, high educational attainment, and good physical and mental health. As shown in Map 2-14 below, the City is generally considered a high resource, with census tract 701802 and 701801 having slightly less resource than the remaining areas of the City. Map 2-14: High Resource Areas The City’s designation as a high resource area is largely attributed to the availability of high performing schools, numerous employment opportunities, easy access to low cost transportation, and environmentally healthy neighborhoods. The analysis of Access to Opportunity summarized below is based on the AFH: 1. Access to Schools Since there are only three middle/high schools in Santa Monica, disparities in school proficiency are most relevant to elementary school education. This is especially true because elementary school education builds the foundation for success in secondary and post-secondary education, and those without a strong foundation often struggle to catch up to their peers as they mature. As illustrated by Map 2-15, the northern half of the City has significantly higher school proficiency index numbers than the southern half, with a notable dip in proficiency in the Pico, Mid-City, and Ocean Park neighborhoods. This closely correlates with wealthier households, single-unit zoning, and concentrations of White 8.B.g Packet Pg. 497 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 57 City of Santa Monica | 2021 - 2029 Housing Element households. Despite these internal disparities, children in the City regardless of race generally have very high access to proficient schools, with most school proficiency index numbers above the 70s. With such proficient schools, Santa Monica generally far outperforms the region as a whole. Map 2-15: School Proficiency Index Map 2. Access to Employment In the City of Santa Monica, disparities in job proximity are generally modest with Black residents experiencing greater slightly greater job proximity followed by Hispanic and Asian American and Pacific Islander residents, with White residents having the lowest job proximity. This indicates that people of color in the City are more likely to live closer to their jobs, within the commercial areas. With respect to labor market engagement, disparities are somewhat larger. The order in which groups live in neighborhoods with high labor market engagement is, for the most part, reversed (meaning that Whites tend to live in areas with higher labor market engagement while population of color tend to live in areas with lower labor market engagement). One qualification to that overall trend is that Asian Americans and Pacific Islanders live in areas with significantly higher labor market engagement than do Hispanics. In the City of Santa Monica, disparities in labor market engagement, but not in job proximity, are driven by residential patterns. Black and Hispanic residents, including residents of Mexican national origin, are disproportionately likely to live in the Pico neighborhood while areas such as North of Montana, 8.B.g Packet Pg. 498 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 58Chapter 2 | Assessment of Fair Housing in the City North of Wilshire, and Sunset Park are more heavily White. As shown in Map 2-16, two Census Tracts that include parts of the Pico neighborhood have Labor Market Indices of 44 and 50, respectively. Of the nine Block Groups in those two Census Tracts, seven are majority non-White. At the same time, the vast majority of Block Groups in Census Tracts with Labor Market Indices of 90 or above have White population concentrations of 70% or more. White residents live in areas that, by far, have the highest labor market engagement. Asian American and Pacific Islander residents live in areas with significantly lower labor market engagement, but the difference is most dramatic for Black and Hispanic residents. In the region, there are virtually no differences in job proximity by race and ethnicity. Hispanic residents have slightly lower job proximity than other groups, but the disparity is minute. With respect to labor market engagement, however, there are significant disparities. In the region, areas with high labor market engagement are areas with disproportionately high White populations including the City of Santa Monica, westside neighborhoods within Los Angeles such as West Los Angeles, and adjacent cities like West Hollywood and Beverly Hills; neighborhoods of Los Angeles within communities in the southern or western portion of the San Fernando Valley including like Sherman Oaks, Encino, Tarzana, and Woodland Hills; the cities of Pasadena; Manhattan Beach, Hermosa Beach, Redondo Beach, and Palos Verdes in southern Los Angeles County; and most of Orange County outside of the diverse communities of Anaheim, Garden Grove, Santa Ana, and Westminster. Map 2-16: Labor Market Engagement Index Map 8.B.g Packet Pg. 499 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 59 City of Santa Monica | 2021 - 2029 Housing Element 3. Access to Transportation The City of Santa Monica has very high levels of utilization of transit. Overall, as shown in Map 2-17, there is very good access to low-cost public transportation, with high transportation indices (i.e., high access to transportation) for the census tracts located along the City’s major boulevards (Wilshire Boulevard, Santa Monica Boulevard, Colorado Avenue). The areas with the lowest access to low-cost transportation (lowest transportation cost index), such as the northeast tract, also have the lowest levels of public transit utilization. Santa Monica is serviced by the Metro “E” (Expo) Light Rail Line, which directly connects Santa Monica to Downtown Los Angeles by rail, and provides for additional rail access to as well as Pasadena, the San Fernando Valley, the South Bay, Long Beach, and points in between. The City is also serviced by Big Blue Bus, which departs the LAX City Bus Center with two lines that run through Santa Monica. These connections to and the extensive LA Metro bus system and light rail network help to make the Region’s transportation system fairly integrated. Santa Monica is fairly small and compact, and well-serviced by public transport. There do not seem to be any great disparities based on residential living patterns. In the Region, however, disparities in access to transportation are far more evident, and heavily dependent on residential living patterns. Map 2-17: Low Transportation Cost Index Map 8.B.g Packet Pg. 500 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 60Chapter 2 | Assessment of Fair Housing in the City 4. Access to Low Poverty Neighborhoods In the City of Santa Monica, access to low poverty neighborhoods is closely linked to residential patterns of racial and ethnic concentration. Map 2-18 shows the low poverty indices for the City. The areas with the lowest Low Poverty Indices and thus the highest concentrations of poverty are in the Pico neighborhood and the immediate vicinity of Downtown Santa Monica. These areas have higher concentrations of Black and Hispanic households than the city as a whole. By contrast, the North of Wilshire and North of Montana neighborhoods, with higher White populations, both have higher Low Poverty Indices and thus lower concentrations of poverty In the City of Santa Monica, Black and Hispanic households have lower access to low poverty neighborhoods than do White and Asian American or Pacific Islander households. The disparities are significant but not extreme. Map 2-18: Low Poverty Index 5. Access to Environmentally Healthy Neighborhoods Map 2-19 which shows the Environmental Health Hazard indices across the City and substantiates the view that there are significant differences in environmental health between neighborhoods and that those disparities are correlated with neighborhood demographics. The eastern area of NOMA and Northeast neighborhood of the City are the most environmentally healthy than other areas in the City, and have the highest environmental health indices. The Pico neighborhood, current and former industrial areas of the Industrial Conservation zones, and Downtown Santa Monica are more heavily affected by their proximity to the I-10 freeway than are more heavily White neighborhoods 8.B.g Packet Pg. 501 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 61 City of Santa Monica | 2021 - 2029 Housing Element like North of Wilshire and North of Montana. The Pico neighborhood and Downtown Santa Monica have the lowest Environmental Health Hazard indices, indicating adverse environmental conditions, while the North of Montana neighborhood has the highest indices (Map 2-19). Map 2-19: Environmental Health Index Green spaces like Reed Park help to improve the health of a neighborhood, whereas industrial uses like the City Yards in the Pico neighborhood negatively impact the health of a neighborhood. 8.B.g Packet Pg. 502 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 62Chapter 2 | Assessment of Fair Housing in the City D. Disproportionate Housing Needs Disproportionate Housing Needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. According to the California Department of Housing and Community Development, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions. 1. Cost Burden and Overpayment The general rule is that no more than 30% of gross monthly income should be spent on housing. Households that spend more than this percentage are considered to be “housing cost burdened”. Severely cost burdened households are those households spending greater than 50% of income on housing. As further detailed in Appendix B and shown below, renter households are significantly more cost-burdened compared to homeowners, with 31.6 percent of renter households burdened by housing costs compared to 9.5 percent of owner households, as shown by Figure 2-4. The areas with the most cost burdened renter households are located in Downtown, and the areas along the I-10 freeway (Map 2-20), while the areas with the most cost burdened owner households are located in the Downtown, north of Downtown, and a couple census tracts south of the I-10 freeway (Map 2-21). Figure 2-4: Cost Burden and Overpayment for Renters and Homeowners Households Renters Owners Total Renters and Owners Cost Burdened Total Cost Burdened Total Cost Burdened % of Citywide Extremely Low Income (0-30% AMI)5,055 6,145 825 975 7,120 15.4% Very Low Income (31-50% AMI) 2,815 3,320 555 770 26,490 8.8% Low Income (51-80% AMI)2,880 4,220 725 1,180 5,400 11.6% Moderate Income (80-100% AMI)1,690 2,685 320 570 7,120 7.0% Above 100% AMI 2,220 17,135 2,020 9,355 26,490 57.1% Total 14,660 33,505 4,445 12,855 46,360 15.4% % of Total Households 31.6%9.5% 8.B.g Packet Pg. 503 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 63 City of Santa Monica | 2021 - 2029 Housing Element Map 2-20: Cost Burdened Renter Households Map 2-21: Cost Burdened Owner Households 8.B.g Packet Pg. 504 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 64Chapter 2 | Assessment of Fair Housing in the City Even after the 1968 passage of the Fair Housing Act, people of color have continued to experience housing inequalities across the nation and within the City. As described in Appendix B Housing Needs Assessment, Black/African American and Hispanic/Latino households in the City have the lowest homeownership rates at 8% and 18%, respectively, far less than the 30% home ownership rate for White households. Additionally, these households of color pay a greater share of their income towards housing costs given that they have the lowest median household incomes. In the City, Black/African American and Hispanic/Latino households have median incomes of $42,703 and $71,483 respectively, far below the citywide median of $96,570 (Figure 2-5). With the high cost of housing coupled with low wages, approximately 11.7% of Black and 8.6% of Hispanic/Latino family households in the City were cost- burdened even before the COVID19 pandemic. These cost-burdened households are at greater risk of poverty and homelessness. Figure 2-5: Median Household Income by Race Hispanic or Latino White Alone,Not Hispanic Black Asian Two or More Races Some Other Race $109,528 $71,483 $100,691 $42,703 $105,395 $64,444 2. Overcrowding Appendix B provides data on household size and overcrowding. The average household size in the City is 1.99. A housing unit that is occupied by more than one person per room (excluding kitchens, bathrooms, hallways and porches) is defined by U.S. Department of Housing and Urban Development (HUD) as being overcrowded. In 2019, 185 owner occupied households and 1,360 renter occupied households were determined to be overcrowded for a total of 1,545 households (3.2% of total City households). Map 2-22 shows the trends of overcrowded households in the City by census tract. The tract with the most overcrowded households located in Downtown. The percentages of overcrowded households for all census tracts in the City are less than the statewide average of 8.2 percent. 8.B.g Packet Pg. 505 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 65 City of Santa Monica | 2021 - 2029 Housing Element Map 2-22: Overcrowded Households Additionally, Black and Hispanic/Latino Households are more likely to be subject to overcrowding or substandard housing conditions (see Appendix B). 3. Homelessness The surge of homelessness is becoming an urgent reality for many in the City. As detailed further in Appendix B, based on the most recent point in time count, there are approximately 907 homeless individuals in Santa Monica on any given night. In the greater LA region, that number is closer to 66,000. Rising rents, stagnant wages, and a decreased supply of affordable housing means that almost 7,000 people in LA County lose their housing every month. While the last count in 2020 showed positive results including an 8% decrease in Santa Monica compared to a 13% increase countywide, COVID-19 has exacerbated Los Angeles County’s twin crises of housing and homelessness, and stymied interventions due to limited shelter capacity and an overburdened court system. Racial inequities in housing undoubtedly has worsened due to the pandemic. While the pandemic has affected employment nationwide, its effects have been disproportionate. The job loss has been particularly dire for Blacks/African American and Latinos who experienced exceptionally high levels of unemployment and slow rates of job recovery, and therefore, are most vulnerable to losing their homes. 8.B.g Packet Pg. 506 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 66Chapter 2 | Assessment of Fair Housing in the City Figure 2-6: Santa Monica Homeless Count, 2015 - 2020 200 400 600 800 1000 1200 0 2015 2016 2017 2018 2019 2020 4. Substandard Housing Conditions Most residential structures begin to show signs of deterioration as they approach 30 years, and often begin to require rehabilitation work to their major components, such as roofing, siding, plumbing, and electrical systems. As provided in greater detail in Appendix B, the 2019 ACS data show that almost 85% of housing in Santa Monica is more than 30 years old (i.e., built before 1990). This is much higher than the 68% measured in 2000, because Santa Monica experienced a major multi-unit construction boom in the 1970s. The age of a structure does not necessarily equate to substandard conditions, however. Over time, building owners may have performed improvements as necessary to keep the unit in competitive market. Furthermore, many units may have been rehabilitated following the 1994 Northridge Earthquake, which resulted in many buildings being damaged. Another tool to evaluate the condition of housing is through review of Code Enforcement cases regarding violations of the City’s as well as building and safety codes. Since 2015, the City has opened 222 Code violations related to substandard housing conditions. COVID-19 Effects on People of Color • Almost quarter of Black and Latino renters did not pay or deferred rent in May 2020, compared with 14 percent of white renters. • While a quarter of white renters expressed slight or no confidence in their ability to pay rent in June 2020, nearly half of Black and Latino renters expressed similar concern. Source: US Census Bureau weekly Household Pulse Survey 8.B.g Packet Pg. 507 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 67 City of Santa Monica | 2021 - 2029 Housing Element E. Displacement Risk The Urban Displacement Project (UDP) is a research initiative of UC Berkeley that conducts research related to potential gentrification and displacement risks in various cities, including Santa Monica and Los Angeles. Risks are based on a number of factors, such as income levels of households, diversity of neighborhoods, and changing housing costs. Map 2-23 shows the displacement assessment of census tracts in the City. As shown, Census Tract 701802 is the most vulnerable to displacement. Based on the City’s review of residential buildings that are older than 1980 (i.e. more than 40 years old) and that are underdeveloped relative to its underlying maximum allowable density, up to 274 units are considered at risk of displacement in this census tract. Map 2-23: Displacement Risk in the City F. Fair Housing Issues And Local Contributing Factors During the preparation of the AFH, the City led numerous outreach efforts with various stakeholders and conducted extensive analysis to identify factors that are barriers to fair housing. These factors were prioritized as shown in Figure 2-7. 8.B.g Packet Pg. 508 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 68Chapter 2 | Assessment of Fair Housing in the City Figure 2-7: Barriers to Fair Housing High Priority 1. Displacement of residents due to economic pressures 2. Impediments to mobility 3. Lack of access to opportunity due to high housing costs 4. Lack of affordable, accessible housing in a range of unit sizes 5. Land use and zoning laws 6. Private discrimination Medium Priority 1. Availability of affordable units in a range of sizes 2. Community Opposition 3. Lack of affordable, integrated housing for individuals who need supportive services 4. Lack of assistance for transitioning from institutional settings to integrated housing 5. Lack of local or regional cooperation 6. Lack of meaningful language access for individuals with limited English proficiency 7. Location and type of affordable housing 8. Location of proficient schools and school assignment policies 9. Loss of affordable housing 10. Siting selection policies, practices, and decisions for publicly supported housing, including discretionary aspects of Qualified Allocation Plans and other programs 11. Source of income discrimination Low Priority 1. Access for persons with disabilities to proficient schools 2. Access to financial services 3. Access to publicly supported housing for persons with disabilities 4. Access to transportation for persons with disabilities 5. Admissions and occupancy policies and procedures, including preferences in publicly supported housing 6. Availability, type, frequency, and reliability of public transportation 7. Deteriorated and abandoned properties 8. Displacement of and/or lack of housing support for victims of domestic violence, dating violence, sexual assault, and stalking 9. Inaccessible public or private infrastructure 10. Inaccessible government facilities or services 11. Lack of affordable in-home or community-based supportive services 12. Lack of assistance for housing accessibility modifications 13. Lack of community revitalization strategies 14. Lack of local private fair housing outreach and enforcement 15. Lack of local public fair housing enforcement 16. Lack of public investment in specific neighborhoods, including services or amenities 17. Lack of private investment in specific neighborhoods 18. Lack of resources for fair housing agencies and organizations 19. Lack of state or local fair housing laws 20. Lending discrimination 21. Location of accessible housing 22. Location of employers 23. Location of environmental health hazards 24. Occupancy codes and restrictions 25. Quality of affordable housing information programs 26. Regulatory barriers to providing housing and supportive services for persons with disabilities 8.B.g Packet Pg. 509 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 69 City of Santa Monica | 2021 - 2029 Housing Element The “High Priority” factors identified in the AFH are consistent with public input received during the public outreach process for the Housing Element (see Appendix A). While the City has been a leader in the production of affordable housing for the past few decades and implements a number of actions and programs to address fair housing, factors such as the high cost of housing, existing zoning, and economic pressures compounded with patterns of segregation have made it very difficult for households of color to live in the City. These factors are summarized briefly below in Figure 2-8: Figure 2-8: Summary of Fair Housing Issues and Local Conditions Fair Housing Issue Identified High Priority Significant Contributing Factors Integration and Segregation; Disproportionate Housing Needs; Publicly Supported Housing Displacement of residents due to economic pressures Santa Monica’s rent control law applies to most residential rental buildings constructed prior to 1979 and to certain single-family homes and condos. However, the Costa-Hawkins Rental Housing Act allows owners to raise the rents of rent- controlled units when tenants relocate or are evicted for non-payment. In addition, the Ellis Act gives property owners the right to exit the rental business, thereby evicting all of their tenants in one fell swoop (usually in the wake of a major remodel or transitioning to condo ownership). Rent-control evictions are on the rise in Santa Monica. Integration and Segregation; Disparities in Access to Opportunity; Publicly Supported Housing Impediments to Mobility There is not a mobility counseling program for Housing Choice Voucher holders assisted by the largest public housing authorities in the Region: the Housing Authority of the City of Los Angeles and the Housing Authority of the County of Los Angeles. As a result, there are informational gaps that impede some residents of heavily Black and Hispanic neighborhoods in the Region from utilizing their assistance to move to high opportunity areas like Santa Monica, other parts of the West Side, coastal and southern Orange County, and the southwestern portions of the San Fernando Valley. Because of the small geographic footprint of the City of Santa Monica, the lack of mobility counseling is a less significant reinforcement of segregation in that local context. Additionally, although the Santa Monica Housing Authority utilizes exception payment standards to bring more apartments in Santa Monica within reach of Housing Choice Voucher holders, housing costs are so high in the city that even higher payment standards may be appropriate. Disparities in Access to Opportunity; Disproportionate Housing Needs; Publicly Supported Housing High housing costs Housing prices within the city of Santa Monica are very high as indicated in Appendix B. Despite the high costs, Santa Monica has taken steps to protect housing stock. The city charter has an inclusionary zoning provision that requires not less than 30% of all newly constructed multifamily housing to be reserved for moderate or low-income families. Santa Monica has also implemented rent control since 1979. It covers all units constructed prior to passage, some units constructed after passage, and in contrast to typical rent control provisions, also covers some single family homes. In the past few Housing Element cycles, Santa Monica has exceeded its RHNA for low income units In addition, there are approximately 1,000 LIHTC units currently in existence and earmarked for low-income households. However, these provisions largely protect those living in currently Santa Monica. Despite proximity to Los Angeles and the existence of opportunities within the city, those who don’t currently live in Santa Monica are priced out of living in the city and accessing resources or opportunity the city has to offer. Based on income and family sizes, those who are priced out will tend to be disproportionately Black, Hispanic, and with larger families. 8.B.g Packet Pg. 510 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 70Chapter 2 | Assessment of Fair Housing in the City Fair Housing Issue Identified High Priority Significant Contributing Factors Integration and Segregation; Disproportionate Housing Needs Lack of affordable, accessible housing in a range of unit sizes Persons with disabilities in Santa Monica disproportionately have low incomes and live in poverty, thus increasing their relative need for affordable housing. In light of the broader affordable housing shortage in the city and the Region, there is a shortage for persons with disabilities. The vast majority of LIHTC units in the area were put into service from 1991-onward, thus conforming with modern accessibility standards. Publicly supported housing is also subject to the modification requirements of Section 504 of the Rehabilitation Act. Nevertheless, new affordable, multifamily units – those that are most likely to be both affordable and accessible – are too few in number to meet the total need. Supportive housing developments often consist primarily or exclusively of one-bedroom apartments. When it comes to supportive housing for persons with disabilities, although the demand likely consists primarily of a need for one-bedroom units, there are individuals at risk of institutionalization who have dependent children and persons with disabilities who need a live-in aide with their own bedroom. Including a mix of a small number of two- and even three-bedroom units in developments with a supportive housing component would foster greater community integration. Segregation, R/ECAPs (in the Region), Disparities in Access to Opportunity, Disproportionate Housing Needs, Publicly Supported Housing, and Disability and Access Land use and zoning laws Santa Monica is very compact, roughly rectangular, abutting the ocean, and just 8.3 square miles. The street layout and zoning and is very efficient, with the downtown area located along the beach and down the center of the city. Single- unit zoning is located on the northern and southern ends of the City, with denser zoning toward the center of the City and the main transportation thoroughfares. Specifically, neighborhoods like North of Montana and Sunset Park that are disproportionately White are primarily zoned for single-family homes. The problem is most severe in the North of Montana neighborhood. The high housing cost of single family homes and the single family home- restricted zoning on either end of the City functionally restricts racial diversity in these neighborhoods, as shown by the disproportionately White and Asian American populations of the neighborhoods. However, Santa Monica has also had an inclusionary housing program in place for 30 years within the Santa Monica Municipal Code (Affordable Housing Production Program) that requires developers to abide by affordable housing requirements, such as designating portions of their buildings for moderate-, low-, very low-, and extremely low-income rental housing. The City also has a Housing Trust Fund to finance the development, construction, and duration of affordable housing. Segregation Private discrimination Given Santa Monica’s very progressive stance and expansive state and local anti-discrimination provisions, the majority of housing discrimination in the city occurs privately, rather than at the hands of the city or state. At Santa Monica Legal Aid, most of the complaints received detail discrimination based on a tenant’s disability, particularly complaints regarding denied request for a reasonable accommodation or modification. The second largest category is Section 8 discrimination, despite Santa Monica’s explicit prohibition against source of income discrimination. The third largest category is discrimination based on familial status. Santa Monica Legal Aid coordinates with the Santa Monica City Attorney’s office to investigate and resolve these complaints, including initiating lawsuits when necessary. 8.B.g Packet Pg. 511 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 71 City of Santa Monica | 2021 - 2029 Housing Element G. Fair Housing Enforcement And Outreach Capacity The City of Santa Monica takes fair housing laws seriously and has enacted a number of local laws in support of fair housing including: • Chapter 4.28 of SMMC, addressing fair housing for families with children, disability, and source of income discrimination • Chapter 4.40 of SMMC addressing fair housing regardless of sexual orientation or domestic partnership • Chapter 4.52 of SMMC addressing fair housing for persons living with HIV/AIDS • Chapter 9.49 of SMMC, addressing reasonable accommodations for persons with disabilities The City continues to promote fair housing and prevent housing discrimination. The Public Rights Division (PRD) of the City Attorney’s Office enforces Fair Housing Laws, and actively accepts, investigates, and resolves fair housing complaints. The PRD does this through sending demand letters to offending parties, coordinating with the Legal Aid Foundation of Los Angeles, and suing offending parties directly. As part of its investigations and enforcement in fair housing case, the City has continued to enforce local ordinance and State law outlawing housing discrimination based on source of income, such as rental housing vouchers. In 2020, the City responded to 43 fair housing complaints, and in fiscal year 2020-2021, the program resulted in ensuring several dozen landlords will accept Section 8 vouchers, in compliance with State law. The City also funds Legal Aid Foundation of Los Angeles (LAFLA) to pursue fair housing enforcement. Additionally, the City’s Code Compliance staff are available to help relocate people, if necessary. The Santa Monica Police Department is also committed to investigating and resolving hate crimes that may occur in the housing context. Unresolved fair housing violations are not a significant contributing factor to fair housing issues, as the City of Santa Monica actively pursues enforcement. 43 Fair housing complaints responded to in 2021 200+ Hours of dedicated City staff time for fair housing outreach and enforcement 13,000 Inquiries on tenant rights handled annually 8.B.g Packet Pg. 512 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 72Chapter 2 | Assessment of Fair Housing in the City The PRD also enforces the City’s Tenant Harassment Ordinance, and the City’s Rent Control Board monitors evictions and advises Santa Monica tenants of their rights. The Rent Control Board continues to engage the community about the protections under Rent Control Law through a number of events and seminars, as well as ongoing one-on-one consultations with tenants and property owners about their rights and responsibilities under the law. More than 13,000 inquiries are handled annually. The Board monitors owner-occupancy evictions to ensure that grounds for eviction is not abused and an inter-departmental task-force addresses issues related to withdrawals under the Ellis Act and the current use of those properties that have been withdrawn from the rental market. Other recent actions the City has enacted to assure that tenants are not discriminated against or harassed by building owners and address fair housing issues, particularly displacement protection, include: • In 2010, the Just Cause Eviction protections that were available only for tenants in rent- controlled units, were extended to all tenants when voters approved Measure RR. • On December 13, 2011, the City Council adopted an ordinance which extended the protections of the Tenant Anti-Harassment Ordinance to all tenants with just cause eviction protections. • In 2015, the City Council amended the City’s fair housing ordinance to include source of income as a protected class and included a pioneering definition of “Source of Income” that included rental housing assistance such as the Section 8 Housing Voucher Program. • On May 22, 2018, the City Council adopted an ordinance which extends specific tenant protections to households with either educators or students under the age of 18 if the notice of termination falls during the school year. • In March of 2020, the City issued the first of a series of emergency orders that protected tenants from evictions during the pandemic and economic emergency. In addition to enforcement, the PRD also annually conducts a campaign to improve community awareness of fair housing laws and spends over $2,500 to undertake fair housing activities including public awareness and advertising in efforts to eliminate housing discrimination in the City. Prior to the COVID19 pandemic, the PRD hosted an annual fair housing workshop that is attended by hundreds of people. The PRD also regularly publishes articles about fair housing in the Santa Monica Daily Press and produces outreach videos on housing. In 2020-2021, the City sponsored or participated in fair housing webinars to promote community awareness and education. Approximately 200 staff hours are dedicated annually in fair housing enforcement work and community outreach. 8.B.g Packet Pg. 513 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 73 City of Santa Monica | 2021 - 2029 Housing Element H. Summary And Actions To Affirmatively Further Fair Housing 1. Current Actions The City of Santa Monica has adopted numerous policies and actions to protect existing housing stock, prevent discrimination, protect tenants from displacement, and increase the supply of affordable housing, including rent control that has been in place for over 40 years. Santa Monica’s anti-discrimination and strong tenant protections include just-cause evictions, anti-tenant harassment laws, and notice of tenant buyouts; prohibitions on source of income discrimination; the Preserving Our Diversity (POD) program which provides cash-based assistance to low-income seniors; and anti- discrimination laws that afford protections beyond the federal Fair Housing Act and the California Fair Employment and Housing Act. A few of Santa Monica’s current actions to enhance housing mobility, provide housing choice and affordability, and prevent displacement are highlighted below: Rent Control Law Santa Monica Rent Control was adopted by the voters in April 1979 in response to a shortage of housing units, low vacancy rates and rapidly rising rents. The law was intended to alleviate the hardship of the housing shortage and to ensure that owners received no more than a fair return. The Regulations were adopted by the Rent Control Board to implement and enforce the Rent Control Law. The rent control provisions cover single-family homes, duplexes, triplexes, and apartment buildings. The City’s rent control provides tenant protections and seeks to preserve existing housing stock and maintain naturally occurring affordable housing for its residents. Primary functions of the Rent Control Board include controlling rent amounts, maintaining amenities and services for tenants, provide for only “just cause” evictions, and limiting the removal of controlled units from the rental market, all in efforts to ensure tenant stability and preserving existing housing stock and its affordability. Under the City’s rent control law, tenants may only be evicted if they are at-fault or the landlord wishes to move themselves or their family into the unit. Proposition R (1990) and the Affordable Housing Production Program Proposition R was passed in 1990 by the voters, and requires that 30% of all new multifamily housing in the City be affordable to low- and moderate-income households. The Affordable Housing Production Program (AHPP) implements Proposition R, making the creation of affordable housing mandatory as part of the development of market-rate apartment and condominium buildings. Developers of new multifamily buildings are required to contribute to affordable housing in Santa Monica, including : • Constructing inclusionary affordable residences onsite in a development. • Constructing affordable residences offsite in another development. • Paying an affordable housing fee that is used by the City to subsidize affordable housing developments and are deposited into the Citywide Housing Trust Fund. 8.B.g Packet Pg. 514 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 74Chapter 2 | Assessment of Fair Housing in the City The City continues to comply with the Proposition R affordable housing production mandate of 30% affordability in the long-term; between fiscal year 1996-97 through FY 2018-19, 38% of all multifamily housing constructed (5,346 total), pursuant to Proposition R, is affordable. The City has exceeded the goals of Proposition R, with 40 percent of all new housing built over the past 20 years being deed- restricted for occupancy by low- and moderate-income households. The City’s Affordable Housing Production Program has produced more than 800 units. Housing Trust Fund Additionally, the City has a Housing Trust Fund. Funds come primarily from redevelopment loan repayments and the stream of ongoing revenue provided by the voter-approved sales tax, Measures GS/GSH. The Housing Trust Funds has supported the production of over 1,200 very low and low-income affordable units over the same time period in addition to acquisition and rehabilitation of existing units and rental subsidies to help keep Santa Monicans housed. Section 8 Housing Choice Voucher Program Santa Monica also has made considerable investments into expanding new housing choice and opportunities for low-income households. The Santa Monica Housing Authority operates the Section 8 Housing Choice Voucher program, which provides rental housing vouchers to extremely low- and very low-income households with rent subsidies to bridge the gap between what the household can afford and market rents. Further, the City has been active in preserving affordable housing for seniors through Project-Based vouchers that fund the rehab of affordable units and prevent them from becoming market rate units. Santa Monica’s Approach to Addressing Homelessness Santa Monica also has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. The City’s homeless service system has evolved significantly over 40 years and is nationally recognized as an innovative model that addresses the complex issues that contribute to long and repeated episodes of homelessness. On March 26, 2019, the City introduced the Four “Pillars” upon which the City’s homeless strategies are built: • Preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities; • Addressing the behavioral health needs of vulnerable residents; • Maintaining equitable access to safe, fun, and healthy open spaces; and • Strengthening regional capacity to address homelessness. 8.B.g Packet Pg. 515 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 75 City of Santa Monica | 2021 - 2029 Housing Element These strategies have been implemented through interdepartmental and community partnerships that contributed to a sustained reduction in homelessness in the downtown and beach areas, as well as an overall 8% reduction in the City’s 2020 Point-In-Time homeless count. In February 2021, in response to the economic and housing challenges brought on by the COVID19 pandemic, the City reaffirmed its commitment to addressing homelessness. In addition to continuing the multi-disciplinary street teams and the Reed Park Ambassador program through June 2023, Council prioritized the following additional strategies for consideration during the forthcoming biennial budget process. • Extended Emergency Rental Assistance to prevent residents from falling into homelessness. • An alternative non-congregate shelter on City property. • A behavioral health triage center. • Low acuity crisis response unit in the Santa Monica Fire Department. Even with the City’s residential protections, programs, and incentives at addressing fair housing issues, the lack of affordable housing to meet the housing needs of low- and moderate income residents, especially for people of color, continue to remain a challenge. Pilot Right to Return Program Most recently on July 13, 2021, Santa Monica City Council made changes to Santa Monica’s Affordable Housing Production Program and Housing Trust Fund to address past urban renewal policies that displaced many households of color. Specifically, the City’s affordable housing waitlist priority will be modified to include those former residents who were displaced by the creation of the Civic Auditorium in the Belmar Triangle neighborhood and I-10 freeway in the Pico neighborhood in the 1950s and 1960s. The pilot program is part of the City’s commitment to equity and inclusion. 2. Future Actions This Housing Element includes policies and programs further outlining the City’s commitment to remedying the legacy of past housing discrimination practices, breaking down the patterns of segregation , and ensuring fair housing opportunities to all. Chapter 5 of this Housing Element includes programs that provide address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization, and displacement protection These programs are described briefly below : 8.B.g Packet Pg. 516 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 76Chapter 2 | Assessment of Fair Housing in the City Enhancing Housing Mobility Housing Mobility Strategies consist of removing barriers to housing in areas of opportunity and strategically enhancing access. This Housing Element sets forth the following programs that will enhance housing mobility: • Program 1.C – Incentivize Housing Development On Surface Parking Lots In Residential Zones That Are Associated With Existing Commercial Uses Under Program 1.C, the existing zoning barriers to housing on surface parking lots in the R1 and multiunit residential zones would be removed. Specifically, current zoning restricts the development of surface parking lots that are located in the residential zones. Current zoning limits where vehicular access can be taken on these parcels and also caps the number of residential units that could be developed (e..g, density cap of 4, 5, or 6 units), Program 1.C would remove these existing land use and zoning constraints to housing and adopt new standards to encourage housing projects on surface parking lots. This program would promote access to multifamily housing in the high opportunity areas of R1 and the multiunit residential (R2, R3, R4, OP2, OP3, and OP4) neighborhoods. • Program 3.B - Develop Tenant and Landlord Programs to Address State and Federal Legislation Mandated Regarding Anti-Discrimination Under program 3.B, the City shall continue to implement programs, including tenant and landlord education/outreach, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts. Currently, the City has several progressive legal protection programs, such as just-cause eviction protections and a new 2-year pilot Right to Counsel program to assist tenants facing evictions. • Program 3.C- Facilitate the Conservation of Restricted and Non-Restricted At-Risk Housing Under Program 3.C the City will continue to provide information on maintaining long-term affordability and assist federally-funded housing properties with seeking funding assistance by applying for allocations of housing vouchers from the federal government to maintain housing affordability. • Program 6.A - Maintain Rental Housing Voucher Programs And Expand To Assist All Persons With Disabilities Under Program 6.A, the City will continue to: • Maintain and operate the Section 8, Housing Choice Voucher Program • Maintain a City-wide list of affordable rental vacancies in partnership with Community Corporation of Santa Monica 8.B.g Packet Pg. 517 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 77 City of Santa Monica | 2021 - 2029 Housing Element • Program 6.D - Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources Under Program 6.D, the City will continue to: • Provide education and outreach to tenants and landlords to increase awareness about federal and local housing programs, including Section 8 housing voucher programs • Provide education and outreach to tenants and landlords to increase awareness about federal and local housing rights and legal obligations, including anti- discrimination regarding source of income • Enforce the Affirmative Marketing Policies that are required as part of HOME- assisted rental development Providing New Housing Choices and Affordability in High Opportunity Areas Housing choice strategies promote the housing supply, choices and affordability in areas of high opportunity and outside of areas of concentrated poverty. This Housing Element sets forth the following programs that will provide new housing choices and affordability in high opportunity areas: • Program 1.C - Incentivize Housing Development On Surface Parking Lots In Residential Zones That Are Associated With Existing Commercial Uses As discussed previously, current zoning restricts the development of surface parking lots that are located in the residential zones. Program 1.C would remove these existing land use and zoning constraints to increase housing in the high opportunity areas of R1 and the multiunit (R2, R3, R4, OP2, OP3, and OP4) neighborhoods. • Program 1.J - Revise Development Standards To Ensure Housing Projects are Feasible Incentivized Over Commercial Development. In some areas of the City, such as the Neighborhood Commercial districts of Main Street and Montana Avenue, housing is a permitted use. However, due to a number of factors including zoning code limitations on development, housing has not traditionally occurred in these areas. Furthermore, a financial analysis on residential development standards Programs to enhance housing mobility also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Impediments to mobility • Lack of access to opportunity due to high housing costs • Lack of affordable, accessible housing in a range of unit sizes • Land use and zoning laws • Private Discrimination 8.B.g Packet Pg. 518 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 78Chapter 2 | Assessment of Fair Housing in the City prepared for the City indicate that housing projects are unlikely to occur in the remaining mixed-use areas of the City such as the boulevards, and Bergamot Area due to land use and zoning restrictions on height and floor area ratios. To incentive housing, Program 4.B would rezone and modify the development standards in all the mixed-use and commercial zoning districts to allow housing projects to have greater density and height than commercial projects. This program would incentivize housing over commercial and create new housing choice. • Program 4.C - Provide New Housing Choices And Affordability In High Opportunity Areas Through Incentives For Additional ADUs In R1-Zone Neighborhoods 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. 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. Under State law, properties are permitted to have one ADU and one JADU. This program will further allow one more ADU on single-unit dwelling parcels with the requirement that the additional third ADU be restricted to permanent rental housing. This program will incentivize the production of ADUs thus providing new housing choice and affordability in the high opportunity areas of the R1 neighborhoods. • Program 2.A - Establish a 100% Moderate Income Housing Overlay Moderate Income housing projects currently have no dedicated funding source or incentives under local or State law. Since AB 1763 only applies to projects up to 80% AMI and the City’s Zoning Ordinance similarly defines 100% affordable housing as only including projects up to 80% AMI, there are no incentives for moderate income housing projects (serving households up to 120% AMI). In the 5th Cycle Housing Element, Santa Monica did not meet its RHNA targets for moderate income units. Moderate-income housing units serve an important segment of Santa Monica workers and residents that do not qualify for lower-income affordable units yet cannot afford market rents. Program 2.A would create a new zoning overlay to incentivize moderate income housing projects in the targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th St station. 100% Moderate Income housing projects would be incentivized through special standards such as additional height (at least 33 feet additionally), density bonus, and reduced parking requirements. This program will incentivize the production of moderate-income housing thus providing new housing choice and affordability in the high opportunity areas around the Metro E transit stations. 8.B.g Packet Pg. 519 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 79 City of Santa Monica | 2021 - 2029 Housing Element • Program 2.C Update the City’s Affordable Housing Production Program (AHPP) to Incentivize Housing Production at All Income Levels The City’s long established AHPP program has produced over 800 affordable units – expanding housing choice and affordability for many Santa Monica residents. Despite the success of the AHPP, there is still a significant gap between the housing needs of low-income households and the availability of affordable units. To further incentivize the production of affordable units at various income levels, Program 2.C would establish a new base affordability percentage of 15% for with the inclusionary units provided equally among very low-, low- and moderate-income levels. Program 2.C would also establish new more flexible requirements for in-lieu fees and off-site affordable housing. • Program 4.A - Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Nonresidential Zones Where Not Currently Permitted Currently, multi-unit residential is not permitted in certain commercial areas of the City; namely, the Industrial Conservation District, Office Campus, Creative Arts Center, and Conservation Creative Sector. Residential uses are not permitted in these zones, even though there may be existing residential uses that were developed in the past. Furthermore, areas within some of these zoning districts have significant housing potential with access to residential amenities, such as transit, commercial uses, parks, schools, and infrastructure. Program 4.A would add housing as a permitted use in these zones, creating new housing choices and affordability. • Program 4.B - Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses Parking lots of religious congregations are largely located in multi-unit residential zones presenting a unique opportunity to expand housing choice in these areas. During the Housing Element outreach process, the City met with a variety of religious congregations through the Westside Interfaith Council. A handful of congregations have expressed strong interest in developing affordable housing on the parking lots of their sites. This program would adopt special standards in the Zoning Ordinance to support the production of affordable housing on surface parking lots owned by community assembly uses, which include religious congregations, including allowing some, but not more than 50%, market- rate units to support the affordable housing. With this program, properties associated with religious congregations and other community assembly uses in the multi-unit residential zones would be opened to new housing opportunities. • Program 6.H - Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing In the 2015 Zoning Ordinance update, Santa Monica adapted reasonable accommodation procedures (SMMC Chapter 9.49) that specify the applicability of eligible applicants and 8.B.g Packet Pg. 520 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 80Chapter 2 | Assessment of Fair Housing in the City requests, application requirements, reviewing authority and procedures, findings and decisions, appeal process, and the duration limits of the accommodation. The City will maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws. Place-based Strategies to Encourage Community Conservation and Revitalization: These strategies involve approaches that are focused on conserving and improving assets in areas of lower opportunity and concentrated poverty such as targeted investment in neighborhood revitalization, preserving or rehabilitating existing affordable housing, improving infrastructure, schools, employment, parks, transportation and other community amenities. As a compact city of 8.3 square miles with a costly housing market, the City doesn’t have the same level of distinct lower opportunity and concentrated poverty areas as other cities in the Region, such as the City of Los Angeles. This is evidenced by the fact that the entire City is considered to be a high opportunity area. Even so, some census tracts particularly adjacent to the I-10 freeway may have slightly less resources and opportunity than others. Therefore, this Housing Element sets forth the following programs that will provide promote community conservation and revitalization: • Program 3.C - Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing. The City monitors the status of at-risk projects within the City, advise tenants in advance of potential conversion dates, and assist in answering questions from residents of at risk housing. The City will continue these actions and exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. • Program 3.D - Maintain An Acquisition And Rehabilitation Program The City provides Housing Trust Fund loans to nonprofit housing providers to assist with the purchase and rehabilitation of existing rental properties occupied primarily by low-income households. As resources are available, the City will continue to provide loan assistance to nonprofit affordable housing providers and work with providers to identify new funding sources. Programs to enhance housing choice in high opportunity areas also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Impediments to mobility • High housing cost• Lack of access to opportunity due to high housing costs • Lack of affordable, accessible housing in a range of unit sizes • Land use and zoning laws 8.B.g Packet Pg. 521 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 81 City of Santa Monica | 2021 - 2029 Housing Element • Program 3.E - Maintain A Low Income Residential Repair Program The City implements the Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants; and the Owner-Occupied Rehabilitation Program for low- and moderate-income owners. Minor home modifications improve physical access for people with disabilities and seniors that assist with independent living. The City will continue to implement this program. • Program 3.F - Enhance Code Enforcement Response To Housing-Related Violations The City’s Code Enforcement and Building and Safety Divisions respond to residential building code violation complaints. The City will continue this program and will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. • Program 3.H - Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units The City will continue to provide additional education and outreach to multi-unit property owners on available City programs and support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. • Program 6.B - Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement The City will continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance to the extent feasible. • Program 6.C - Maintain And Expand The Preserving Our Diversity (POD) Program The City will continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. Programs to encourage community conservation and revitalization also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Displacement of Residents due to Economic Pressures• High housing cost• Lack of affordable, accessible housing in a range of unit sizes 8.B.g Packet Pg. 522 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 82Chapter 2 | Assessment of Fair Housing in the City Displacement Protection As discussed previously, while the City already implements a number of programs and actions aimed at keeping residents housed, the inevitable economic pressures of the housing market have resulted in the displacement of residents. A fundamental guiding principle of the Housing Element is the preservation of existing housing stock. The primary reason why the existing multi-unit zones (R2, R3, R4, OP2, OP3, and OP4) are not being proposed for rezoning is due to the fact that most of the City’s rent control housing stock are located in these areas. Map 2-24: Zoning and Rent Control Units These rent control units play an important role in keeping housing affordable to existing residents and helping to ensure their long-term tenancy. Any proposed increase to density in the multi-unit residential zones would make these units vulnerable to redevelopment, potentially forcing Santa Monica renters out of their homes. Therefore, this Housing Element does not propose any zone changes in the multi-unit residential zones. In addition to this community preservation approach, this Housing Element also sets forth the following programs to further provide displacement protection for existing residents: • Program 2.B - Right of First Offer Ordinance for Nonprofit Affordable Housing Providers The City will adopt a Right of First Offer Ordinance that would require that qualified nonprofit organizations would be offered the right of first offer/refusal to purchase private properties 8.B.g Packet Pg. 523 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 83 City of Santa Monica | 2021 - 2029 Housing Element offered for sale in the City. This program would provide existing residents the opportunity to maintain their housing at an affordable level and minimize overall tenant displacement. • Program 3.A - Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are Replaced The City will amend the Municipal Code to adopt local requirements that require housing projects replace existing and former residential units in the past 5 years consistent with the requirements set forth in Government Code Section 65915(c)(3). • Program 3.B. - Develop Programs To Address State And Federal Legislative Mandates The City will continue to implement programs, including tenant and landlord education/ outreach, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing. • Program 3.G - Maintain A Mandatory Seismic Retrofit Program In March 2017, the City Council adopted a Seismic Retrofit Ordinance and the City implemented the Seismic Retrofit Program that proactively seeks to strengthen existing earthquake-vulnerable buildings and enhance the safety and security of their occupants. The City will continue to implement this seismic retrofit program to minimize potential displacement of residents due to seismic risks. • Program 3.I - Right To Counsel Program The City in April 2021 began a two-year pilot Right to Counsel program to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. Program 7.C will continue this program to support tenants facing eviction. • Program 4.E - Right to Return Program The City will implement a Right to Return Pilot Program for households that were historically Programs to protect tentants from displacement also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing: • Displacement of Residents due to Economic Pressures• High housing cost• Lack of affordable, accessible housing in a range of unit sizes • Private Discrimination 8.B.g Packet Pg. 524 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 84Chapter 2 | Assessment of Fair Housing in the City This Page Left Intentionally Blank 8.B.g Packet Pg. 525 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 8.B.g Packet Pg. 526 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 3:Goals and Policies 8.B.g Packet Pg. 527 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 87 City of Santa Monica | 2021 - 2029 Housing Element Chapter 3: Goals and Policies The Housing Element includes seven goals that create the framework for how the City of Santa Monica will address the community’s housing needs over the next eight years. These goals were reviewed as part of the community process for this Housing Element update. The policy goals of this Housing Element focus on: Affordable Housing Production: Prioritize affordable housing on City-owned sites and remove barriers to affordable housing production in all areas of the City. Market-Rate Housing Production: Continue to support the production of new market-rate housing around major transit stops and along major corridors. Affirmatively Furthering Fair Housing: Decisions regarding distribution of new development are viewed through the lens of providing equitable housing access to all neighborhoods. Housing Assistance: Continue to prevent displacement of existing households by providing financial and technical assistance for the provision of housing for all income groups and household types including families with children, seniors, persons with disabilities, and others with special needs. Address Homelessness: Prevent housed Santa Monicans from becoming homeless and continue to address the special need to provide housing and supportive services for the homeless in the community with an emphasis on the most chronic and vulnerable individuals. Balancing Housing with Other City Goals: Incorporate other community goals related to economic sustainability and environmental objectives with the production, conservation, and protection of housing. These include encouraging a balance between housing and economic development, sustainable development, providing supportive services, and increasing walkability and non- motorized forms of transportation. Assuring Equal Housing Opportunities: Continue to assure equal access to housing for all. 8.B.g Packet Pg. 528 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 88Chapter 3 | Goals and Policies GOAL 1 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. In Santa Monica, the demand for housing greatly exceeds the supply. This has resulted in Santa Monica being one of the most expensive places to live in the country. The City is required by the State to address this housing shortage by planning for its Regional Housing Needs Allocation (RHNA). In the past eight years, the City produced 3,643 units, well exceeding its established 5th Cycle RHNA of 1,674 units. The City’s target for this 6th cycle Housing Element is 8,895 units, an average of about 1,100 housing units annually. This number is more than 5 times larger than the allocation required in the prior Housing Element cycle. Meeting this housing target will be challenging and will require the enactment of new policies and programs to bolster housing production. Since then, the City adopted the Land Use and Circulation Element in 2010, updated the Sustainable City Plan in 2014, updated the Urban Forest Master Plan in 2017, and adopted a Climate Action and Adaptation Plan in 2019. All of these plans provide the foundation for the creation of sustainable and healthy communities. New housing plays an important role in achieving the City’s goals to reduce vehicle miles traveled, reduce greenhouse gas emissions, expand the tree canopy, and promote environmental justice. 8.B.g Packet Pg. 529 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 89 City of Santa Monica | 2021 - 2029 Housing Element POLICIES Policy 1.1 Adequate Land for Housing. Provide adequately zoned sites for all types of housing, particularly multi-unit housing in locations near major transportation hubs and services that promote active living in addition to areas that have historically excluded diverse housing opportunities. Policy 1.2 Housing Production Incentives. Encourage and provide adequate development standards and incentives for the production of housing, particularly affordable housing. Policy 1.3 Adaptive Reuse. Encourage and provide incentives for adaptive reuse of existing commercial buildings for housing. Policy 1.4 Design of Housing. Ensure that the design of new housing development is responsive to the surrounding context. Policy 1.5 Innovative and Sustainable Housing Design. Ensure that local regulations support: sustainable construction techniques and materials to the extent technically feasible, environmental justice that protects public health, open space, and expansion of the tree canopy. Policy 1.6 Housing for Special Needs. Maintain development standards that promote the development of special needs housing, such as affordable senior, accessible, and family housing. Policy 1.7 Review of Housing Constraints. Periodically review City taxes, fees, and regulations to ensure that they do not constrain housing development. Policy 1.8 Streamlined Housing Process. Continue to evaluate and provide an expedited and coordinated permitting process and design review, particularly for housing projects, including those using innovative and sustainable construction techniques and materials. Policy 1.9 Partner with School District and Community College District for Housing. The City shall seek opportunities to work with the School District and Community College District to facilitate housing development. Policy 1.10 Funding for Affordable Housing on City-Owned Sites. Pursue grant funding opportunities to facilitate affordable housing on City-owned sites 8.B.g Packet Pg. 530 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 90Chapter 3 | Goals and Policies GOAL 2 Housing production for all income categories including for the community’s workforce and most vulnerable communities. While it is generally recognized that Californians pay more for housing than the average American, Santa Monica’s housing costs are among the highest in the nation. There are a variety of negative effects caused by a lack of affordable housing. With a greater share of household incomes spent on housing costs, households are left with less money available to spend on basic necessities. Having less money available for non-housing costs often means that low income households will have less savings in the bank, putting them at risk for poverty or preventing them from rising out of it. The City’s economy is supported by a diverse variety of industry sectors but 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. Additionally, 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. Affordable housing in Santa Monica has been produced from two sources: market-rate housing and public assistance such as the City’s Housing Trust Fund. Market-rate housing is required to provide affordable housing or pay an in-lieu fee through the Affordable Housing Production Program (AHPP). In the last eight years, the City has constructed 982 affordable housing units, which represents 27% of the total units produced. As part of this Housing Element update, the City of Santa Monica must 8.B.g Packet Pg. 531 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 91 City of Santa Monica | 2021 - 2029 Housing Element adequately plan for and accommodate a total of 6,168 new affordable housing units, which represents 69% of the City’s overall RHNA. While the City generally provides several process and development incentives in support of 100% affordable housing projects, the major barriers to the production of affordable housing include: • Lack of funding • Land costs • Insufficient height and density standards necessary to produce units • Commercial prevailing wage requirements for buildings 5 stories and above. • Neighborhood opposition The City has worked to overcome these barriers over the past 40 years by supporting 100% affordable housing on city-owned land resulting in the production of 770 units of affordable housing. The long-term affordability of these units has been guaranteed through recorded deed restrictions or in the case of property sale, the City has negotiated for right of first option to purchase for a low, fixed amount in the event of future sale. As such the City has a demonstrated history of continuously leveraged public land to produce affordable housing for the benefit of the community. POLICIES Policy 2.1 Affordable Housing Financing. Encourage innovative private sector and governmental programs to promote the financing and development of housing for extremely low-, very low–, and low-income persons and for moderate income families. Policy 2.2 Local Assistance for Affordable Housing. Focus available resources (including City-owned land and Housing Trust Funds) to assist for- profit and nonprofit housing providers to develop housing for extremely low–, very low–, and low-income households. Policy 2.3 Advocacy for Legislative Changes. Support the enactment of federal, state, and local legislation to provide funding and incentives for the preservation and development of housing that is affordable to very low–, low–, and moderate-income households, and to accommodate special needs. Policy 2.4 Local Incentives and Streamlining for Affordable Housing. Continue to encourage and provide development opportunities and incentives, expedited permit review, and reduced planning fees to increase the production of affordable housing including extremely low-, low-, very- low, and moderate-income households. Policy 2.5 Homeownership Opportunities. Explore ways to encourage the development of ownership housing for affordable to moderate-income households and the City’s workforce, including opportunities for employer- provided permanent housing. 8.B.g Packet Pg. 532 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 92Chapter 3 | Goals and Policies Policy 2.6 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. Policy 2.7 Support for Senior Housing. Encourage and support development of senior housing and facilities to meet the needs of seniors, particularly for the oldest senior cohort, including consideration of a preference for “aging in place” along with the need for more congregate housing and residential care facilities. Policy 2.8 Support for Special Needs Housing. Consider incentives and requirements to ensure that new residential development accommodates a mix of household types and sizes that include a person(s) with special needs. Policy 2.9 New Housing Models. Encourage proposals for new housing types, such as co-housing, and assess their feasibility and benefits on a case-by-case basis. Policy 2.6 Maintenance, Improvement and Development of Housing for Persons with Disabilities. Explore alignment with the Voluntary Compliance Agreement (VCA) between the City of Los Angeles and HUD for, Santa Monica to potentially require at least 15% of total units in all newly constructed multi-family developments receiving public funds where City funds are leveraged with Low-Income Housing Tax Credits to be accessible to persons with mobility disabilities and at least 4% of total units to be accessible for persons with hearing and/or vision disabilities. 8.B.g Packet Pg. 533 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 93 City of Santa Monica | 2021 - 2029 Housing Element GOAL 3 Preservation of the existing supply of housing and prevent displacement of existing tenants. In 2020, Santa Monica’s total housing stock consisted of approximately 52,629 total units, 11,572 of which are single-unit residences and 40,853 of which are within multi-unit residential structures. Although there are over 11,000 single-unit dwellings, there are only around 6,500 parcels zoned R1, meaning many are located within multi-unit zones. The total housing stock includes affordable housing units and rent-controlled units, which are valuable assets to the City as they provide housing opportunities to low and moderate-income households. There are currently 3,902 publicly-assisted affordable units located within the City of Santa Monica.1 An estimated 770 units are at-risk of converting to market rate by 2031. In addition, as of December 31, 2020, there were 27,429 rent-controlled units in the City.2 Rent controlled units help ensure that rental costs do not outpace existing wages, and therefore, play a crucial role in keeping existing residents housed. Figure 3-1: Age of Housing Stock 0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20% 981 2014or later 880 2010-2013 3,280 2000-2009 2,838 1990-1999 4,426 1980-1989 10,227 1970-1979 9,018 1960-1969 7,116 1950-1959 4,901 1940-1949 7,457 1939or earlier Deed-restricted affordable housing and rent- controlled units contribute significantly to the City’s housing affordability. Preserving and rehabilitating existing housing stock is a key anti-displacement tool that prevents existing households from becoming unhoused. The vast majority of the City’s housing stock was built before 1980, see Figure 3-1 above. As these units age, they will be at risk of being demolished due to deteriorating conditions if not properly maintained. Some of the City’s existing housing stock will be protected as a result of SB330, which prohibits a project that will demolish 1 These include units produced with federal funding assistance, federal/state tax credits, redevelopment tax increment, City housing trust funds, City Multi-family Earthquake Repair Loan (MERL) Program Assistance and Los Angeles County Housing Authority owned units.2 City of Santa Monica, Rent Control 2020 Annual Report 8.B.g Packet Pg. 534 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 94Chapter 3 | Goals and Policies existing residential units and would not replace, at a minimum, the same number of new residential units. This will address existing multi-unit housing properties of five units or less that are particularly vulnerable to redevelopment and replacement. Additionally, the new allowance for ADUs on existing multi-unit properties not only creates more housing opportunities but may also encourage property owners to retain their rental properties. However, there remains existing multi-unit housing properties in the City that have fewer units than maximum allowable density and as such, could be at risk for demolition and redevelopment by a housing project that proposes a higher number of new units. POLICIES Policy 3.1 Support the City’s Rent Control Law. Ameliorate the effects of the Costa- Hawkins vacancy de-control regulation on the affordable housing stock. Policy 3.2 Preservation of Naturally Occurring and Deed Restricted Affordable Rental Housing. Explore strategies to preserve naturally occurring, rent-controlled, and restricted affordable rental housing. Policy 3.3 Protection of Rental Units. The City shall continue to protect rental housing by restricting the conversion of rental units to ownership units or for uses other than permanent rental housing. Policy 3.4 Replacement of Demolished Multi-Unit Housing. The City shall ensure the reasonable replacement of multi-unit housing that is demolished. Policy 3.5 Availability of Affordable Housing. The City shall ensure the continued availability and affordability of housing for very low-, low-, and moderate-income households. Policy 3.6 Rehabilitation Assistance. Provide rehabilitation assistance to maintain, improve, and extend the use and livability of the City’s aging residential buildings. Explore expansion of existing and new rehabilitation programs that may also result in short-term and long- term deed-restricted affordable units. Policy 3.7 Public and Private Funding for Rehabilitation and Preservation. Encourage and promote the use of public and private funding to provide rehabilitation, home improvement, and maintenance loans and grants with priority given to affordable units at risk of conversion, and multi-unit rental housing. Policy 3.8 Continued Maintenance of Existing Housing. Ensure continued maintenance of existing housing and that property owners are made aware of City programs to promote capital improvements to rental housing. Consider property owner incentives to encourage continued maintenance, repairs, and upgrades to housing that addresses the health and safety needs of the residents while respecting the character of the structure. Policy 3.9 Legal Support for Residents. Continue to provide and strengthen anti-discrimination legal assistance and support for tenants facing harassment or eviction in efforts to prevent displacement of existing tenants. 8.B.g Packet Pg. 535 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 95 City of Santa Monica | 2021 - 2029 Housing Element GOAL 4 A community that provides equitable housing access to all neighborhoods. The City of Santa Monica is generally more homogenous than the County as a whole. The majority of the City’s residential population is White, followed by Hispanics and Asians, respectively. Blacks represent 4% of the population. One of the likely barriers to living in the City for non-Whites is the high cost of housing. Hispanics and Black households have the lowest median income in the City and County as a whole, and as a result, are often priced out of housing opportunities in the City. For those households of color that can afford to live in Santa Monica, many of them are concentrated in neighborhood pockets of the City along the I-10 Freeway, and within the Pico, Downtown and Mid- City neighborhoods. These patterns of segregation are largely the result of decades of structural racism deeply rooted in Federal, State, and local housing policies. This includes the adoption of exclusionary zoning, which was used primarily as a way to economically separate the wealthier Whites from Blacks/African Americans and other people of color. Since many Blacks/African Americans could not afford or were unable to receive mortgages to purchase homes, they were effectively driven out of single- family zoned neighborhoods. The federal policy of “redlining” that arose during the New Deal era (1930s) also have contributed to the patterns of segregated neighborhoods. This discriminatory practice of determining who could qualify for home mortgages based on skin color led to widespread segregated communities across the country and prevented Blacks/African Americans from buying homes. In Santa Monica, areas that were redlined included the Pico Neighborhood, portions of the Mid- City neighborhood south of Santa Monica Boulevard, and Ocean Park. The pattern of redlined areas directly correlate with the areas where the non-White population, lower income households, and renter households are concentrated. Redlining The term “redlining” refers to the discriminatory policy instituted by the federal government to create color-coded maps of every metropolitan area in the country to indicate where it was safe to insure mortgage. These maps were based on racial composition, quality of housing stock, access to amenities, etc. and were color coded to identify best (green “A” grade), still desirable (blue “B” grade), definitely declining (yellow “C” grade), and hazardous (red “D” grade) neighborhoods. Areas of the City that were predominantly commercial/industrial were not color coded. 8.B.g Packet Pg. 536 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 96Chapter 3 | Goals and Policies Figure 3-2: Santa Monica Population by Race, 2019 65%White 10%Asian 4%Black or African American 15%Hispanicor Latino 5%Two or more races 1%Other POLICIES Policy 4.1 Access to Opportunities. Promote access to environmentally healthy neighborhoods that offer transportation services, jobs, high performing schools, parks, and residential amenities – particularly in areas that have historically excluded certain segments of the population. Policy 4.2 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. Policy 4.3 Targeted Investments. Strategically target housing creation and preservation strategies (e.g., public funding, incentives, infrastructure investments, etc.) and diverse housing types in locations that will help overcome historic patterns of segregation as well as programs and measures such as a “Right to Return” program that will help support historically displaced families and individuals in Santa Monica with housing. 8.B.g Packet Pg. 537 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 97 City of Santa Monica | 2021 - 2029 Housing Element GOAL 5 Housing for persons experiencing homelessness. Even prior to the COVID- 19 pandemic, homelessness was and continues to remain a regional and local challenge. Homelessness is driven by a multitude of factors, including: inadequate housing supply at all affordability levels, rising rents that have outpaced stagnant wages, and discriminatory housing and employment policies that have kept low-income populations and people of color in poverty. These challenges are compounded by insufficient and inconsistent access to medical and behavioral healthcare, as well as other essential supportive services. Up until 2020, City staff and volunteers had conducted annual point-in-time counts to approximate the number of homeless individuals within the City borders, along with a count of shelter use that same night. The last recent count took place on the night of January 22, 2020 with a total of 907 individuals counted outside on the streets, in cars and encampments, and in shelters and institutions within the City. While this number represented a decrease from 2017, the situation is expected to worsen due to the economic recession caused by the COVID-19 Pandemic, especially once the City’s eviction protection moratoriums expire. The City’s unhoused population includes veterans, women, persons with disabilities, older adults, and other vulnerable groups. A disproportionate number of Blacks/African Americans experience homelessness in Los Angeles County while the proportion of other racial and ethnic groups are either under or equal to their prevalence in the general population, making it clear that homelessness is also a social justice issue. 8.B.g Packet Pg. 538 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 98Chapter 3 | Goals and Policies Figure 3-3: Homeless Count, 2015 - 2020 City of Santa Monica Service Planning Area 5 - Westside Los Angeles County 2015 738 4276 41174 2016 728 4659 43854 2017 921 5411 52442 2018 957 4401 49955 2019 985 5262 56257 2020 907 6009 66436 Source: Los Angeles Homeless Services Authority, https://www.lahsa.org/homeless-count/ POLICIES Policy 5.1 Regional Fair Share Approach. Encourage a regional fair share approach to providing housing opportunities and assistance to homeless, extremely low-, very low-, and low- income households, and households with special needs. Policy 5.2 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; those whose last permanent address was in Santa Monica; and vulnerable members of Santa Monica’s workforce. Policy 5.3 Removal of Barriers to Supportive Housing. Remove barriers to the provision of low barrier navigation centers, emergency shelters, and supportive/transitional housing. 8.B.g Packet Pg. 539 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 99 City of Santa Monica | 2021 - 2029 Housing Element GOAL 6 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. Certain segments of the population may have greater difficulty in finding decent, affordable housing due to special circumstances. Populations requiring housing assistance and supportive programs include low-income households, the elderly, persons with disabilities, families, persons in need of emergency shelter, and persons with developmental disabilities. In 2017, 15.4% of the City’s total households were Extremely Low Income (0% to 30% AMI), 8.8% were Very Low Income (31% to 50% AMI), 11.6% were Low Income (51% to 80% AMI), and 7.0% were Moderate Income (80% to 100% AMI). Income disparity by racial group is apparent at the City level. Households of colors are more likely to have lower income levels than White households. Many lower-income families are considered housing cost-burdened - spending more than 30 percent of their monthly income for housing costs, leaving very little left for other basic needs like healthcare, food, and transportation. Others are forced into overcrowded or substandard housing conditions or join the increasingly large population of people experiencing homelessness. The elderly population, large families, families with children, and individuals with disabilities also require support, as they may have specific housing requirements that are necessary for access and enjoyment of their residence. Figure 3-4: Household Affordability Level by Race Households Total Households Extremely Low (less than 30% AMI) Very Low Incomes (30-50% AMI) Low Income (51-80% AMI)Moderate (80-120% AM) White 33,400 .6%7.6%10.7%7.2% Hispanic 5,705 20.7%13.4%18.0%7.5% Asian 4,245 15.1%4.8%9.1%4.8% Black/African American 1,508 12.7%28.4%15.7%6.4% Other 1,495 14.9%9.9%12.6%8.6% All Households 46,353 15.4%8.8%11.6%7.0% Source: CHAS HUD Data, 2017. 8.B.g Packet Pg. 540 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 100Chapter 3 | Goals and Policies POLICIES Policy 6.1 Financial Assistance for Residents; Rental Assistance Programs. The City shall provide support in rental assistance programs for extremely low-, very low-, and low-income households and household types including seniors, families with children, persons with disabilities, and others with special needs. Explore funding strategies and identify additional funding sources to provide continued support with rental assistance programs. Policy 6.2 Technical Housing Assistance. The City shall provide information and assistance to extremely low-, very low-, and low-income households and households with special needs and landlords to educate and increase awareness of, and provide oversight on federal and local housing and supportive programs and to assist residents in locating appropriate housing. Address housing barriers and resident challenges in securing and maintaining housing. Policy 6.3 Funding for Supportive Services. Target funds to ensure a broad array of supportive services to extremely low-, very low-, and low-income persons to ensure their continued maintenance of housing once obtained. Ensure funding that supports emergency housing for the homeless. Policy 6.4 Consider Expanding the Preserving Our Diversity (POD) Program. Evaluate expansion of the POD program to other rent burdened households including but not limited to additional seniors, families, and persons with disabilities and special needs. Policy 6.5 Reasonable Accommodations. Provide regulatory relief to enable housing access designed to meet the needs for persons with disabilities to ensure equal housing opportunities, consistent with fair housing laws. Policy 6.6 Resident Protections During Rehabilitation. The City shall provide resident protections including a temporary relocation program with oversight to minimize resident disruption and ensure that rehabilitation of existing units does not negatively impact or result in permanent displacement of existing residents. Policy 6.7 Explore Programs with the County of Los Angeles. The City shall explore the possibility of entering into contracts with the County for project-based vouchers including, but not limited to, programs administered by the County of Los Angeles. 8.B.g Packet Pg. 541 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 101 City of Santa Monica | 2021 - 2029 Housing Element GOAL 7 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. Pursuant to the California Fair Employment and Housing Act [Government Code Section 12921 (a)], the opportunity to seek, obtain, and hold housing cannot be determined by an individual’s “race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, genetic information, or any other basis prohibited by Section 51 of the Civil Code.” Fair housing issues that may arise in Santa Monica (or any jurisdiction) include but are not limited to: • Failure to make reasonable accommodations or modifications to make a dwelling unit accessible to an individual with a disability; • Discrimination in the sale or rental of a dwelling unit against an individual based on race, national origin, familial status, disability, religion, sex, or other characteristic; and • Tenant harassment because of race, color, religion, sex, disability, familial status, or national origin A multi-unit housing development that provides accommodations for persons with a physical disability 8.B.g Packet Pg. 542 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 102Chapter 3 | Goals and Policies The City of Santa Monica takes fair housing laws seriously and has enacted a number of local laws in support of fair housing including: • Chapter 4.28 of SMMC, addressing fair housing for families with children, disability, and source of income discrimination • Chapter 4.40 of SMMC, addressing fair housing regardless of sexual orientation or domestic partnership • Chapter 4.52 of SMMC, addressing fair housing for persons living with HIV/AIDS • Chapter 9.49 of SMMC, addressing reasonable accommodations for persons with disabilities The Public Rights Division (PRD) of the City Attorney’s Office enforces Fair Housing Laws, including investigation of fair housing complaints and litigation if necessary. The PRD also hosts an annual fair housing workshop and regularly publishes articles about fair housing in the Santa Monica Daily Press. The COVID-19 pandemic has highlighted the importance of housing rights, as many Santa Monicans (especially families and people of color) are facing evictions. The rise in hate crimes against all protected classes has also made the issue of fair housing paramount. POLICIES Policy 7.1 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. Policy 7.2 Legal Support for Residents. Continue to provide and strengthen anti-discrimination legal assistance and support for tenants facing harassment or eviction. Policy 7.3 Fair Housing Community Outreach. Continue to work with local organizations and partners to engage in community outreach strategies that provide information on fair housing laws, including community workshops and public awareness campaigns. 8.B.g Packet Pg. 543 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.g Packet Pg. 544 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 4:Summary of Land Available for Housing 8.B.g Packet Pg. 545 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 105 City of Santa Monica | 2021 - 2029 Housing Element A. Regional Housing Needs Allocation The Regional Housing Needs Allocation (RHNA) is a state-mandated process that determines the amount of future housing growth each city and county must plan for in its Housing Element. This “fair share” allocation concept seeks to ensure that each jurisdiction accepts responsibility for the housing needs of not only its resident population, but also for the jurisdiction’s projected share of regional housing growth across all income categories. The RHNA process begins with the California Department of Housing and Community Development’s (HCD) projection of future statewide housing growth need, and the apportionment of this need to regional councils of government throughout the state. The Southern California Association of Governments (SCAG) then determines the share to be allocated to each city and county within its region based on its approved Final RHNA methodology. On March 4, 2021, SCAG adopted the final RHNA allocation for all jurisdictions within its region. Figure 4-1 shows Santa Monica’s allocation in the Final Regional Housing Needs Allocation Plan—the planning period of October 2021 through October 2029. Approximately 69% of the units are allocated for households earning less than 120% of the Area Median Income (AMI). The RHNA represents the minimum number of housing units for which each community is required to provide “adequate sites” through zoning and is one of the primary threshold criteria necessary to achieve State approval of the Housing Element. Chapter 4: Summary of Land Available for Housing On March 4, 2020, SCAG approved the Final RHNA methodology for determining each jurisdiction’s RHNA within the SCAG region. The methodology utilized a three- step process: 1. Determine the jurisdiction’s projected housing need using regional projected household growth and calculate a future vacancy need by applying a healthy vacancy rate to owner and renter households. Assign a replacement need based on local survey results. 2. Determine the jurisdiction’s existing housing need based on a jurisdiction’s proximity to transit and jobs. 3. Add the projected and existing housing need together to get a total and apply social equity adjustment factors to determine the four RHNA 8.B.g Packet Pg. 546 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 106Chapter 4 | Summary of Land Available for Housing Figure 4-1: Santa Monica’s 2021-2029 Regional Housing Needs Assessment Income Level % of AMI*Units % of RHNA Allocation Very Low 31-50%2,794 31% Low 51-80%1,672 19% Moderate 81-120%1,702 19% Above Moderate 120%+2,727 31% Total 8,895 100% 1. Extremely Low Income Housing Needs The RHNA does not include the income level of extremely low-income units (ELI). However, state law (AB 2634) requires Housing Elements to include the projected number of extremely low income housing needs, and the City’s AHPP requires the production of ELI units. HCD indicates that local agencies may calculate the projected housing need for ELI households by applying one of the following two methodologies to the RHNA for very low-income (VLI) households: • Use available Census data to calculate the percentages of ELI and VLI households and apply these percentages; or • Assume 50 percent of the VLI units would qualify as ELI. Applying the first methodology, approximately 7,124 extremely low-income and 4,089 very low- income households were identified in Santa Monica as detailed further in Appendix B. This equates to 64 percent and 36 percent respectively, of the total ELI and VLI households (Figure 4-2). These percentages suggest that of Santa Monica’s RHNA share of 2,794 RHNA very low income units, a minimum of 1,788 units should be available for extremely low-income households and 1,008 units for very low-income households. Figure 4-2: Low Income Housing Needs Existing # of Households %RHNA Projected Need Extremely Low 71,24 64%2,794 1,788 Very Low 4,089 36%1,006 8.B.g Packet Pg. 547 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 107 City of Santa Monica | 2021 - 2029 Housing Element B. Suitable Sites Inventory The Regional Housing Needs Allocation (RHNA) is a state-mandated process that determines the amount of future housing growth each city and county must plan for in its Housing Element. This “fair share” allocation concept seeks to ensure that each jurisdiction accepts responsibility for the housing needs of not only its resident population, but also for the jurisdiction’s projected share of regional housing growth across all income categories. 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. For the 6th Cycle 2021-2029 Housing Element, the City’s RHNA is 8,895 units, of which 69% must be provided at affordable levels. The SSI for the City of Santa Monica’s 6th Cycle Housing Element was prepared in accordance with State Housing Element law and HCD’s Housing Element Sites Inventory Guidebook. Appendix F provides a report of the methodology used to prepare the SSI. Map 4-1: Suitable Sites 8.B.g Packet Pg. 548 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 108Chapter 4 | Summary of Land Available for Housing 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 SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning, general characteristics such as historic and land use designations, and market factors. City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. 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. Based on the assessment of sites using the above factors and methodology, there are 138 parcels that have approved and pending projects for residential development and 180 non-vacant commercial/mixed use zoned parcels in the City identified to have high potential for residential redevelopment. In addition, 22 residentially zoned sites that are developed as parking lots have been identified as having high potential to be redeveloped for housing. Approximately 340 sites have been identified that have the highest potential to accommodate housing. These are shown on Map 4-1. Sites may be viewed interactively on the City’s Housing Element Update webpage at: https://www.santamonica.gov/housing-element-update. The sites in the SSI are categorized according to Figure 4-3. Accommodating for Very Low and Low Income Housing The State uses the density allowed on a site as a “proxy” for determining whether a site can accommodate housing at lower-income levels. • Very Low and Low Income. State law establishes a “default density standard” of 30 units per acre for low-income units in the City of Santa Monica. This means that if a site’s zoning allows for a density that is greater than 30 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households. The City’s Zoning Ordinance uses FAR rather than the density factor of units/acre. Therefore, to determine how many units per acre are possible on each site in the SSI, the number of units possible was calculated based on the allowable FARs established in Programs 1.F and 1.J. The number of units was then translated into units/acre based on the parcel size of each site. These calculations indicate that with the rezoning in Programs 1.F and 1.J, all the non-vacant, commercially zoned sites in the SSI can accommodate housing at greater densities than the “default density” of 30 units/acre. Therefore, per HCD, all sites can be identified as having the capacity and density to accommodate lower-income units. • Moderate-income. Since all the identified SSI sites can accommodate lower-income units, the City has also determined that each site can accommodate moderate-income housing since units affordable to lower-income households would also be affordable to moderate-income households. 8.B.g Packet Pg. 549 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 109 City of Santa Monica | 2021 - 2029 Housing Element Figure 4-3: Suitable Sites Prioritization Categories #Category Description 1 Approved and Pending Housing Projects Santa Monica has a number of pipeline housing projects that have been approved or are pursuing entitlements. These units are expected to be constructed in the next eight years and would count toward the City’s 6th Cycle RHNA. 2 Prior SSI Sites 83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have undergone entitlements but the remaining have not. 3 DCP Buildout As part of the Downtown Community Plan that was adopted in 2017, sites in the Downtown were identified for potential redevelopment. 4 City-Owned Sites An important strategy for the City to meet its RHNA targets is the utilization of existing City-owned sites for housing, particularly affordable housing. All City-owned sites that are not currently developed with open space/parks, community centers, civic uses, utilities, etc. are categorized as Category 4 sites. 5 Parking Lots A handful of sites in the City are parking lots, or parking structures. Parking lots are very underutilized and represent the greatest opportunity for new housing without displacement of existing uses. 6 Auto Storage Lots These are parcels currently being utilized almost entirely as auto inventory surface lots for auto dealerships. Auto dealerships have indicated interest in turning over these large surface lots into redevelopment opportunities as they are rethinking their sales operations. 7 Parcels with recent/active sales Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites (such as Loopnet), a number of properties have recently sold between 2019-2021 or have active sales listing. 8 Underutilized Sites (20,000 excess sf development potential) Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to have a net new development potential of 20,000 sf or greater (based on their existing built sf compared against their currently allowable maximum floor area). 9 Large Parcels (15,000 sf+)Most parcels in the City are 7,500 sf. Large parcels that are 15,000 sf have greater potential for redevelopment. 10 Remaining Sites with less than 0.5 ILR All remaining City sites with an improvements to land value ratio (ILR) of 0.5 or less have the highest likelihood of redevelopment. 11 Religious Institutions AB 1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. A number of religious institutions with large surface parking lots are located throughout the City. 12 A-Lots and Residentially Zone Parking Lots “A-Lots” are residentially zoned (R1/R2/R3/R4) parcels with an “A” Off-Street Parking Overlay. Within the City, there are 42 A-lots. In addition, there are numerous residentially zoned parking lots that serve the parking needs of boulevard-fronting commercial uses. 8.B.g Packet Pg. 550 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 110Chapter 4 | Summary of Land Available for Housing City owned parking lot off of Main Street. 1. Approved and Pending Housing Projects The City has a significant number of housing projects in the pipeline that if constructed will count toward the City’s 6th Cycle RHNA. As of May 2022, there were approximately 2,594 approved units (of which 637 are affordable) and 2,550 pending units on 137 parcels. The list of approved and pending projects is provided in Appendix F. A review of the past 5th Cycle Housing Element shows that 10% of approved and pending projects were withdrawn and/or have had permit approvals expire. It is not possible for City staff to predict how many and which specific approved and pending projects could be withdrawn or ultimately not developed. Doing so would be arbitrary and speculative. Therefore, a 10% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 2,205 approved units and 2,168 pending units that are projected to count towards the 6th Cycle Housing Element. 2. Prior SSI Sites The SSI identifies 24 sites that were in the last (5th) Cycle Housing Element with the capacity for approximately 1,500 units. According to Government Code Section 65583.2, if the SSI contains sites that were used in a prior housing element planning period, the City must allow by-right a development that includes at least 20% of the units as affordable. Sites where zoning already permits residential “use by right” as set forth in Government Code section 65583.2 (i), at the beginning of the planning period would be considered to meet this requirement. The City currently allows by-right housing projects through an interim zoning ordinance. In order for the reused sites identified in the SSI to qualify for inclusion, this Housing Element includes Program 1.A to amend the Zoning Ordinance to establish a permanent by-right approval process for qualifying housing projects, including housing projects providing 20% of units as lower income affordable units. 8.B.g Packet Pg. 551 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 111 City of Santa Monica | 2021 - 2029 Housing Element 3. City-Owned Sites Achieving the number of affordable housing units for the 6th Cycle RHNA will be challenging, especially given limited public funding and high land costs in the City. The City recognizes that City- owned land can play an important role in producing significant housing, particularly affordable housing, and therefore, has made a commitment to prioritizing such land for 100% affordable housing within this Housing Element. Program 2.E. commits City-owned sites for the development of affordable housing through a public process that would maximize the amount of affordable housing that could be feasibly developed. The City-owned sites in the SSI are: Public Parking lots 7, 8, and 12 Parking Structure 3, 4th & Arizona, Bergamot Arts Center, and Main Street parking lots. With consideration to existing constraints (such as lease terms, financial resources, etc.), City-owned sites have the potential for accommodating 1,880 units. Program 2.E commits the City to plan for a minimum of 1,880 affordable housing units across available City-owned sites, which may include but shall not be limited to rezoning actions. 4. Community Assebly Sites (Including Religious Congregations) A number of religious congregations with large surface parking lots are located throughout the City. State law has made it easier to develop housing on religious institutional properties by removing parking as a barrier to development. During the outreach process of the Housing Element, many of these religious congregation leaders have expressed interest in developing housing on their properties and indicated that the provision of affordable housing on these sites would be aligned with their core mission. With Program 4.B to amend the Zoning Ordinance to facilitate the development of housing on surface parking lots owned by community assembly uses, these sites could accommodate 257 units. 8.B.g Packet Pg. 552 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 112Chapter 4 | Summary of Land Available for Housing 5. All Remaining Sites The remaining sites in the inventory include parking lots, underutilized sites with low-scale buildings, recently sold/active sales sites, and large sites. Mixed-Use Zones Many of the SSI sites are located in the City’s commercial and mixed-use zones (MUBL, MUB, GC, NC). Changes in the Downtown Community Plan and Zoning Ordinance as specified in Programs 1.F and 1.J will be required to support multi-unit housing and the production of inclusionary, affordable housing units in compliance with the City’s Affordable Housing Production Program. In particular, the new increases in density and height would increase the likelihood of housing units to be developed in the NC zone (where housing has traditionally not occurred). Office Campus/Industrial Conservation/Creative Conservation Sector Sites in the OC, IC, and CCS zones are typically developed for office, business park, warehousing, light industrial, and other commercial uses. A number of sites in these zones have been determined to be compatible for residential uses. The Housing Element includes Program 4.A to amend the Zoning Ordinance to allow multi-unit residential in non-residential zones where housing is currently prohibited. 6. Capacity to Accommodate the RHNA by Income Levels 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 has the capacity to accommodate at least 13,600 units providing a 53 percent buffer above the City’s RHNA of 8,895 units. This number is based on the application of new development standards for housing projects as established in Programs 1.F and 1.J. The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing. The land inventory includes capacity for 521 extremely low, 2,819 very low income, 2,703 low income, and 1,901 moderate income units. Figure 4-4 breaks down the summary of the SSI capacity based on category and income levels. 8.B.g Packet Pg. 553 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 113 City of Santa Monica | 2021 - 2029 Housing Element Figure 4-4: Suitable Sites Capacity Summary Table – Base Tier 1 Housing Total Capacity Capacity for Affordable Units # Units # Affordable Units ELI VLI LI Moderate Category 1 Approved 2,205 637 127 177 185 148 Category 1 Pending 2,168 420 24 321 34 41 Category 4 City Sites 1,880 1,880 627 627 627 - Category 11 Religious Sites 257 130 32 32 32 34 Category 12 Parking Lots 96 9 --9 - All Remaining Categories 6,619 6,619 1,655 1,655 1,655 1,655 ADUs 376 249 56 8 162 23 Total 13,600 9,944 2,521 2,819 2,703 1,901 RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702 Buffer +4,705 +3,776 +1,124 +1,422 +1,031 +199 53% C. Accessory Dwelling Units Accessory Dwelling 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. Figure 4-5 and Map 4-2 summarize ADU development and locations 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 owners take advantage of the new ability to establish sometimes multiple ADUs with existing multiple-unit residential and mixed-use developments. 8.B.g Packet Pg. 554 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 114Chapter 4 | Summary of Land Available for Housing Figure 4-5: Santa Monica ADU Production Building Permit Year Permits Issued Total 2018 23 56 2019 60 83 2020 41 115 2021 102 27 TOTAL 226 281 Average 2018-2020 (23+6+41+102)/4=56.5 units per year Source: Building permit data as of May 31, 2022. Map 4-2: ADU Locations Sources: Esri, Airbus DS, USGS, NGA, NASA, CGIAR, N Robinson, NCEAS, NLS, OS, NMA, Geodatastyrelsen, Rijkswaterstaat, GSA, Geoland, FEMA, Intermap and the GIS user community, Sources: Esri, HERE, Garmin, FAO, NOAA,USGS, © OpenStreetMap contributors, and the GIS User Community ADU Locations Zoning R1: Single-Unit Residential (188) R2: Low Density Residential (23) R3: Medium Density Residential (6) OP1: Ocean Park Single-Unit Residential (2) OP2: Ocean Park Low Density Residential (7) 8.B.g Packet Pg. 555 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 115 City of Santa Monica | 2021 - 2029 Housing Element Per State law, a projection of the number of ADUs expected to be built within the 8-year planning period can be counted towards the RHNA. However, this projection must be based on the following factors: • The number of ADUs or JADUs developed in the prior planning period; • Community need and demand for these types of housing units; • The resources and/or incentives available that will encourage the development of ADUs; • The availability of ADUs and JADUs for occupancy; • The unit must meet the Census definition of a housing unit and be reported to the Department of Finance as part of the annual City and County Housing Unit Change Survey; and • The anticipated affordability of these units. In order to project the increased potential of ADU development, HCD recommends the following options: • Use the trends in ADU construction since January 2018 to estimate new production. • Assume an average increase of five times the previous planning period construction trends prior to 2018. • Use trends from regional production of ADUs. • Include programs that aggressively promote and incentivize ADU and JADU construction. As shown in the Figure 4-5 based on ADU building permit data between 2018 and 2021, Santa Monica averaged 56 ADUs per year. However, given that 36 of the ADUs (approximately 16%) were located on parcels with existing multi-unit dwellings, which are less typical applicants for ADUs, the average annual production estimate has been reduced by 16% to approximately 47 ADUs per year. Therefore, it can be expected that over the next eight-year Housing Element cycle, approximately 376 ADUs will be built and can be used towards our RHNA. This estimate is conservative, as it accounts for a potential progressive decline in available land for ADU within single-unit zones. As noted, this forecast also does not account for possible future interest in ADUs to be incorporated into existing multiple-unit residential and mixed-use developments, which the City has only just started seeing very recently as the new law permitting this only took effect January 1, 2020. In order to determine assumptions of ADU affordability in the Southern California region, SCAG conducted a regional analysis of existing ADU rents. Figure 4-6 shows assumptions for ADU affordability based on the SCAG assumptions. Determining ADU Income Levels SCAG conducted a regional analysis of current market rents that can be used to obtain credit towards each income category in the RHNA. SCAG’s analysis was pre-certified by HCD and allows cities to assume that the total anticipated ADU production would be assigned to the following income categories: • Extremely Low – 15%• Very Low – 2%• Low – 43%• Moderate – 6% • Above Moderate – 34% 8.B.g Packet Pg. 556 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 116Chapter 4 | Summary of Land Available for Housing Figure 4-6: Estimated Affordability of Projected ADUs 2021-2029 Income Level Percent of ADUsa Projected # of ADUs Extremely Low Income 15%56 Very Low 2%8 Low 43%162 Moderate 6%23 Above Moderate 34%128 a Based on SCAG Survey of ADU Affordability D. Adequate Sites Alternative - Rehabilitation and Conversion of Existing Units Government Code Section 65583.1(c) allows for use of existing units to address up to 25 percent of the lower income RHNA by counting existing units made available or preserved through the provision of “committed assistance” to low- and very low-income households at affordable housing costs or affordable rents. This option is referred to as “Alternative Adequate Sites”. However, there are limited parameters under which substantial rehabilitation, conversion, or preservation of units can be counted and the Housing Element would be required to identify exactly how the city will guarantee compliance in order to grant the credit. The units must be: • Substantially rehabilitated and at imminent risk of loss to the housing stock • In a multi-unit rental or ownership housing complex of three or more units that are converted from non-affordable to affordable rental • Preserved at levels affordable to low- or very low-income households where the local government has provided those units with continued assistance The City has a history of dedicating revenues to support the rehabilitation of substandard housing units. From 2005 onward, the City provided Housing Trust Fund loans to nonprofit developers for acquisition, rehabilitation, and deed restriction. The City also provides housing assistance to existing residents through a number of programs and has a demonstrated history of working with willing property owners and tenants to grant project-based housing vouchers that might allow some units to qualify towards the RHNA. Further, the Housing Element includes Program 2.C allowing market-rate projects to comply with the AHPP through the acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Based on past performance, it is expected that the City will continue to preserve the existing at risk housing stock through the acquisition and rehabilitation of existing low-income units. However, it would be difficult to predict how many rehabilitated units could be counted towards the RHNA. 8.B.g Packet Pg. 557 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.g Packet Pg. 558 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 5:Implementation Programs 8.B.g Packet Pg. 559 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 119 City of Santa Monica | 2021 - 2029 Housing Element The City is committed to implementing the goals and policies in Chapter 3 through the programs in this chapter. These programs have been developed through extensive community engagement and with consideration for actions necessary to achieve a compliant Housing Element. The programs reflect what realistically could be completed in the eight-year planning period. Each program includes background, a description of the program action, timeframe by which the action will be completed, and the City agencies responsible for oversight of the program. The City will be reporting on each of these programs as part of its Annual Progress Report to the California Department of Housing and Community Development. GOAL 1 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. Program 1.A By-Right Approvals For Housing Projects The City shall make permanent amendments to the Zoning Ordinance that are currently interim and make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to allow, at a minimum: 1) 100% affordable housing projects; 2) non-Downtown housing projects that are code-compliant or are granted specified modifications/waivers to be established in the Zoning Ordinance; 3) Downtown housing projects that do not exceed Tier 2 maximums and are code-compliant or are granted specified modifications and waivers to be established in the Zoning Ordinance; and 4) housing projects that include at least 20% of units on-site as affordable to lower-income households [Government Code Section 65583.2(c)], to be reviewed through a by-right process. The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. Such by-right projects shall still be subject to design review, provided that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. The City shall extend interim zoning amendments for process thresholds pending the full implementation of this program. Chapter 5: Implementation Programs 8.B.g Packet Pg. 560 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 120Chapter 5 | Implementation Programs The City shall also develop written procedures to implement the streamlined review process for eligible projects under SB35. The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process. Program Background: Based on consultation with both affordable and market-rate housing providers, the uncertainty presented by a discretionary approval process is a factor in whether to move forward with housing projects in light of other risks that are out of the City’s control including land costs, construction costs, and lender requirements. On March 10, 2020, in efforts to streamline the process for housing production, the City Council adopted changes to the LUCE, DCP and BAP as well as an emergency interim ordinance to allow 100% affordable housing projects and housing projects up to Tier 2 maximums that are subject to the protections of the HAA to be reviewed through a by-right administrative process. The emergency interim ordinance expires December 31, 2021, unless extended by the City Council. Additionally, according to Government Code Section 65583.2, if the Suitable Sites Inventory (SSI) contains sites that were used in a prior housing element planning period, the City must allow by-right a development on those sites if the project includes at least 20% of the units as affordable. Therefore, in order for the 5th Cycle Housing Element sites identified in the SSI to qualify for inclusion, the by-right process must be included in the LUCE, Zoning Ordinance, DCP and BAP, as applicable. • Timeframe: by October 15, 2022 • Responsibility: City Planning Division; City Attorney Office • Objective: Allow a ministerial approval process based on objective standards for 100% affordable housing projects and housing projects that do not exceed Tier 2 maximums and are subject to the Housing Accountability Act. LUCE Tier System The LUCE created a tiered land use system based on increments of height and floor area ratio (FAR). Tier 1 establishes a base height and FAR while Tier 2 establishes additional height and FAR that can be requested if community 8.B.g Packet Pg. 561 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 121 City of Santa Monica | 2021 - 2029 Housing Element Program 1.B Streamline the Architectural Review Process and Ensure Design Review Objectivity for Housing Projects The City shall adopt new streamlining procedures to allow staff level design review for smaller housing projects and expedited design review of larger housing projects by shifting the design review process to before or concurrently with entitlement issuance. This will reduce processing timelines and increase certainty for housing providers. These procedural changes would involve amending the Municipal Code to assure that design review cannot unreasonably delay a housing project approval by, for example, placing limits on number of hearings and maximum time limits for design review. The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency with SB35. Program Background: Santa Monica Municipal Code Chapter 9.55 establishes the Architectural Review Board (ARB), and, along with certain provisions of the City’s Zoning Ordinance, sets forth the City’s design review processes. For all new construction, additions or remodel of an existing building, in all zones except R1 (single-unit), the ARB must make findings in its design review of development including compatibility with surroundings and design that is expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity and individuality. While the findings, which have been in place since the 1970s, are not objective, the design review process occurs after project entitlements and focuses only on project design; as a result, the ARB’s review cannot be used to deny or reduce the density of a housing project. Additionally, while the City is currently not subject to SB 35 under the 5th Cycle Housing Element reporting period (2013-2021) because the City has regularly met its RHNA targets, it is anticipated that the City with be subject to SB 35 in the coming 6th Cycle Housing Element reporting period (2021- 2029), and will therefore be limited to use of objective design standards when reviewing housing projects eligible for SB 35’s expedited review process. • Timeframe: Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Streamlined housing approvals. 8.B.g Packet Pg. 562 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 122Chapter 5 | Implementation Programs Program 1.C Incentivize Housing Development On Surface Parking Lots In Residential Zones In order to provide new housing choices and affordability in high opportunity areas, the City shall adopt standards that incentivize housing production on surface parking lots in residential zones associated with existing commercial uses, including, but not limited to, removing density caps and commercial parking replacement restrictions, lot consolidation, street access to the project, and restoring underlying maximum allowable density. The City shall also adopt standards that incentivize housing production on surface parking lots associated with existing residential uses as long as the existing residential use is not removed. Program Background: There are approximately 108 residentially-zoned surface parking lots associated with an adjacent commercial use. Of those parking lots, 32 are identified as high or medium-high potential for housing in the SSI. The parking lots serve the adjacent boulevard-facing commercial uses. The existing multi- unit residential zones have density caps of 4-6 units regardless of the size of the property, which limits their capacity for housing potential. • Timeframe: by August 1,2023 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Incentivize housing production on underutilized sites that would not displace existing residential tenants. A typical “A-Lot” in Santa Monica. The residentially-zoned surface parking lot in the foreground with the associate commercial use in the background. 8.B.g Packet Pg. 563 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 123 City of Santa Monica | 2021 - 2029 Housing Element Program 1.D Reduce Minimum Parking Requirements For Housing Projects The City shall reduce minimum parking requirements for all housing projects by applying Parking Overlay 1 rates. Program Background: Analysis of total development costs for housing projects have shown that stringent parking requirements add significantly to the cost of housing construction. In 2017, the City eliminated parking minimums in the Downtown as part of the adoption of the Downtown Community Plan. Eliminating and/or reducing minimum parking requirements would allow a housing developer to choose the “right-size” supply of parking to meet demand as necessary, and would significantly reduce the cost of housing construction. • Timeframe: by October 15, 2022 • Responsibility: City Planning Division; Mobility Division; City Attorney’s Office • Objective: Lower the cost of housing production. The Downtown Community Plan eliminated parking minimum requirements in an effort to reduce construction costs. 8.B.g Packet Pg. 564 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 124Chapter 5 | Implementation Programs Program 1.E Revise The Design Standards In The Bergamot Area Plan (BAP) For Easier Understanding And To Support Housing Production The City shall modify the design guidelines in the BAP to establish objective standards to support housing production by increasing certainty for housing providers. The revisions to design standards will address at minimum: 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 to support housing production. The BAP should also consider the special housing needs of artists, such as live-work units, to promote artist residents in the Bergamot area. Program Background: The BAP was initiated to transition 142.5 acres of former industrial land into a walkable, sustainable, and 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. However, the design standards in the Plan are complex, unclear, onerous, and do not incentivize housing. As a result, since its adoption in 2013, only three housing projects have been proposed in the Bergamot area. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Provide clarity in the regulatory environment for housing and incentivize housing production in the Bergamot area. The Bergamot Area Plan was adopted in September of 2013, and covers 142.5 acres of former industrial land as well as the Beergamot Arts Center 8.B.g Packet Pg. 565 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 125 City of Santa Monica | 2021 - 2029 Housing Element Program 1.F Revise The Downtown Community Plan Development (DCP) Standards To Support Housing Projects The City shall modify the development standards in the DCP to ensure they are set at levels that can support the minimum AHPP requirements and to support feasible housing projects. The City shall also amend the development standards and AHPP requirements to ensure Tier 2 and Tier 3 Downtown housing projects are feasible. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. Any changes will promote housing and ensure that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR and height shown in the table below. The off-site affordability requirement will be greater than the on-site requirement. Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Minimum Tier 1 FAR/Height with Rezoning Current Tier 2 FAR/Height Minimum Tier 2 FAR/Height with Rezoning Curent Tier 3 FAR/Height Minimum Tier 3 FAR/Height with Rezoning LT (East)12 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- LT (West)11 1.50/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- NV 31 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -4.0/84 ft BC (Promenade)12 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- BC (2nd/4th)25 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft -- TA 52 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft 4.0/84 ft 4.0/84 ft OT 15 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft -- WT 6 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft -- 8.B.g Packet Pg. 566 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 126Chapter 5 | Implementation Programs The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees, unit mix, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. Program Background: The DCP was adopted in 2017 with a primary focus on producing thousands of new housing units at a range of sizes and affordability levels. The DCP provided both development and process incentives for housing projects through greater FARs relative to commercial development, no minimum parking requirements, and a ministerial approval process for typical mixed-use housing projects. In exchange for these strong incentives, Downtown housing projects are required to provide additional affordable housing and augmented fees for the portion of the floor area above Tier 1 maximums. Since DCP adoption, approximately 1,133 units have been approved in the Downtown with a lesser amount that have moved ahead into building permits. Of those 1,133 approved units, the vast majority were projects that pre-dated the DCP’s inclusionary housing requirements. The current FARs and heights allowed in the DCP are shown below: • Timeframe: by October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Continue to encourage housing production in Downtown area. The Downtown Community Plan was adopted in July of 2017, and covers the Downtown area between Wilshire Blvd and the I-10 from Lincoln Blvd west to Ocean Ave. 8.B.g Packet Pg. 567 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 127 City of Santa Monica | 2021 - 2029 Housing Element Program 1.G Incentivize And Facilitate The Development Of Accessory Dwelling Units (ADUs) Through An Adu Accelerator Program The City shall develop an Accessory Dwelling Unit Accelerator Program that will simplify the ADU process by providing property owners interested in constructing ADUs throughout all neighborhoods 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 further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year. Additionally, the City will review and update its locally adopted ADU Ordinance for consistency with State law. Program Background: An effective strategy to increasing the housing supply is facilitating the construction of Accessory Dwelling Units (ADUs), particularly in single-unit residential districts. Due to their smaller size and relatively lower cost of construction, ADUs can provide lower-cost housing opportunities within single-unit neighborhoods that are less accessible due to high housing costs. In 2020, the City approved an ADU Ordinance (SMMC Section 9.31.025) to incorporate State law requirements for ADUs and Junior Accessory Dwelling Units (JADUs). The ordinance further encourages the production of ADUs/JADUs by exempting them from parcel coverage or floor area calculations and provides for a ministerial approval process for all ADUs and JADUs. Since implementation of these new State laws, the City has seen an increase in ADU production and interest each year. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division • Objective: Streamline approvals and facilitate development of ADUs. Program 1.H Adaptive Reuse Of Existing Commercial Buildings For Permanent Residential Use As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to incentivize the adaptive reuse of existing commercial tenant spaces citywide, for permanent residential use and also allow adaptive reuse of existing ground floor commercial space for artists and live-work use. Changes to incentivize the conversion of existing commercial tenant space to residential use include but are not limited to, relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements. 8.B.g Packet Pg. 568 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 128Chapter 5 | Implementation Programs Program Background: The COVID-19 pandemic has had a dramatic impact on the City’s commercial real estate market. Even prior to the pandemic, the retail industry had been struggling to compete with online retailers and the office market had started to trend downward. Empty storefronts and partially-occupied office buildings are not an uncommon sight in the City. With the downturn of retail and office real estate accelerated by the pandemic, the concept of converting commercial into residential has gained significant interest as another avenue to increase the supply of housing in the City. • Timeframe: by December 31, 2024 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Increase flexibility for reuse of vacant commercial space to residential use. Program 1.I Ensure That Local Regulations Support Innovations In Construction Technology To The Extent Technically Feasible The City shall support innovative lower-cost, efficient, and environmentally sustainable construction techniques for housing. Program shall implement a streamlined building permit review process for housing projects utilizing innovative construction methods and technology, and project-based outcome-oriented permitting benchmarks. Program Background: New innovations in building and construction technology could help decrease both the time and cost of housing construction. This includes the use of modular/pre-fabricated (prefab) construction or the use of cross laminated timber. Prefab construction involves producing standardized components of a structure in an offsite factory, then assembling them onsite. When prefab construction is done at economies of scale, it can result in significant reduction in housing cost. Cross laminated timber (CLT) has recently started gaining traction in North America as a viable type of construction. In addition to being more sustainable, CLT can significantly reduce the time and labor costs for construction. • Timeframe: by December 31, 2024 • Responsibility: City Planning Division; Building and Safety Division • Objective: Remove impediments to innovation in housing construction. 8.B.g Packet Pg. 569 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 129 City of Santa Monica | 2021 - 2029 Housing Element Program 1.J Rezoning By Revising Development Standards To Ensure That Housing Projects Are Feasible And Incentivized Over Commercial Development The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI inventory are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.0 to 3.25 with heights ranging from 55 feet to 65 feet. Any changes will promote housing to ensure overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR and height shown in the tables below. The off-site affordability requirement will be greater than the on- site requirement. Zone Approx. Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Minimum FAR/Height with Rezoning MUBL – N of I-10 107 1.50/36 ft 1.75/36 ft 3.25/70 ft MUBL – Pico 15 1.50/36 ft 1.75/36 ft 2.00/45 ft MUBL – Pico (West of Lincoln) 4 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL – Main St 10 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL - Lincoln 107 1.50/36 ft 1.75/36 ft 2.50/55 ft MUB 59 1.50/39 ft 2.25/50 ft 3.25/70 ft GC (SMB)24 1.25/ -1.50/35 ft 3.25/70 ft GC (Lincoln)19 1.50/36 ft 2.00/36 ft 2.50/55 ft GC (Pico)4 1.50/36 ft 2.00/36 ft 2.00/45 ft NC 27 1.50/32 ft N/A 2.25/50 ft NC (Main)14 1.00/27 ft N/A 2.50/55 ft NC (Ocean Park)15 1.00/32 ft N/A 2.50/55 ft NC (Montana)15 1.00/32 ft N/A 2.50/55 ft 8.B.g Packet Pg. 570 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 130Chapter 5 | Implementation Programs IC 77 N/A N/A 3.00/65 ft OC 88 N/A N/A 2.75/60 ft HMU 39 1.50/45 ft 2.50/70 ft 2.50/70 ft Bergamot Area # Acres to be Rezoned Current Tier 1 FAR/Height Current Tier 2 FAR/Height Current Tier 3 FAR/Height Minimum FAR/Height with Rezoning BTV 35 1.75/32 ft 2.00/60 ft 2.50/75 ft 4.0/84 ft MUC – North of Pennsylvania Avenue parcel line between Stewart and Stanford; South of Expo Bike Path 31 1.50/32 ft 1.70/47 ft 2.20/57 ft 3.25/70 ft MUC - Remainder 36 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft CCS 8 1.50/32 ft N/A N/A 2.50/55 ft CAC 17 1.00/32 ft 1.00/60 ft 1.00/75 ft 2.50/55 ft The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation. In addition to FAR and height, the City shall review and mofify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix requirements, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods. Program Background: When the LUCE was adopted in 2010, its core strategy was to capitalize on the City’s extensive transportation system including the Metro Expo Light Rail and to protect the City’s residential neighborhoods with an emphasis on policies that discourage tenant displacement. This growth strategy has resulted in significant new housing production in the Downtown, but it has also perpetuated the historic patterns of housing segregation that remains to this day. Although all of Santa Monica is considered a high or highest resource area, there remain a handful of areas where housing would not be likely to develop due to FARs that are not high enough to support the City’s regulatory requirements. The current FARs and heights allowed in the Zoning Ordinance are shown below: 8.B.g Packet Pg. 571 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 131 City of Santa Monica | 2021 - 2029 Housing Element • Timeframe: by October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Support the production of affordable housing and encourage the equitable production of housing across the City. Program 1.K Adequate Sites Program To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower income units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing 100 percent residential use and requiring residential use to occupy at least 50 percent of the floor area. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City complies with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations. Program Background: Government Code section 65583(f) and Government Code section 65583.2(h) states that where the inventory of sites does not identify adequate sites to accommodate the RHNA for lower income households, a program must be included to identify sites that can be developed for housing within the planning period. As the City will be accommodating more than 50 percent of the low- and very low-income regional housing shortfall on City-owned sites, the City must allow these sites in the inventory to accommodate 100 percent residential use and require residential use to occupy at least 50 percent of the floor area in a mixed-use project. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division • Objective: Create opportunity to accommodate the City’s lower-income RHNA targets. 8.B.g Packet Pg. 572 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 132Chapter 5 | Implementation Programs GOAL 2 Housing production for all income categories including for the community’s workforce and most vulnerable communities. Program 2.A Establish A Moderate-Income Affordable Housing Zoning Overlay The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in at least three targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th Street/Santa Monica College Expo station. The moderate-income affordable housing overlay would allow a height increase of up to three additional stories or 33 feet, 50% density bonus, up to four incentives and concessions, no minimum parking requirements, and flexibility in unit size/unit mix in exchange for additional common area amenities. Program Background: AB 1763 amended State density bonus law (Government Code Section 65915) to allow 100% affordable housing projects unlimited density and up to 3 stories or 33 feet above maximum height limits within 1/2 mile of transit. The changes also provide relief from minimum parking requirements and allow requests for up to four incentives/concessions from local development standards. State Density Bonus law incentives for 100% affordable housing projects only applies to projects up to 80% AMI. The City’s Zoning Ordinance similarly defines 100% affordable housing as only including projects up to 80% AMI. As a result, there are no incentives for moderate income housing projects (serving households up to 120% AMI) even though the City has received a RHNA allocation for moderate income units. In the 5th Cycle Housing Element, the City did not meet its RHNA targets for moderate-income units. In addition, funding sources for 100% affordable projects generally focus on households earning up to 80% AMI and do not provide funding for moderate-income projects. Moderate-income housing units serve an important segment of Santa Monica workers and residents that do not qualify for lower-income affordable units yet cannot afford market rents. • Timeframe: by June 30, 2023• Responsibility: City Planning Division; City Attorney’s Office• Objective: Provide significant incentives for 100% affordable housing including moderate income households. 8.B.g Packet Pg. 573 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 133 City of Santa Monica | 2021 - 2029 Housing Element Program 2.B Right Of First Offer Ordinance For Nonprofit Affordable Housing Providers Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, the City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making non-profit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildings through this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable. Program Background: Acquisition and rehabilitation of existing housing and conversion to affordable units can preserve naturally occurring affordable housing while also providing existing residents the opportunity to maintain their housing at an affordable level and minimize overall tenant displacement. • Timeframe: by December 31, 2024• Responsibility: City Planning Division; Housing and Human Services Division; City Attorney’s Office• Objective: Support 100% affordable housing by assisting nonprofit affordable housing providers to be competitive in the land acquisition market. Program 2.C Update The City’s Affordable Housing Production Program To Increase The Number Of Affordable Housing Units At All Income Levels In order to increase the number of affordable housing units at all income levels such that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to maximize the contributions of the AHPP to achieving the RHNA affordable housing allocation and advancing the City’s affordable housing goals. Areas to be considered may include, but not be limited to: 8.B.g Packet Pg. 574 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 134Chapter 5 | Implementation Programs • Increase the threshold (to at least 6 units) at which projects are required to provide on- site or off-site affordable units. • Eliminate the current “menu” option of affordability requirements and instead establish a new base affordability percentage • Re-evaluate the in-lieu fee option for applicants to pay a fee instead of constructing affordable units to ensure that the fee supports the funding and construction of new affordable housing throughout the City; and • Evaluate the possibility of a mixed-compliance option that would provide applicants more flexibility in meeting AHPP requirements • Increase the minimum percentage of required off-site affordable units to be higher than the on-site option; • Allow projects to locate off-site affordable housing anywhere in the City that is not a disadvantaged area as defined by SB535, which includes socioeconomic and environmental metrics • Allow market-rate projects to comply with AHPP off-site option through acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Program Background: In 1990, Santa Monica voters adopted Proposition R, which requires 30% of all multi-family residential housing that is newly constructed in the City to be affordable for at least 55 years to and occupied by low- and moderate-income households. In July 1998, the City Council enacted an Affordable Housing Production Program (AHPP), requiring developers of market-rate apartment and condominium projects to contribute to affordable housing production and thereby help the City meet its affordable housing need. The current AHPP requires market-rate housing developers to select from a “menu” of options for the production of affordable housing (see table below). However, in 2013, the menu option of the AHPP was amended to add the extremely low-income option, and since that time, the menu 8.B.g Packet Pg. 575 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 135 City of Santa Monica | 2021 - 2029 Housing Element had the effect of producing many affordable units at the extremely low-income level at the cost of production of other income levels, with particular shortages happening at the 80% to 120% AMI income levels. In response, Option 1 (the extremely-low income option) was temporarily removed by adoption of Ordinance 26059(CCS) by the City Council on April 9, 2019 until November 26, 2019, which has since been extended by the City Council until February 28, 2022. This temporary elimination of the extremely low-income “menu” option had the effect of increasing the minimum inclusionary requirement to 10% of total units for Tier 1 projects, and 15% of Tier 2 and 3 projects affordable to 50% AMI households. AHPP Menu Option Tier 1 Tier 2/3 1 5% of the total units at 30% AMI 7.5% of the total units at 30% AMI 2 10% of the total units at 50% AMI 15% of the total units at 50% AMI 3 20% of the total units at 80% AMI 30% of the total units at 80% AMI 4 100% of the total units at 120% AMI Not applicable The AHPP also currently allows developers to fulfill their affordable obligation by providing units off-site or, in limited circumstances, paying an in-lieu fee. However, if a developer elects to provide affordable units off site, the units are required to be located within ¼ mile of the market-rate project, except that within the Downtown Community Plan area, developers of Tier 2 or Tier 3 housing project have the flexibility to locate the off-site housing anywhere within the Downtown. • Timeframe: by April 30, 2023 • Responsibility: Housing and Human Services Division; Economic Development Division; City Attorney’s Office • Objective: Ensure that the AHPP provides housing developers viable options for compliance. Program 2.D Update Density Bonus Ordinance To Ensure Consistency With State Law And Integration Into The City’s Land Use System 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 AHPP. The ordinance will clarify how to apply State density bonus law in the City’s commercial and mixed-use districts that do not have maximum density controls, including application of State density bonuses to floor area dedicated to residential uses. The amendments to the Municipal Code shall also set forth a voluntary by-right menu of incentives & concessions that do not require following the 8.B.g Packet Pg. 576 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 136Chapter 5 | Implementation Programs process under Government Code Section 65915(d) for approval. Requests for “off-menu” incentives and concessions may be requested pursuant to Government Code Section 65915(d). Program Background: 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 for 100% affordable housing projects. At the time of the update in 2020, the City deferred amendments that would clarify how to apply State Density Bonus Law to the City’s commercial and mixed-use districts, pending further study, which has been ongoing since December 2019. After the August 2020 update, Assembly Bill 2345 took effect on January 1, 2021, which expanded and enhanced development incentives for market rate projects that provide affordable housing. AB 2345 increases the maximum density bonus from thirty-five percent (35%) to fifty percent (50%). To be eligible for the maximum bonus of 50%, a project must set aside at least (i) fifteen percent (15%) of total units for very low-income households, (ii) twenty-four percent (24%) of total units for low-income households, or (iii) forty-four percent (44%) of for-sale units for moderate income households. Levels of bonus density between thirty-five percent (35%) and fifty percent (50%) are granted on a sliding scale • Timeframe: by October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Ensure consistency with State Law. Program 2.E Commit To The Production Of Affordable Housing On City-Owned/Publicly- Owned Land The City shall commit City-owned sites for the production of 100% affordable housing, with consideration of other community-serving purposes, including, but not limited, to green space, place making, and/ or community-serving commercial and revenue generating uses. The City shall plan for a minimum of 1,880 affordable housing units across available City-owned sites, which are located throughout the city, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first RFP for a city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as 8.B.g Packet Pg. 577 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 137 City of Santa Monica | 2021 - 2029 Housing Element existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months. As has been done in the past, the City will use a variety of tools to facilitate 100% affordable housing development including but not limited to: • Facilitate appropriate zoning and process to support 100% affordable housing • Substantially reduced or free ground rent • Providing funding through local housing trust fund • Support applications for other funding sources for affordable housing (e.g. low-income- housing tax credits, grants, State funding, Federal funding) • Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Further, 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. Program Background: As a built-out community, the City of Santa Monica has few remaining vacant sites for residential development. This shortage of vacant land necessitates the use of alternative mechanisms for providing sites for housing. In the past, the City has used such mechanisms as long-term leases of City-owned or publicly-owned land. City-owned land is subject to the same development standards as privately-owned land, but may benefit from additional flexibility in order to maximize the development potential for 100% affordable housing. An RFP to redevelop Parking Structure 3 located on the Third Street Promenade as affordable housing was issued in August 15, 2019 and a developer partner was selected. The Parking Structure 3 RFP required that proposals including a significant commitment to permanent supportive housing for people experiencing homelessness and established parameters for affordable housing including long-term income eligibility and affordability covenants, tenant selection from the City’s below- market-rate list, and allowance to target other populations such as working families, seniors, and artist live/work housing. 8.B.g Packet Pg. 578 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 138Chapter 5 | Implementation Programs • Timeframe: RFPs issued by June 30, 2023; June 30, 2025; June 30, 2027 • Responsibility: Housing Division: City Planning Division; Economic Development Division • Objective: Prioritize affordable housing production on city-owned land. Program 2.F New Affordable Housing Finance Programs To Enable Continued Provision Of Technical And Financial Assistance For Housing Production 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. The City has adopted policy on prioritizing our local funding through a Housing Trust Fund plan that includes spending commitments for affordable housing production and preservation for special needs and ELI households, including exploring new funding for conversion to deed-restricted, multi-unit developments in areas of affluence. The plan outlines a funding strategy for ELI households including seniors and persons living with disabilities. The City will continue to implement the policy and execute funding commitments to produce housing targeted to persons experiencing homelessness or at-risk of homelessness. Local funding through the Housing Trust Fund will also help support the production of at leats 1,880 affordable housing units on City-owned/publicly owned land in accordance with Program 2E. On an ongoing basis, the City will continue to communicate with local affordable housing providers on potential housing projects based on funding availability. Financial and technical assistance shall be provided when resources are available and committed to nonprofit housing providers to the greatest extent possible to support the development of affordable housing, including special needs housing and arts housing. The City will research 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 Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Program Background: The City has historically provided technical and financial support to a variety of nonprofit housing providers to support affordable housing development through the local Housing Trust Fund. Since the dissolution of the City of Santa Monica’s Redevelopment Agency (RDA), the main funding source for the Housing Trust Fund comes from a 0.5% sales tax passed by the voters in 2016. Remaining funding sources, such as the affordable housing commercial linkage fee and the affordable housing in-lieu 8.B.g Packet Pg. 579 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 139 City of Santa Monica | 2021 - 2029 Housing Element fee, and contributions from negotiated development agreements, do not provide sufficient funding to fill the gap left from the loss of RDA funds. The City continues to work with nonprofit partners to seek out and apply for federal and state funding, as it has done in the past, which resulted in numerous successful funding efforts by nonprofit affordable housing providers. Santa Monica has been awarded a total of $10 million from the Local Housing Trust Fund (LHTF) program for the 2020 and 2021 funding rounds and is also eligible to receive an estimated $3.285 million from the first five years of the Permanent Local Housing Allocation (PLHA) entitlement program. The awarded State grants, as well as future State grants, are essential to Santa Monica’s ability to create affordable housing on City-owned land and further the goals of the City’s Housing Element. In the current environment, the City will need to think creatively and support efforts at the state and federal level to create new funding opportunities for affordable housing in order to maintain current productivity levels. This Housing Element commits City-owned land for 100% affordable housing. Because land acquisition is typically the largest cost driver for affordable housing, it is anticipated that use of City land will alleviate the impact of land cost on the feasibility of an affordable housing project and allow limited funding resources to be used more effectively in producing affordable housing. • Timeframe: Annual Ongoing • Responsibility: City Planning Division; Housing and Human Services Division • Objective: Seek innovative affordable housing financing tools to increase production. Program 2.G Expand Housing Choice By Facilitating The Development And Maintenance Of Special Needs Housing The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle. This includes the provision of new programs, services, infrastructure and amenities that can help seniors who choose to live independently remain in their homes as long as possible. Within legal constraints, encourage or require housing providers to assign affordable housing units designed for persons with disabilities, including physical or developmental disabilities, for use by those who require those features. The City shall encourage barrier-free construction and adaptation. Through the 5-year Consolidated Plan process, the City shall continue to identify housing and supportive service gaps for various special needs groups and propose policy and priorities based on the analysis. 8.B.g Packet Pg. 580 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 140Chapter 5 | Implementation Programs Program Background: Santa Monica has a significant residential population in classes protected by California State housing law, which include the elderly, Individuals with mental, physical, and developmental disabilities, large families, female-headed households, and homeless individuals and families without permanent housing. Finding access to resources and adequate, affordable housing is often challenging for individuals and families under such circumstances. Housing for seniors and those with disabilities should incorporate features that contribute to a barrier-free environment, ensuring that anyone who uses a wheelchair or other mobility device is able to visit a building, and accessibility to transit and services. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division; Building and Safety Division • Objective: Housing for individuals with special needs. Program 2.H Maintain Proposition I Monitoring The City shall monitor utilization of Proposition I authority through annual reporting of new “low rent- housing projects. Program Background: Article 34 of the State Constitution requires that any low rent housing project developed, constructed, or acquired by a public agency must first be approved by a majority of the voters living in that jurisdiction. 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 one- half of 1% of the total dwelling units existing in the city at the end of the prior fiscal year. This annual authorization may be carried over the three years. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Ensure the City continues to report on compliance with Proposition I. 8.B.g Packet Pg. 581 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 141 City of Santa Monica | 2021 - 2029 Housing Element Program 2.I Zoning For A Variety Of Housing Types Including Special Needs Housing And Housing Access For Persons With Disabilities The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law regarding special needs housing types and residential land use classifications. Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty. Program Background: Since the 2015 Zoning Ordinance update, the State has passed various laws that have removed barriers for special needs housing types, such as emergency shelters, group residential, and supportive/ transitional, as well as other residential land uses. These laws have been put into place to ensure that cities zone for a variety of housing types. • Timeframe: by December 31, 2023 and Annual Ongoing• Responsibility: City Planning Division; City Attorney’s Office; Housing and Human Services Division• Objective: Ensure the City is compliant with all State laws for special needs housing types and residential land uses. Program 2.J Prioritize Water And Sewer Service To Housing Projects With On-Site Affordable Units The City shall establish written procedures to grant priority to developments with on-site units affordable to lower-income households if availability of service is limited. Program Background: Government Code Section 65589.7 requires water and sewer service providers to establish procedures that grant priority water and sewer service to developments that include units affordable to lower- income households. • Timeframe: by December 31, 2023 • Responsibility: Public Works Department • Objective: Prioritize infrastructure service to developments with lower income units to support the production of affordable housing throughout the City. 8.B.g Packet Pg. 582 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 142Chapter 5 | Implementation Programs GOAL 3 Preservation of the existing supply of housing and prevent displacement of existing tenants. Program 3.A Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are Replaced The City shall amend the Municipal Code to adopt local requirements that make permanent and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced. As required by Government Code Section 65583.2(g)(3), the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity’s valid exercise of its police power (approximately 27,484 units), or (3) within the past five years were occupied by low or very low income households, shall be required to replace all of those units as affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth Government Code Section 65915(c)(3). Program Background: SB 330 (effective 01/01/21 through 01/01/25) and SB 8 (extended SB330 through 01/01/30) enacted a program that establishes unit replacement requirements and tenant protections for new housing projects proposing the demolition or removal of “protected units”, generally defined as units subject to any form of rent restrictions or price control. These “protected units” include rent-controlled units that must be replaced as part of a new housing project until SB330 sunsets in 2030. • Timeframe: by June 30, 2023• Responsibility: City Planning Division• Objective: Protect existing residents by preserving existing rental housing stock; no net loss of units. 8.B.g Packet Pg. 583 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 143 City of Santa Monica | 2021 - 2029 Housing Element Program 3.B Develop Tenant And Landlord Programs To Address State And Federal Legislative Mandates Regarding Anti-Discrimination The City shall continue to implement programs throughout the City, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing in light of the loss of formerly affordable units due to vacancy de-control and Ellis withdrawals. The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles Program Background: Residents of Santa Monica adopted the City’s rent control law in 1979. Passage of the Costa-Hawkins Rental Housing Act in 1995 by the State Legislature gradually required vacancy de- control/re-control in apartments, and de-control of houses and most condominiums by January 1999; this enables apartment building landlords to raise the price of rent-controlled apartments to market rate when the unit is vacated and is to be rented to a new tenant, establishing a new base rent for the unit. This has allowed 74% of the rent-control housing stock to reset to market rents. Even with Santa Monica’s exception to the HUD payment standard granted in 2016, the vast majority of Santa Monica’s existing housing supply is out of reach for lower income households. With limited federal funding resources being allocated to cities, the demand for housing assistance outpaces available resources. The City’s progressive legal protections, such as the just-cause eviction protections in rent-controlled units, have contributed to keeping rent-controlled units affordable to current low- and very low– income tenants. In addition, to help reduce the impact of Costa-Hawkins, the City has developed an Housing Anti-Discrimination ordinance (Santa Monica Municipal Code chapter 4.28), which prohibits various types of housing discrimination—such as refusal to rent, differential treatment, discriminatory statements--on the basis of disability, age, source of income, parenthood, pregnancy, or the potential or actual occupancy of a minor child. In 2015, as an affordable housing measure, the City added Source of Income as a protected class and then added an extra layer of protection with a pioneering definition for Source of Income. For the first time in Santa Monica and in California, the fair housing law expressly protected recipients of rental assistance such as Section 8. Furthermore, the City has launched a 2-year pilot Right to Counsel program to assist tenants facing eviction. The City also provides one-time homeless prevention grants to households in danger of losing their housing. 8.B.g Packet Pg. 584 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 144Chapter 5 | Implementation Programs • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division (lead); Rent Control Board • Objective: Develop programs to address State and Federal housing mandates. Program 3.C Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing There are approximately 770 affordable, deed-restricted units that are at-risk of conversion to market rate in the next 10 years. The City will continue to monitor over this Housing Element cycle the status of the approximately 770 affordable deed-restricted at-risk units throughout the City, ensure that required notice is given to tenants, advise property owners and tenants in advance of potential conversion dates, and assist in answering questions from residents of at-risk housing. As a part of the ongoing monitoring, the City will continue to provide information on maintaining long- term affordability and assist federally-funded housing properties with seeking funding assistance in applying for allocations of housing vouchers from the federal government to maintain housing affordability. On an ongoing basis, the City will continue to communicate with local affordable housing providers on conserving housing projects . The City will exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. Additionally, the City shall continue to report annually on non-covenant residential units such as the approximately 27,484 rent-controlled units. Program Background: The City has a variety of affordable housing projects, consisting of 3,902 deed-restricted residences that are currently serving the community. Publicly-assisted housing units with federal rental assistance subsidies are protected by covenants. Those units with covenants nearing expiration are considered “at-risk” of potential conversion to market-rate housing. According to the City’s local data, a total of 770 publicly-assisted housing units protected by covenants that are due to expire in the next 10 years. They are, therefore, at risk of potential conversion to market rate. These units serve seniors or persons with special needs, with one property serving families. In addition to the federal covenants, the affordability of the units in these projects is further protected through additional requirements or incentives that the City placed on their loans when they were constructed. Some units are considered to have a lowered risk of conversion to market rate because they are owned and operated by nonprofits whose mission is to create and maintain affordable housing. As the cost of conserving existing deed-restricted affordable units is far less than the cost of producing new ones, and the need for affordable units remains strong, efforts should be directed at ensuring the long-term affordability of these units for low-income households. 8.B.g Packet Pg. 585 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 145 City of Santa Monica | 2021 - 2029 Housing Element • Timeframe: Annually: staff will identify funds and work with nonprofits as necessary to secure at-risk units, where appropriate and feasible; Ongoing: Monitoring • Responsibility: Housing and Human Services Division • Objective: The City proactively monitors units at risk of conversion due to expiring covenants and takes actions to ensure their long-term affordability. Program 3.D Maintain An Acquisition And Rehabilitation Program 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 for acquisition and rehabilitation throughout the city. As outlined in Program 2.B, the City shall adopt a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer to acquire existing private properties as they become available for purchase. Program Background: The City provides Housing Trust Fund loans to nonprofit housing providers to assist with the purchase and rehabilitation of existing rental properties occupied primarily by low-income households. The acquisition and rehabilitation of existing housing and conversion to affordable rental units preserve naturally occurring affordable housing while also ensuring housing stability for existing tenants by allowing them to remain in their units at deed-restricted affordable rents. • Timeframe: Annual Ongoing• Responsibility: Housing and Human Services Division; Santa Monica Housing Authority • Objective: Protect existing residents by acquiring and rehabilitating existing housing. Program 3.E Maintain A Low-Income Residential Repair Program The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the City. Program Background: The City implements the Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants; and the Owner-Occupied Rehabilitation Program for low- and moderate-income owners. 8.B.g Packet Pg. 586 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 146Chapter 5 | Implementation Programs Minor home modifications improve physical access for people with disabilities and seniors that assist with independent living. Modifications are funded through the City’s Human Services Grants Program using Community Development Block Grant (CDBG) funds. • Timeframe: by 2024 • Responsibility: Housing and Human Services Division; Santa Monica Housing Authority • Objective: Rehabilitate 38 multi-unit dwellings and provide 20 minor home repairs. Program 3.F Enhance Code Enforcement Response To Housing-Related Violations The City shall continue to respond to residential building code violation complaints throughout the City. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day. Program Background: The Code Enforcement Division responds to complaints of violations of City building codes and in coordination with the Building and Safety Division, provides inspections and notices to property owners to bring their units into compliance. In the case of a residential building code violations that do not affect habitability, the City provides up to 30-days to correct the violation. If the work necessitates a building permit, the City provides up to 180 days to correct the violation (the life of the permit). In the case of substandard housing that affects habitability, the City requires the landlord to promptly commence the work to restore the unit(s) to a habitable condition and return tenants to their units through the Habitability Determination Form and Relocation Order and provide tenant protections (temporary relocation). • Timeframe: Annual Ongoing • Responsibility: Building and Safety Division, Code Enforcement Division, Housing and Human Services Division • Objective: Require property owners to respond to Building Code violations and complete routine maintenance on their residential buildings. 8.B.g Packet Pg. 587 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 147 City of Santa Monica | 2021 - 2029 Housing Element Program 3.G Maintain A Mandatory Seismic Retrofit Program The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle. Program Background: In March 2017, the City Council adopted a Seismic Retrofit Ordinance and the City implemented the Seismic Retrofit Program that proactively seeks to strengthen existing earthquake-vulnerable buildings and enhance the safety and security of their occupants. Nearly 2,000 commercial and residential buildings in the City were identified as potentially seismically vulnerable in need of possible structural improvement and are required to comply with the Program within established timeframes based on building types (20-year program overall). Ongoing seismic retrofit improvements to existing multi-unit residential buildings will help maintain the safety and structural integrity of the City’s aging housing stock. • Timeframe: Annual Ongoing • Responsibility: Building and Safety Division • Objective: Protect existing residents by ensuring the safety and structural integrity of existing residential buildings. Program 3.H Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units The City shall provide additional education and outreach to multi-unit property owners on available City programs to support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties. Program Background: Tenants in rent-controlled units who allege that their rental units need repairs or maintenance, or that their housing services have been reduced, may petition to have their monthly rent decreased. In 2019, eighty decrease petitions were filed. Both the City and Rent Control Board co-sponsor an annual Maintenance of Residential Rental Property seminar and coordinate regarding relocation disputes, use of withdrawn properties, and maintenance and enforcement issues. Annual tenant and landlord forums also educate both groups on their rights and responsibilities including but not limited to available programs, resident qualifications, and benefits of program participation. 8.B.g Packet Pg. 588 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 148Chapter 5 | Implementation Programs • Timeframe: Annual Ongoing • Responsibility: Rent Control Board • Objective: Inform property owners regarding proper maintenance of residential units. Program 3.I Right To Counsel Program The City shall continue to implement a Right to Counsel pilot program and evaluate its overall effectiveness, program capacity, and long-term feasibility. Program Background: In April 2021, the City initiated a two-year pilot Right to Counsel program, an initiative to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This pilot program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. The program includes a contract with the Legal Aid Foundation of Los Angeles (LAFLA), the nonprofit law firm for low-income residents, to provide full-scope eviction defense services in which LAFLA attorneys will represent tenants in court. This partnership seeks to provide emergency support to low-income tenants in need of legal assistance. Under the City’s pilot program and Los Angeles County’s parallel program, StayHousedLA, LAFLA has already helped 40 Santa Monica tenants facing eviction obtain full-scope legal representation. Another 42 have received limited scope services. • Timeframe: Ongoing • Responsibility: City Attorney’s Office • Objective: Prevent the displacement of tenants by providing access to legal assistance and support for tenants facing eviction. Program 3.J Restrict Conversion Of Existing Rental Housing To Condominiums The City shall continue to regulate condominium conversions pursuant to SMMC Section 9.24.040. The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory. Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data. 8.B.g Packet Pg. 589 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 149 City of Santa Monica | 2021 - 2029 Housing Element Program Background: Displacement of residents due to economic pressure is one of the main contributing factors to housing segregation. Displacement and gentrification are widespread in Santa Monica with the Ellis Act and Costa-Hawkins Rental Housing Act allowing owners to either exit the rental business and evict all tenants or raise the rents of vacated rent-controlled units. Restrictions on condominium conversions are in place to ensure that required noticing is provided to tenants and that conversions can only occur if there is a surplus of rental housing inventory in the immediate period before approval of a conversion. Condominium conversions are currently regulated by SMMC Section 9.24.040. The Condominium Conversion ordinance sets out the conditions under which a condo conversion could be approved including: 1. Rent Control Board approval to remove units from the rental market 2. Tenants have been given required notice of intent to convert and to seek alternative housing 3. Preparation of a conversion report by City staff 4. Notice of any public hearings 5. Structural, electrical, fire and life safety, and plumbing systems are in good repair and maintenance 6. Findings as required by the Planning Commission including finding that the vacancy factor of rental housing units exceeds 5 percent of the total rental housing inventory for a period of 90 days prior to the date of approval. • Timeframe: Ongoing • Responsibility: City Planning Division • Objective: Restrict loss of rental housing units to condominium conversions. Conversion restrictions will continue to protect and retain older 8.B.g Packet Pg. 590 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 150Chapter 5 | Implementation Programs GOAL 4 A community that provides equitable housing access to all neighborhoods. Program 4.A Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Non-Residential Zones Where Not Currently Permitted 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 amended to add multi-unit housing as a permitted use in areas where housing is currently prohibited. Land use regulations, FAR, and height (as indicated in Program 1.J) will be revised to allow housing in the three zones that currently do not allow housing such as the Office Campus, Industrial Conservation, and Creative Conservation Sector zones. To promote fair and equitable housing opportunities throughout the City, the City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) including in areas that have historically not permitted or accommodated housing, to allow for higher maximum allowable FAR and height in the NC, IC, and OC zoning districts. For the purposes of addressing environmental health considerations, the City shall amend the Zoning Ordinance to specify locations in the City where housing projects are required to conduct an air quality assessment and implement recommendations from the assessment. Program Background: When the LUCE was adopted in 2010, its core growth strategy was to encourage housing in close proximity to major transportation systems, such as the Metro Expo Light Rail and transit corridors, and to protect the City’s residential neighborhoods by discouraging development that would result in displacement of tenants. The housing incentives were balanced with a plan to support the City’s economic base by incentivizing retention of existing commercial and industrial space in select areas of the City to support existing and growing businesses. This growth strategy has resulted in new housing production largely in the Downtown and some limited areas on the boulevards, but it has also perpetuated the historic patterns of housing segregation that remain to this day. Although all of Santa Monica is considered a “high resource” area based on maps produced by the California Tax Credit Allocation Committee, there remain a handful of areas that provide little to no housing opportunities. 8.B.g Packet Pg. 591 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 151 City of Santa Monica | 2021 - 2029 Housing Element • Timeframe: by October 15, 2022 • Responsibility: City Planning Division; City Attorney’s Office • Objective: Support the production of affordable housing and encourage the equitable production of housing across the City. Program 4.B Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses 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 community assembly uses, including religious congregations, including allowing not more than 50% market-rate units to support the affordable housing, unlimited, density, no minimum parking requirements, an additional 33 feet of building height, and allowance for the primary community assembly use and related ancillary use, for the support or expansion thereof, on or above the ground floor. Program Background: AB1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. Approximately seven parcels with religious congregations, which are classified in Santa Monica as community assembly uses, have large surface parking lots, have been identified on the SSI, and are located within high or highest resource areas. During the outreach process of the Housing Element, many of these religious congregations have expressed interest in developing housing on their properties; however, the Zoning Ordinance development standards for these sites severely limits the housing potential of these sites. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division • Objective: Increase equitable access to all residential neighborhoods and incentivize affordable housing in areas that have historically excluded diverse housing opportunities. 8.B.g Packet Pg. 592 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 152Chapter 5 | Implementation Programs Program 4.C Provide New Housing Choices And Affordability In High Opportunity Areas Through Incentives For Additional ADUs In R1-Zone Neighborhoods The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with Program 4.F. This would include allowing an additional ADU to be constructed if the ADU is deed restricted as a rental unit. As ADUs are naturally more affordable by design given their size, the program would help affirmatively further fair housing by helping to provide new housing choices and affordability in high opportunity areas of the City that are largely unaffordable to many people. Program Background: Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, 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. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City. 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. The vast majority of new ADUs constructed or under development in the past 3 years have been in the City’s R1 (single- unit) neighborhoods, providing a valuable source of rental housing access in otherwise high cost neighborhoods. Under State law, properties are permitted to have one ADU and one JADU. This program will further allow one more ADU on single-unit dwelling parcels with the requirement that the additional third ADU be restricted to permanent rental housing. This program will incentivize the production of ADUs thus providing new housing choice and affordability in the high opportunity areas of the R1 neighborhoods. • Timeframe: by June 30, 2023 • Responsibility: City Planning Division • Objective: Increase equitable access to all neighborhoods by lowering barriers to housing access in areas that have historically excluded diverse housing opportunities. 8.B.g Packet Pg. 593 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 153 City of Santa Monica | 2021 - 2029 Housing Element Program 4.D Right To Return Program The City shall continue to implement a Right to Return Pilot Program and evaluate outreach strategies, applicant demand, the availability of historical documentation, verification processes, compliance with government legislation, and the administrative resources required to implement a broader long- term program. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households. Program Background: In July 2021, the City initiated a Right of Return Pilot Program that prioritizes housing for the historically displaced households in Santa Monica during the 1950s and 1960s due to urban renewal policies. The pilot program implements historical displacement policy by providing housing access to former residents or their descendants who were displaced by the creation of the Civic Auditorium in the Belmar Triangle neighborhood and the I-10 freeway in the Pico neighborhood, both of which disproportionately impacted low- income communities and communities of color. Qualifying households will be placed on the City of Santa Monica’s affordable housing waitlist (Below Market Housing waitlist) with Second Priority and will be referred to affordable housing providers as housing units become available. • Timeframe: Annual Ongoing• Responsibility: Housing and Human Services Division• Objective: Address the historical displacement of Santa Monica households which resulted from the development of the Civic Auditorium and I-10 freeway through the Pico neighborhood during the 1950s and 1960s that disproportionately impacted low-income communities and communities of color and displaced thousands of households living in Santa Monica. Construction of the Civic Center Auditorium in 1957Source: Santa Monica Public Library 8.B.g Packet Pg. 594 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 154Chapter 5 | Implementation Programs Program 4.E PROVIDE NEW HOUSING CHOICES AND AFFORDABILITY IN HIGH OPPORTUNITY AREAS THROUGH INCENTIVES FOR SB9 UNITS IN R1-ZONE NEIGHBORHOODS The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. In addition, these SB9 units shall be required to be rented or sold. This will open up the possibility for property owners to construct up to 6 units through a multi-step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F. Program Background: Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, 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. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City. SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, is a state bill that requires cities to allow one additional residential unit onto parcels zoned for single-unit dwellings. Allowing homeowners proposing SB9 projects to also construct ADUs, particularly on larger parcels, will increase new housing opportunities in high opportunity areas and also promote place-based strategies for community revitalization by increasing housing opportunities in all areas of Santa Monica. • Timeframe: June 30, 2023 • Responsibility: City Planning Division • Objective: Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods 8.B.g Packet Pg. 595 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 155 City of Santa Monica | 2021 - 2029 Housing Element Program 4.F ESTABLISH TARGET TO INCREASE HOUSING PRODUCTION IN R1 ZONES AND INCLUDE MID-CYCLE MONITORING The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. • Timeframe: Assess progress by December 31, 2025 • Responsibility: City Planning Division • Objective: Increase the number of net new housing units in R1 zones GOAL 5 Housing for persons experiencing homelessness. Program 5.A Reduce The Number Of Homeless Individuals Living On The Streets Of Santa Monica Through The Provision Of A Range Of Housing Options, With An Emphasis On Affordable, Permanent, Supportive Housing The City shall continue to seek and leverage funds that contribute to the development of a range of permanent, supportive housing options, within and outside of Santa Monica. Focus case management and housing resources on the most chronic and vulnerable homeless individuals that have been identified on the City’s Homeless Service Registry. Continue to serve other priority homeless populations through City- funded programs. Continue strategies to reunite those not first-homeless in Santa Monica with family and friends in their home communities. Review City policies and practices that may contribute to homelessness. Program Background: Santa Monica has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. In March 2019, the City introduced the Four “Pillars” upon which the City’s homeless strategies are based; 1) preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities; 2) addressing the behavioral health needs of vulnerable residents; 3) maintaining equitable access to safe, fun, and healthy open spaces; and 4) strengthening regional capacity to address homelessness. These strategies have been implemented 8.B.g Packet Pg. 596 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 156Chapter 5 | Implementation Programs through interdepartmental and community partnerships that contributed to a sustained reduction in homelessness in the City’s downtown and beach areas, and helped contribute to an 8% local reduction in the City of Santa Monica’s annual Homeless Count in 2019. On an annual basis, the City supports agencies that provide supportive services, emergency shelter, and transitional and permanent supportive housing beds to Santa Monica’s priority homeless populations. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Continue to invest in and implement housing and supportive services to prevent and address the impacts of homelessness. Program 5.B Low Barrier Navigation Centers As By-Right Use The City shall amend the Zoning Ordinance to allow Low Barrier Navigation Centers as a by-right permitted use in all non-residential zones permitting multi-unit uses. Program Background: Assembly Bill 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multi-unit uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a housing first, low-barrier, service- enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter and housing. • Timeframe: December 31, 2023 • Responsibility: City Planning Division • Objective: Ensure the City’s regulations and procedures are in conformance with State Law. The Ocean Park Community Center (OPCC), an example of a Low Barrier Navigation Center in Santa Monica. 8.B.g Packet Pg. 597 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 157 City of Santa Monica | 2021 - 2029 Housing Element GOAL 6 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. Program 6.A Enhance Housing Mobility By Maintaining Rental Housing Voucher Programs Throughout the City And Expand To Assist All Persons With Disabilities The City shall continue to operate strong rental housing voucher programs throughout the City and advocate for funding guidelines for Section 8 that are competitive for Santa Monica; and shall pursue additional funding to maintain and expand voucher programs, if possible. Review and update the Housing Authority Administrative Plan annually to ensure compliance with the latest HUD regulations and to provide flexibility to respond to tenants’ needs consistent with legal requirements. Utilize vouchers as a tool to prevent senior homelessness where eligible. When funding opportunities are available, expand the rental housing voucher programs to fill the gap between income levels and the cost of housing for persons with permanent disabilities, including persons with Developmental Disabilities. Program Background: The Santa Monica Housing Authority (SMHA) administers two types of rental assistance vouchers, tenant-based and project-based, across five different federal housing programs: Housing Choice Voucher (HCV); Continuum of Care (CoC); HOME Investment Partnerships Program (HOME); Veterans Affairs Supportive Housing (VASH), and Emergency Housing Voucher (EHV) programs. Tenant-based vouchers are allocated to specific individuals, which allow participants to choose where to lease rental housing, whereas project-based vouchers are allocated to specific properties rather than participants. In FY2021-21, the SMHA administered approximately 1,600 rental housing vouchers, including Section 8, Continuum of Care vouchers, HOME vouchers, and VASH vouchers. The HOME program targets rent-burdened households at-risk of becoming homeless and persons who have been homeless for at least a year. Of the 772 vouchers that were used, voucher households reside throughout Santa Monica’s multifamily neighborhoods, with no concentration in one zip code. Five properties in Santa Monica representing senior and supportive affordable housing with significant allocations of project-based vouchers are located in zip codes 90401 (Downtown), 90403 (Wilshire- Montana/Northeast) and 90405 (Ocean Park/Sunset Park) representing a total of 340 affordable housing opportunities. 8.B.g Packet Pg. 598 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 158Chapter 5 | Implementation Programs Distribution of Voucher Households 2017-2021 by Santa Monica Zip Code Tenant-Based Vouchers Project-Based Vouchers Total Rental Housing Vouchers 90401 (Downtown) Count 154 155 309 Percentage 31%57%40% 90402 (North of Montana) Count 2 0 2 Percentage 0%0%0% 90403 (Wilshire-Montana/Northeast) Count 44 102 146 Percentage 9%37%19% 90404 (Mid-City/Pico) Count 178 0 178 Percentage 36%0%23% • Timeframe: Annual Ongoing • Responsibility: Santa Monica Housing Authority; Housing and Human Services Division • Objective: Maintain voucher programs to ensure availability and choice of housing for households at all income levels. Program 6.B Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle. 8.B.g Packet Pg. 599 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 159 City of Santa Monica | 2021 - 2029 Housing Element Program Background: The City monitors the availability of Federal, State, and County funding sources to support rental assistance programs on an ongoing basis. The City also undertook eviction prevention efforts to focus on keeping residents housed during the ongoing COVID-19 pandemic. The Legal Aid Foundation of Los Angeles (LAFLA) supported residents in maintaining housing through their general legal services program, which provides eviction defense services. Since April 2021, under the City’s Right to Counsel pilot program and County’s Stay Housed LA Program, LAFLA has provided 81 tenants facing eviction with legal representation. In FY2020-21 LAFLA’s general legal services program served 590 Santa Monica households utilizing $506,149 in Human Services Grants Program funding. The City also created an enhanced communications campaign to inform renter residents and property owners about the State Rental Assistance program, Housing is Key, and to support with application completion. Educational efforts focus on multilingual outreach to the most vulnerable residents who may not have access to online information. Application support was provided by City staff who answered questions, ran a clinic, and connected residents with the State’s help center and established partner organizations. As of June 7, 2022, 2,207 Santa Monica households were served with an average assistance of $15,566 and $34,354,444 total funds paid. In addition to the State Rental Assistance program, the City implemented the COVID Emergency Rental Assistance Program (ERAP) using $2,549,979 in federal Community Development Block Grant funds (CDBG) and General Funds of $251,535 to provide three months’ rent up to $5,000 to 640 households economically impacted by COVID. A total of 1,106 applications were submitted; 104 households did not qualify for or declined assistance, and an additional 362 households were not offered assistance due to lack of funding (of these 86 received assistance through the LA County program). Funding for program administration came from CDBG and the re-purposing of a County homelessness grant through the Westside Cities Council of Governments (WSCCOG). The Los Angeles County Development Authority (LACDA) also administered a rental assistance program that opened in August 2020 to assist applicants throughout the County with a total of $133 million from the Coronavirus Aid, Relief, and Economic Security Act (CARES) and County General Funds. At the close of the program, 435 Santa Monica residents were awarded approximately $3.81 million in assistance through the County program. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Maintain housing stability for vulnerable individuals and households. 8.B.g Packet Pg. 600 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 160Chapter 5 | Implementation Programs Program 6.C Maintain And Expand The Preserving Our Diversity (Pod) Program The City shall continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. The program shall ensure that POD subsidies do not result in an increase in rents. The City intends the POD Program to serve at least 150 participants within this Housing Element cycle. Support measures that are not housing constraints to generate and allocate tax revenue for income assistance. Program Background: The City’s POD program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors to have a minimum amount of income remaining after rent is paid each month for food and medical expenses. Currently, the program is available for qualifying long-term senior residents. In FY2020-21, the POD program served 196 low-income senior households providing an average monthly assistance of approximately $500 per month, allowing participants to age in place. Applications for POD are accepted both online and by mail, with assistance for those seeking a reasonable accommodation. • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Assist POD beneficiaries in achieving a basic needs budget. Program 6.D Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources The City shall prioritize additional education and outreach to tenants and landlords throughout the City 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. The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational webinars per year. Program Background: Rental housing vouchers provide extremely low- and very low-income households with rent subsidies to bridge the gap between what the household can afford and market rents, although there is a limit to the subsidy amount. The Santa Monica Housing Authority has collaborated with owners of senior 8.B.g Packet Pg. 601 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 161 City of Santa Monica | 2021 - 2029 Housing Element housing developments to obtain hundreds of new vouchers allocated to the senior developments allowing property owners to fund rehabilitation and maintenance and ensuring long-term affordability for the existing tenants. The Municipal Code and State law require rental property owners to accept Section 8 or housing vouchers and prohibit discrimination against an applicant based on source of income, including housing vouchers. Comments from tenants and landlords during the community engagement for this Housing Element update indicate that there continues to be lack of awareness of the availability of housing programs that could benefit both groups. • Timeframe: Ongoing subject to additional staffing resources • Responsibility: Housing and Human Services Division • Objective: Raise awareness of housing assistance programs and tenant and landlord rights and responsibilities. Maintain A Community Development Grant Program The City shall continue to fund supportive services that serve the priority homeless populations, striking a balance between existing programs that have demonstrated effectiveness and national best practices that are consistent with the City’s adopted Action Plan to Address Homelessness in Santa Monica. Program Background: Santa Monica currently provides funding to 19 nonprofit human service and housing development organizations supporting different programs through the Community Development Grant Program. These programs serve, in part, to assist homeless persons, very low–, and low-income households, and special need populations. Funds are provided through a broad array of funding sources including but not limited to the City’s General Fund, HOME, and Community Development Block Grant Fund. The Rent Control Department hosts several workshops and seminars for tenants and landlords throughout the year. Program 6.E 8.B.g Packet Pg. 602 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 162Chapter 5 | Implementation Programs • Timeframe: Annual Ongoing • Responsibility: Housing and Human Services Division • Objective: Maintain a grant program to fund-programs that service priority homeless populations, lower-income households, and special needs populations. Program 6.F Provide Tenant Relocation Assistance The City shall continue to implement the Tenant Relocation Assistance program; periodically review existing City policies and ordinances and recommend modifications if deemed necessary, including but not limited to, additional support in locating new housing for displaced residents upon relocation. The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica. Program Background: The City’s Municipal Code provides several tenant relocation programs to protect tenants living in rent-controlled units, with certain exceptions. When a unit is withdrawn from the housing stock, or the landlord recovers possession of a unit, landlords are required to pay a relocation fee for each unit based upon the size of the unit. An additional fee is required if one or more of the tenants is a senior, disabled, or a minor. In lieu of providing financial relocation assistance, the landlord may provide actual physical relocation if the new unit is comparable to the original unit. • Timeframe: Annual Ongoing • Responsibility: City Attorney’s Office, Housing and Human Services Division, Rent Control Board • Objective: Provide displaced tenants with cash-based relocation assistance. Program 6.G Maintain A Temporary Relocation Program The City shall continue the Temporary Relocation Program, including program oversight and enforcement, and coordination in providing accommodations to minimize impacts to residents including emergency hotel vouchers for tenants who have been ordered to vacate their units by the City for code violations, safety improvements, or maintenance. The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated. 8.B.g Packet Pg. 603 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 163 City of Santa Monica | 2021 - 2029 Housing Element Program Background: This program is designed to provide housing for persons temporarily displaced as a result of repairs to their dwelling unit due to health and safety violations or to comply with mandatory programs such as the Seismic Retrofit Program. • Timeframe: Annual Ongoing • Responsibility: Building and Safety Division, Housing and Human Services Division • Objective: Provide housing for tenants temporary displaced from their units due to required maintenance. Program 6.H Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing The City shall maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws. Program Background: With the anticipated demographic changes resulting in an aging population and increased interest in enhancing opportunities to age in place and live independently, the Zoning Ordinance includes a reasonable accommodation procedure to enable persons with a disability to request an accommodation from land use and zoning regulations, policies and practices as needed to provide those individuals with an equal opportunity to use and enjoy a dwelling, consistent with fair housing law. • Timeframe: Ongoing • Responsibility: City Planning Division • Objective: Provide regulatory relief to enable housing access for disabled persons. 8.B.g Packet Pg. 604 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 164Chapter 5 | Implementation Programs GOAL 7 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. Program 7.A Maintain Fair Housing Enforcement And Outreach Programs The City shall continue to implement fair housing programs. The City shall educate landlords about discrimination and educate the real estate community on the necessity of ensuring that their practices meet the objectives of the fair housing laws. The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide tenant application assistance and support to special needs populations including seniors, persons with disabilities, and individuals transitioning from institutional settings and individuals who are at risk of institutionalization. Program Background: The City Attorney’s Office, through its Public Rights Division (PRD), along with other government agencies, enforces federal, state and local fair housing laws. The PRD has an in-house attorney with expertise in fair housing law and a Spanish-speaking community liaison who works with the attorney. The PRD investigates discrimination complaints and offers education and programs to residents on their rights and responsibilities under the fair housing laws, and takes complaints involving housing discrimination based on all protected classes, but primarily on disability, family status, source of income, and race. Most of the cases are resolved informally, using demand letters, calls, and meetings to either to persuade the need for a change in what the landlord is doing or to conclude that there is insufficient evidence of a fair housing violation However, if there is sufficient evidence of ongoing fair housing violations and the landlord has refused to correct the problem, then the PRD often files a lawsuit in court to enforce the fair housing laws. Since 2007, the PRD hosts a Fair Housing Workshop twice a year. The workshop covers several topics, including reasonable accommodations for tenants with disabilities, the City’s Right to Return program, pandemic-related issues in fair housing, and source-of-income discrimination laws which protect Section 8 voucher-holders and users of rental assistance. All owners, property managers, attorneys, social-service providers, and tenants are invited to attend, free of charge. Over the years, hundreds of tenants and housing providers have attended. The PRD’s workshops continued even through the pandemic, with a switch to virtual settings. The 8.B.g Packet Pg. 605 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 165 City of Santa Monica | 2021 - 2029 Housing Element City has also made fair housing presentations to other local and regional groups. Just since April 2020, the City presented or even co-hosted housing rights events sponsored by Santa Monica Rent Control Board, the Legal Aid Foundation of Los Angeles, Western Center for Law & Poverty, Santa Monicans for Renters’ Rights, Fair Housing Council of San Diego, ACLU of Southern California, WISE & Healthy Aging, St. Joseph’s Center, and the Santa Monica Committee for Racial Justice. • Timeframe: Ongoing • Responsibility: City Attorney’s Office • Objective: Education of tenants and landlords of their rights and responsibilities under fair housing laws. Program 7.B Provide Tenant/Landlord Mediation And Legal Services The City shall continue to support tenant/landlord mediation and legal services assistance. Program Background: The Santa Monica Rent Control Board also mediates disputes between tenants and property owners that arise from rent control law. The City has also partnered with the Status Institute for Dispute Resolution at Pepperdine University School of Law to provide mediation services to help resolve landlord tenant for Santa Monica residents, free of charge. The Housing and Human Services Division funds the Los Angeles Legal Aid Foundation to provide legal services related to housing to low-income Santa Monica residents. Referrals are also made to local dispute resolutions services. • Timeframe: Ongoing • Responsibility: City Attorney’s Office; Rent Control Board; Housing and Human Services Division • Objective: Provide tenant/landlord dispute resolution services. 8.B.g Packet Pg. 606 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 166Chapter 5 | Implementation Programs Program 7.C Maintain The Anti-Discrimination And Tenant Protection Program The City shall continue to prevent discrimination, tenant harassment, and unlawful evictions through monitoring and enforcing of “just cause” eviction protections, and continue to provide fair housing services through the Public Rights Division of the Santa Monica City Attorney’s Office. The City shall review current laws and recommend any needed modifications to ensure protection of tenants to the maximum extent possible. Program Background: Santa Monica has long maintained anti-discrimination protections, which among other prohibitions, prevents a tenant from being evicted if the eviction is based on the tenant’s familial status, including tenant’s status of being married or having children. The Public Rights Division (PRD) of the Santa Monica City Attorney’s Office handles complaints, answers questions about possible violations of the Fair Housing laws in Santa Monica and investigates possible fair housing violations. • Timeframe: Ongoing • Responsibility: City Attorney’s Office; Rent Control Board; Housing and Human Services Division • Objective: Protect existing tenants from harassment and unlawful eviction. 8.B.g Packet Pg. 607 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 167 City of Santa Monica | 2021 - 2029 Housing Element A. Quantified Objectives Pursuant to Government Code Section 65583(b), the City has developed quantified objectives for housing production, housing rehabilitation, and housing assistance as required by State law. The following sets forth these objectives for the 2021–2029 planning period. 1. New Construction Objectives The City of Santa Monica was allocated 8,895 units, of which 6,168 units must be affordable, in the 2021-2029 Regional Housing Needs Assessment (RHNA) adopted by the Southern California Association of Governments (SCAG) and certified by the State Department of Housing & Community Development in March 2029. 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 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 5th 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 it unrealistic that the City will be able to achieve its 6th Cycle RHNA for affordable housing units. 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 be filled by sources other than the City. For privately-funded inclusionary units, the estimated cost to a developer is approximately $480,000. Figure 5-1 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. 8.B.g Packet Pg. 608 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 168Chapter 5 | Implementation Programs Figure 5-1: RHNA vs. Quantified Objective Household Income Category RHNA % of Total Quantified Objective % of Total Very Low 2,794 31%1,116 16% Low 1,672 19%654 10% Moderate 1,702 19%479 7% Above Moderate 2,727 31%4,459 67% Total 8,895 6,798 Source: City of Santa Monica Community Development Department The goal of 6,798 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 objectives reflect the lack of public financing available for affordable housing. Even with maximizing affordable housing on City-owned sites and the City’s inclusionary requirements from the AHPP and DCP, providing 69% of the future units as affordable will be difficult. The quantified objective aims for 33% of units produced to be affordable to low and moderate income households. This is in excess of the requirement set forth in the City’s Proposition R (passed in November 1990). Proposition R specifies that at least 30% of all new multifamily-residential housing constructed in the city on an annual basis be permanently affordable to low and moderate-income households with at least 50% of the newly constructed units required to be permanently affordable to low-income households. 2. Housing Rehabilitation and Conservation Objectives Housing Rehabilitation programs are important for maintaining the integrity of existing housing stock, preventing displacement of existing residents, preserving the overall quality of neighborhoods, and contributing to a higher quality of life. With respect to housing conservation, the City provides rehabilitation assistance through two main programs: • The Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants • The Owner-Occupied Rehabilitation Program for low- and moderate-income owners (typically used for mobile-home owners). 8.B.g Packet Pg. 609 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 169 City of Santa Monica | 2021 - 2029 Housing Element The City of Santa Monica’s goal for the Housing Element planning period is to support and fund the rehabilitation of 38 units of multi-family and provide 20 minor home repairs, as shown in Figure 5-2. A new program has been added for this Housing Element based on the analysis of affordable housing units with covenants that expire, putting them potentially at risk of losing their affordability. While the City has focused its efforts in recent years on new construction, acquisition and rehabilitation continues to be an important tool for conserving existing rental housing. The housing is restricted as affordable housing for a period ranging from 55-80 years. Such units were not ‘counted’ toward fair share housing production, but are consistent with the City’s policies for preserving affordable housing units. During the last Housing Element period (2014-2021), the City invested more than $33 million in the acquisition and rehabilitation of existing rental housing, creating four projects with 88 units for very-low and low-income households. Available funding continues to be a significant issue to support this program’s capacity at present levels. The Housing Plan therefore reflects a reduced quantitative objective for the acquisition and rehabilitation of 40 housing units affordable to very-low income households over the next eight years (Figure 5-2). The City will continue to seek funding sources to maintain this program and exceed the objective. The City’s housing and supportive services supports long-term residency and housing affordability. As outlined in the next section, the City has an aggressive program for funding housing and supportive services to special needs populations. These supportive programs help to conserve housing units in that rental/housing assistance, in the form of financial support and legal support for tenants against eviction, assist tenants in maintaining housing, prevent resident displacement, and preserve housing stock. Accordingly, an estimated number of housing vouchers and qualifying tenants for supportive services are reflected as “units” in Table 5-2 under the conservation objective: • The Preserving Our Diversity (POD) Program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors. It is estimated to include at least 150 participants within the next housing cycle. • Rental assistance voucher programs include Section 8, Continuum of Care, HOME Tenant-Based Rental Assistance (TBRA) vouchers, and Veterans Affairs Supportive Housing. The City will continue to provide an estimated 1,600 housing vouchers for qualified residents. 8.B.g Packet Pg. 610 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 170Chapter 5 | Implementation Programs • The City’s Right to Counsel Program is an initiative to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This pilot program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. Maintaining housing for low-income residents also contributes to the conservation of existing units. Assuming the current two-year pilot program will be renewed regularly and annual funding remains consistent over the next 8 years, the goal of the City is to provide assistance to an estimated 210 participants within the next housing cycle. Figure 5-2: 2021-2029 Housing Rehabilitation and Conservation Quantified Objective Income Category Rehabilitated Units Conservation Units Definition Multi-Family Rehabilitation Minor Home Repairs Acquisition & Rehabilitation POD Rental Assistance Vouchers Right to Counsel Very Low 0-50% of County MFI 19 10 40 150 1,600 0 Low 51 to 80% of County MFI 19 10 0 0 0 210 Moderate 81 to 120% of County MFI 0 0 0 0 0 0 Upper Over 120% of County MFI 0 0 0 0 0 0 Totals 38 20 40 150 1,600 210 58 2,000 8.B.g Packet Pg. 611 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 171 City of Santa Monica | 2021 - 2029 Housing Element 3. Housing and Supportive Services The City of Santa Monica has an aggressive program for funding housing and supportive services to special needs populations. These include households with very low or extremely low incomes, persons with disabilities, large families, seniors, the homeless, and other persons in need of assistance. The City’s goals for housing assistance and supportive services during the 2021-2029 Housing Element period, contingent upon the availability of adequate funds and annual City Council approval, are: • Rental Assistance Vouchers: Continue to provide about 1600 vouchers, including Section 8, Continuum of Care, HOME Tenant-Based Rental Assistance (TBRA) vouchers, and Veterans Affairs Supportive Housing vouchers. • Homeless Services: Focus efforts on the priority populations defined in the Action Plan for Addressing Homelessness in Santa Monica: o The long-term chronic and vulnerable of the homeless population living on the streets of Santa Monica, including homeless veterans o Persons whose last permanent address is in Santa Monica o Vulnerable members of Santa Monica’s workforce o High users of local first responder services • Regional Partner: Continue to be an active partner in finding regional solutions to the problem of homelessness. • Health Care for Low Income Persons: Provide primary health care for over 2,700 low- income Santa Monica residents annually. • Legal Assistance: Provide legal advice and referrals to over 700 low-income Santa Monica residents in the areas of housing, government benefits, and family-law issues annually. • Senior and Disabled Services: Support and fund a variety of services for senior and disabled individuals, including: o Provide paratransit services for approximately 2,200 seniors and persons with disabilities annually. This includes providing approximately 1,400 one-way, escorted trips for people who need extra assistance, as well as limited after- hours taxi service. 8.B.g Packet Pg. 612 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 172Chapter 5 | Implementation Programs o Provide a range of health and mental health services, including health screenings, primary medical care, health education, peer counseling (individual, group, and family), caregiver services, and care coordination o Provide intensive care management services primarily to low-income Santa Monica seniors that include in-home assessments, purchase of services necessary to maintain the client in his/her home, benefits assistance, referrals to other agencies, and close monitoring of clients. o Provide care management and other support services in conjunction with the Santa Monica Police Department’s efforts to address elder abuse. o Through the non-profit WISE & Healthy Aging (WISE) Diner Meal Program, provide a well-rounded lunch to older adults at three City sites. Boxed meals were provided via pickup or delivery while COVID-19 restrictions were in place. o Provide home-delivered meals to approximately 300 home-bound seniors and persons with disabilities annually. With COVID-19, the need for home-delivered meals increased significantly, with about 650 individuals having accessed this service. o Provide ongoing operating support for WISE’s Adult Day Care Center serving frail seniors, including seniors with Parkinson’s and Alzheimer’s Disease. o Provide expanded healthy living and arts programming, and opportunities for socialization for older adults with linkages to supportive services, through the consolidation of services in a one-stop facility. • Housing Modifications for Individuals with a disability: Continue to provide funding to the Disability Community Resource Center, which provides home modifications to low-income households that include a person with a disability. Modifications include the installation of grab bars, nonslip bath mats, ramps, shower benches, and toilet seat hand rails, as well as larger projects such as stair lift installations. Provide assistance to approximately 15 individuals annually. 8.B.g Packet Pg. 613 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Image 8.B.g Packet Pg. 614 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Glossary 8.B.g Packet Pg. 615 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 175 City of Santa Monica | 2021 - 2029 Housing Element 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 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. 8.B.g Packet Pg. 616 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 176Glossary 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 A household whose gross income does not exceed 30% of the area median income. 14. VLI: Very-Low Income A household whose gross income does not exceed 50% of the area median income. 15. LI: Low-Income A household whose gross income does not exceed 80% of the area median income. 16. Moderate-Income: 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 8.B.g Packet Pg. 617 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 177 City of Santa Monica | 2021 - 2029 Housing Element 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 27. DCP: Downtown Community Plan o LT: Lincoln Transition o NV: Neighborhood Village o BC: Bayside Conservation (Promenade) o BC: Bayside Conservation (2nd & 4th Streets) o TA: Transit Adjacent o OT: Ocean Transition o WT: Wilshire Transition 28. BAP: Bergamot Area Plan o BTV: Bergamot Transit Village o MUC: Mixed-Use Creative o CAC: Conservation: Arts Center o CSC: Conservation: Creative Sector 29. NOMA: North of Montana Neighborhood 30. Wilmont: Wilshire-Montana Neighborhood 8.B.g Packet Pg. 618 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 8.B.g Packet Pg. 619 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E: Constraints on Housing ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●● ● ● ● ● ● ●●● ● ● ● ● ● 8.B.h Packet Pg. 620 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Table of Contents INTRODUCTION ...................................................................................................................................................................... 4 A. GOVERNMENTAL CONSTRAINTS ........................................................................................................................ 4 1. Land Use Controls .................................................................................................................................................... 4 a. Land Use and Circulation Element ............................................................................................................. 5 b. Zoning Ordinance .............................................................................................................................................. 8 i. Affordable Housing ...................................................................................................................................... 14 ii. Affordable Housing Production Program ........................................................................................ 14 iii. Community Benefits ................................................................................................................................... 15 iv. Parking Requirements................................................................................................................................ 15 v. State Density Bonus ..................................................................................................................................... 17 c. Downtown Community Plan ....................................................................................................................... 18 d. Bergamot Area Plan ........................................................................................................................................ 21 e. Civic Center Specific Plan ............................................................................................................................ 23 f. Local Coastal Program ................................................................................................................................. 24 2. Zoning for a Variety of Housing Types ........................................................................................................ 24 a. Accessory Dwelling Units /Junior Accessory Dwelling Units ...................................................... 27 b. Emergency Shelters ........................................................................................................................................ 30 i. Capacity for Emergency Shelters ........................................................................................................ 31 c. Employee Housing ........................................................................................................................................... 32 d. Farmworker Housing ...................................................................................................................................... 32 e. Group Residential ............................................................................................................................................. 32 f. Low Barrier Navigation Centers ............................................................................................................... 33 g. Manufactured Homes and Mobile Home Parks ................................................................................ 33 h. Residential Facilities ........................................................................................................................................ 34 i. Single-Room Occupancy Housing .......................................................................................................... 35 j. Supportive/Transitional Housing .............................................................................................................. 36 3. Zoning Regulations and Practices for Persons with Disabilities ..................................................... 37 a. Definition of a Family ....................................................................................................................................... 37 b. Definition of Disability ..................................................................................................................................... 38 c. Reasonable Accommodation .................................................................................................................... 38 4. Building Codes and Code Compliance ...................................................................................................... 39 a. Building Code Implementations ............................................................................................................... 39 b. Local Amendments ......................................................................................................................................... 40 c. Compliance and Enforcement .................................................................................................................. 42 5. On- and Off-Site Improvements.................................................................................................................... 42 6. Entitlement and Development Impact Fees ............................................................................................ 43 7. Entitlement and Permit Processing .............................................................................................................. 48 a. Processes and Thresholds ........................................................................................................................... 48 b. Ministerial Approvals ....................................................................................................................................... 49 i. Administrative Approvals ........................................................................................................................ 49 ii. Building Permit Only Projects ................................................................................................................ 50 8.B.h Packet Pg. 621 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) c. Discretionary Approval.................................................................................................................................. 50 i. Development Review Permit ................................................................................................................. 50 d. Architectural Review Board ........................................................................................................................ 52 e. Use Permits and Other Processes............................................................................................................ 53 i. Conditional and Minor Use Permits ..................................................................................................... 53 ii. Subdivision Maps .......................................................................................................................................... 55 f. State Law .............................................................................................................................................................. 56 i. Senate Bill 330 ............................................................................................................................................... 56 ii. Senate Bill 35 .................................................................................................................................................. 57 iii. Housing Accountability Act .................................................................................................................... 57 8. Local Measures, Propositions, Rent Control Law, and Ordinances ............................................. 58 a. Santa Monica City Charter Section 615 ................................................................................................. 58 b. Rent Control ........................................................................................................................................................ 59 i. Vacancy Decontrol ..................................................................................................................................... 60 ii. Just Cause Eviction ..................................................................................................................................... 60 iii. Tenant Harassment Protections ......................................................................................................... 62 iv. Relocation Assistance ............................................................................................................................... 62 v. Rent Control Dispute Resolution .......................................................................................................... 63 c. State of California, Article 34 ...................................................................................................................... 64 d. Home Sharing (Short-Term Rental) Ordinance ............................................................................... 65 e. Residential Leasing Requirements Ordinance .................................................................................. 66 f. City Anti-Discrimination Ordinances ..................................................................................................... 67 i. Sexual Orientation or Domestic Partnership ................................................................................. 67 ii. Persons Living with AIDS ........................................................................................................................... 67 iii. Families with Children ............................................................................................................................... 67 g. Rent Control Bootleg Unit Ordinance ..................................................................................................... 68 h. Water Neutrality Ordinance ....................................................................................................................... 68 B. NON-GOVERNMENTAL CONSTRAINTS ......................................................................................................... 70 1. Construction Costs ............................................................................................................................................... 70 2. Land Costs and Availability ................................................................................................................................ 71 3. Availability of Financing ....................................................................................................................................... 71 4. Requests for Housing Development at Reduced Densities .............................................................. 72 5. Length of Time Between Project Approval and Applications for Building Permits .............. 72 8.B.h Packet Pg. 622 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-4 INTRODUCTION The City of Santa Monica has consistently placed the provision of adequate and affordable housing for all residents as one of its primary goals. However, many factors can encourage or constrain the development, maintenance, and improvement of housing including governmental, market, construction, and infrastructure constraints. Pursuant to Government Code Section 65583(a)(5-6), this appendix identifies potential governmental and nongovernmental constraints and analyzes the extent to which the City can mitigate the negative impacts of these constraints where possible. A thorough understanding of the current constraints to housing development can help to create appropriate policy responses to mitigate constraints and make it easier and more affordable to develop housing. A. GOVERNMENTAL CONSTRAINTS Governmental policies and regulations can result in both positive and negative effects on the availability and production of housing. This section, as required by Government Code Section 65583(a)(5), describes and evaluates City policies and regulations that could potentially constrain the City’s ability to achieve its housing goals. Potential constraints to housing include land use controls (through General Plan policies and zoning regulations), development standards, infrastructure requirements, development impact fees, and development approval processes. While government policies and regulations are intended to serve public objectives and further the public good, the City of Santa Monica recognizes that its actions can potentially constrain the availability and affordability of housing to meet the community’s future needs. The City has implemented several measures, and proposes additional programs, to streamline the approval process and remove barriers to all types of housing throughout Santa Monica as described in this section. 1. Land Use Controls Land use controls, such as use regulations and development standards, have the most immediate impact on the location and construction of new housing. Below is a description of the various plans, documents, and other controls that set forth the goals, policies, and standards that affect both where various types of housing can be located in the City [see Section A(2) below] as well as the development standards and requirements that shape housing developments. Pursuant to Government Code Section 65940.1(a)(1)(B), all documents and standards summarized below can be found on the City’s Community Development Department website. 8.B.h Packet Pg. 623 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-5 a. Land Use and Circulation Element Santa Monica adopted its General Plan Land Use and Circulation Element (LUCE) in 2010 (subsequently updated in 2015 with the Zoning Ordinance update, 2017 with the adoption of the Downtown Community Plan, and 2020 with the revisions to housing process thresholds) which substantially revised the City’s land use policies, goals, and standards in non-residential zones but generally maintained the status quo in the city’s traditional residential neighborhoods. The overarching goal of the LUCE is to create significant new additional housing opportunities within transit-served areas in a manner that provides more affordable options, enhances sustainability, creates complete neighborhoods, and provides easy access to local services. Additionally, the LUCE established policies to preserve the existing pattern of uses for the protection and long-term conservation of established neighborhoods. To accomplish these goals, the LUCE implemented a variety of strategies including, but not limited to the following: • Encourage the creation of new housing in selected transit-accessible areas such as Downtown, Bergamot, and along the City’s boulevards. • Established Activity Center Overlays, which would provide opportunity to promote the creation of mixed-use gathering areas at transportation crossroads on parcels of sufficient size offering goods and services for the neighborhood, convenient transit access, and unique urban spaces. Each Activity Center relied upon cooperation from multiple property owners to consolidate large parcels, an area plan, and a development agreement for each individual project. • Establish a Neighborhood Conservation Strategy to promote the protection of housing in existing neighborhoods, much of which is under rent control, strengthen standards for demolition, and redirect growth to appropriate locations along transit corridors and in the vicinity of the Metro E (formerly Expo) light rail stations. • Establish a maximum base height for ministerial project review and require projects exceeding the base height to incorporate community benefits, such as additional affordable housing. The LUCE established 17 land use designations, as shown in Map E-1, grouped into the following five broad categories: • Neighborhoods • Boulevards • Mixed Use Centers • Employment and Commerce • Community and Public Uses 8.B.h Packet Pg. 624 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-6 Map E-1 LUCE Land Use Designations The LUCE encouraged the expansion of housing opportunities into new areas of the City with residential uses permitted in all but three (Industrial Conservation, Office Campus, and Parks and Open Space) of the 17 land use designations. While the implementing Zoning Ordinance established specific development standards, the LUCE set forth standards for building height, densities (in neighborhood designations), and intensities that establish the outer parameters for zoning. The LUCE does not specify maximum densities for non-neighborhood designations. Instead, density is regulated through building intensities such as Floor Area Ratio (FAR) and height which has provided flexibility to housing developments. In most land use designations, the LUCE also established a tiered system that affords additional building height and density (through traditional means or through an increase in FAR depending on the designation) beyond the base (Tier 1) standards for projects that provide community benefits or that are 100% affordable housing. However, these established outer parameters for Tier 1 projects, which were established in 2010, currently present constraints on the City’s ability to meet its updated housing goals due to low FARs and building heights that were demonstrated to be infeasible in studies conducted in the spring of 2021. Therefore, Housing Element Programs 1.F and 1.J propose to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production citywide. Figure E-1 presents the 17 LUCE land use designations and summarizes the base (Tier 1) height and density/intensity standards and the Tier 2 and 3 standards for projects which provide identified community benefits and/or 100% affordable housing developments. 8.B.h Packet Pg. 625 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-7 Figure E-1 LUCE Land Use Designation – Height and Density/Intensity Parameters LUCE Land Use Designation Max. Building Height and Density/Intensity Tier 1 Tier 2 Tier 3 100% Affordable Housing Neighborhoods Single-Unit Housing No tiers. Height: 28’ – 35’ depending on parcel size, dimensions, and location; Density: 1 du/parcel Low Density Housing No tiers. Height: 30’ – 40’ depending on parcel location; Density: 29 du/acre Medium Density Housing 30’ / 29 du/acre 40’ / 35 du/acre - 40’ / 35 du/acre High Density Housing 30’ / 35 du/acre 45’ / 48 du/acre - 45’ / 48 du/acre Boulevards Mixed Use Boulevard Low 32’ / 1.5 FAR 36’ / 1.5 FAR* 36’ / 1.75 FAR 47’ / 2.0 FAR 47’ / 2.0 FAR Mixed Use Boulevard (100% residential above ground floor) 32’ / 1.5 FAR 39’ / 1.5 FAR* 50’ / 2.25 FAR 55’ / 2.75 FAR 55’ / 2.75 FAR DCP – East Side of Lincoln Blvd: 50’ / 2.25 FAR - DCP – East Side of Lincoln Blvd: 60’ / 2.75 FAR DCP – West Side of Lincoln Blvd: 60’ / 2.75 FAR - DCP – West Side of Lincoln Blvd: 70’ / 3.25 FAR DCP – Wilshire Blvd West of Lincoln Blvd: 50’ / 2.25 FAR - - Mixed Use Boulevard (All Other Projects) 32’ / 1.5 FAR 35’ / 1.5 FAR* 45’ / 2.25 FAR 55’ / 2.75 FAR 55’ / 2.75 FAR DCP – East Side of Lincoln Blvd: 40’ / 1.75 FAR - DCP – East Side of Lincoln Blvd: 55’ / 2.75 FAR DCP – West Side of Lincoln Blvd: 50’ / 2.25 FAR - DCP – West Side of Lincoln Blvd: 55’’ / 3.25 FAR DCP – Wilshire Blvd West of Lincoln Blvd: 40’ / 1.75 FAR - DCP – Wilshire Blvd West of Lincoln Blvd: 40’ / 1.75 FAR General Commercial (Santa Monica Blvd) 32’ / 1.25 FAR 35’ / 1.5 FAR - 35’ / 1.5 FAR General Commercial (Lincoln & Pico Blvds) 32’ / 1.5 FAR 36’ / 1.5 FAR* 36’ / 1.75 FAR 2.0 FAR*** - 40’ / 2.0 FAR Mixed Use Centers Neighborhood Commercial 32’ / 1.5 FAR 1.75 FAR** - - 32’ / 1.75 FAR 40’ / 2.0 FAR (Pico Blvd) Bergamot Transit Village 32’ / 1.75 FAR 39’ / 1.75 FAR* 60’ / 3.0 FAR 75’ / 3.5 FAR 75’ / 3.5 FAR Mixed Use Creative 32’ / 1.5 FAR 36’ / 1.5 FAR* 47’ / 2.0 FAR 57’ / 2.5 FAR 57’ / 2.5 FAR Beach and Oceanfront 32’ / 1.5 FAR 36’ / 1.5 FAR* 47’ / 2.0 FAR 2.25 FAR*** - 47’ / 2.25 FAR Downtown Core Downtown Community Plan establishes development standards 8.B.h Packet Pg. 626 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-8 LUCE Land Use Designation Max. Building Height and Density/Intensity Tier 1 Tier 2 Tier 3 100% Affordable Housing Employment and Commerce Industrial Conservation Residential uses are not permitted Office Campus Residential uses are not permitted Healthcare Mixed-Use No tiers. Hospital Area Specific Plan establishes development standards Community and Public Uses Institutional/Public Lands/ Civic Center No tiers. Civic Center Specific Plan establishes development standards Office Campus Residential uses are not permitted * Height bonus for provision of on-site affordable housing. ** FAR bonus for provision of on-site affordable housing. *** FAR bonus for provision of additional affordable housing. b. Zoning Ordinance In 2015, the City completed a comprehensive update of its Zoning Ordinance to ensure consistency with the new policies, goals, and standards set forth in the LUCE and specified implementation mechanisms for achieving these policy standards. Through the Zoning Ordinance, land use regulations regarding where types of housing can be developed within the City and various development standards such as parcel size, density (for residential zones), number of stories, building height, parcel coverage/FAR, setbacks, and open space are provided for each of the City’s 21 zone district classifications governed by the Zoning Ordinance (as shown in Map E-2). Except in the City’s residential zones where traditional means of density are prescribed, density limitations are controlled through a combination of building height and FAR limitations. The Zoning Ordinance defines a “dwelling unit” as “one or more rooms designed, occupied, or intended for occupancy as separate living quarters, with full cooking, sleeping and bathroom facilities for the exclusive use of a single household” that exceeds 375 square feet. Additionally, the Zoning Ordinance and its associated land use regulations provide additional regulations for affordable units to ensure consistency with market rate unit sizes including standards for minimum unit sizes and unit mix/bedroom counts. Typically, these unit size requirements range from 500 square feet for a studio unit to 850 square feet for a two-bedroom unit. 8.B.h Packet Pg. 627 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-9 Map E-2 Zoning Ordinance Zone District Classifications While the Zoning Ordinance also implements the tiered development concept that was established in the LUCE, between the adoption of the LUCE in 2010 and the Zoning Ordinance update in 2015, Santa Monica’s growth management strategy fluctuated based on a multitude of factors that influenced how the community’s priorities were identified and addressed. This resulted in a reduced tiered system implemented in the Zoning Ordinance that eliminated the Tier 3 option identified in the LUCE for certain land use designations. The changes also removed four of the five “Activity Centers” which were intended to incentivize mixed-use residential development around the City’s transit stations through additional height above Tier 3 limits and FAR increases. As established in the LUCE, Tier 3 projects were voluntary and required a discretionary process and negotiated community benefits, while Activity Centers required cooperation of multiple property owners of large sites, an area plan, and individual development agreements for each project. As a result of the extensive process necessary to achieve Tier 3 or an Activity Center, the City moved toward a more standardized and simplified process through creation of an objective community benefits system. 8.B.h Packet Pg. 628 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-10 Even with the removal of these concepts, the City’s development standards are generous toward housing projects especially in mixed-use and commercial zones where setbacks are minimal (if any) and density limits are not established. The tiered system, with its provision of pre-established community benefits in exchange for increased building heights and densities/intensities, has also proven to be the preferred route for many housing developers to capture some level of additional development potential. However, based on feasibility testing conducted by the City’s economic consultant, current development standards such as low FAR and building height limitations have been identified to be constraints on the City’s ability to meet its updated housing goals. Additionally, other development standards such as minimum/maximum ground floor heights, active ground floor use requirements, daylight plane, and maximum building footprint have been brought to the City’s attention as other possible constraints. In some cases, a developer may apply for a modification or waiver to provide relief from these development requirements, but this adds time and uncertainty to housing project approvals. Therefore, Housing Element Program 1.J proposes to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production citywide. The new development standards for FAR and building height will be higher than existing standards and in some cases, higher than what was initially adopted as part of the original 2010 LUCE. Within the residential zone districts (R2, R3, R4, OPD, OP2, OP3, and OP4), housing development is subject to a density limitation based on a units per acre calculation or a total maximum number of units, whichever is less. Most of the City’s rent control and more naturally occurring “affordable” housing stock is located in these residential districts, and as such, the density limits are intended to prevent the widespread displacement of tenants in existing residential units, particularly rent control units. However, there are a number of residentially zoned sites that are developed as surface parking lots for commercial uses on boulevard fronting parcels. The current density limits, as well as other development regulations (such as access requirements), are an existing barrier to development of these surface parking lot sites. Therefore, Housing Element Program 1.C proposes to remove the density limits for these parcels and revise the Zoning Ordinance to incentivize the development of surface parking lots in residential zones. Figures E-2, E-3, and E-4 present the main development standards that control housing development within the City’s residential, commercial, and other zone districts, respectively. 8.B.h Packet Pg. 629 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-2 Development Standards in Residential Zone Districts Development Standard Residential Zone Districts R1 R2 R3 R4 OP1 OPD OP2 OP3 OP4 Minimum Parcel Size 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 4,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. Maximum Parcel Area per Unit (Density) Tier 1 – Base Standard 1 unit 2,000 (or 4 total units, whichever is less) 1,500 (or 5 total units, whichever is less) 1,250 (or 6 total units, whichever is less) 1 unit 2 units 2,000 1,500 1,250 Tier 2 – With Provisions of Community Benefits - - 1,250 900 - - - - - 100% Affordable Housing Projects - 1,500 1,250 900 - - - - - Maximum Parcel Coverage (% of Parcel Area) Base Standard 45% - 55% depending on number of stories and new/existing development Ground floor: 45% Upper Stories: 90% of allowable ground floor coverage Ground floor: 50% Upper Stories: 90% of allowable ground floor coverage Ground floor: 50% Upper Stories (% of allowable ground floor coverage): 2nd Story: 80% 3rd Story: 60% 4th Story: 50% 50% 50% 50% 50% 50% 100% Affordable Housing Projects - 90% of allowable ground floor 90% of allowable ground floor 50% of allowable ground floor 60% 60% 60% 60% 60% Maximum Building Height (Stories/Feet) Tier 1 – Base Standard 2 / 28’ -32’ depending on parcel size 2 / 30’ 2 / 30’ 3 / 30’ 2 / 20’ – 27’ depending on roof type 2 / 23’ – 30’ depending on roof type 2 / 23’ – 30’ depending on roof type 2 / 23’ – 30’ depending on roof type 3 / 35’ Tier 2 – With Provisions of Community Benefits - - 3 / 40’ 4 / 45’ - - - - - 100% Affordable Housing Projects - No limit / 30’ No limit / 40’ No limit / 45’ 2 No limit / 23’ – 30’ depending on roof type No limit / 23’ – 30’ depending on roof type No limit / 23’ – 30’ depending on roof type No limit / 35’ Minimum Setbacks Front Varies by street 20’ 20’ 20’ 15’ 30’ 20’ 20’ 15’ Sides 10% or 30% aggregate Parcel 50’ or greater: 8’ Parcel less than 50’: 4’ or 16% Parcel 50’ or greater: 8’ Parcel less than 50’: 4’ or 16% Parcel 50’ or greater: 8’ Parcel less than 50’: 4’ or 16% Development/ Parcel Specific Development/ Parcel Specific Development/ Parcel Specific Development/ Parcel Specific Development/ Parcel Specific Rear 15’ 15’ 15’ 15’ 10’ 15’ 15’ 15’ 15’ Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private - 60 sq. ft. 60 sq. ft. 60 sq. ft. - 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. Total - 150 sq. ft. 150 sq. ft. 150 sq. ft. - 150 sq. ft. 150 sq. ft. 150 sq. ft. 100 sq. ft. 8.B.h Packet Pg. 630 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Figure E-3 Development Standards for Commercial Zone Districts Development Standard Commercial Zone Districts MUBL MUB GC (Santa Monica Blvd) GC (Lincoln & Pico Blvds) NC NC (Main St) NC (Ocean Park Blvd & Montana Ave) Minimum Parcel Size 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. Maximum FAR Tier 1 – Base Standard 1.25 1.25 1.0 1.25 1.25 0.75 0.75 Tier 1 – Projects Including On-site Affordable Housing in Compliance with AHPP 1.5 1.5 1.25 1.5 1.5 1.0 1.0 Tier 2 – With Provisions of Community Benefits 1.75 2.25 1.5 1.75 (2.0 if on-site affordable housing provided) - - - 100% Affordable Housing Projects 2.0 2.75 1.5 2.0 1.75; 2.0, on Pico Blvd only 1.25 1.25 Maximum Building Height (Stories/Feet) Tier 1 – Base Standard 2 / 32′ 2 / 32′ 2 / 32′ 2 / 32′ 2 / 32′ 2 / 27′ 2 / 32′ Tier 1 – Projects Including On-site Affordable Housing in Compliance with AHPP 3 / 36′ 3 / 39′ if 100% residential above ground floor, 3/35′ for all other projects - 3 / 36′ 2 / 32′ 2 / 27′ 2 / 32′ Tier 2 – With Provisions of Community Benefits 3 / 36′ 3 / 45′ 2 / 35′ 3 / 32′ (3 / 36′ if on-site affordable housing provided) - - - Tier 2 – With Provisions of Community Benefits and 100% Residential Above the Ground Floor No limit / 36′ No limit / 50′ No limit / 35′ No limit to stories / 32′ (36′ if on-site affordable housing provided) - - - 100% Affordable Housing Projects No limit / 55′ No limit / 55′ No limit / 35′ No limit / 40′ No limit / 32′; 40′ on Pico Blvd only No limit / 32′ No limit / 32′ Minimum Setbacks Interior Side and Rear if Adjacent to Residential District 10’ 10’ 10’ 10’ 10’ 10’ 10’ Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. Total 100 sq. ft. 100 sq. ft. 100 sq. ft.. 100 sq. ft. 100 sq. ft. 100 sq. ft.. 100 sq. ft. 8.B.h Packet Pg. 631 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Figure E-4 Development Standards for Other Zone Districts Development Standard Zone Districts IC OC HMU OF Minimum Parcel Size 15,000 sq. ft. 15,000 sq. ft. 7,500 sq. ft. 5,000 sq. ft. Maximum Density - - - Parcels Along PCH between Santa Monica Pier and the north City limits: Parcels 4,000 sq. ft. or more: 1 dwelling unit/1,500 sq. ft. Parcels less than 4,000 sq. ft.: 1 dwelling unit/parcel if existing, no new dwelling units Maximum FAR Tier 1 – Base Standard 1.0 1.5 1.5 1.5; 0.5 for parcels located along the PCD between the Santa Monica Pier and the north City limits Tier 2 – With Provisions of Community Benefits 1.75 1.75 2.5 2.0 100% Affordable Housing Projects 2.25 - 2.5 2.25 Maximum Parcel Coverage - - - 70; 50 on parcels along the PCH between the Santa Monica Pier and the north City limits Maximum Building Height (Stories/Feet) Tier 1 – Base Standard 2 / 32′ 2 / 32′ 3 / 45′ 2 / 32’ – 30’ depending on roof type and location Tier 1 – Projects Including On-site Affordable Housing in Compliance with AHPP - - - 3 / 36′ Tier 2 – With Provisions of Community Benefits 3 / 45′ 3 / 45′ 5 / 70′ 3/47′ Tier 2 – With Provisions of Community Benefits and 100% Residential Above the Ground Floor - - - No limit / 47′ 100% Affordable Housing Projects No limit / 45′ - No limit / 70′ No limit / 47′ Minimum Setbacks Street Frontage - - - 5’ except for 20’. on PCH between northern City limits and Santa Monica Pier Side - - - Parcel specific Rear - - - 15’ if adjacent to a residential use; 25’ for beach rear setback on parcels over 100’. in depth located along the PCH between the Santa Monica Pier and the north City limits Interior Side and Rear if Adjacent to Residential District 15’ 15’ 15’ - Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private - - 60 sq. ft. 60 sq. ft. Total - - 100 sq. ft.. 100 sq. ft. 8.B.h Packet Pg. 632 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix E | Constraints on Housing E-14 i. Affordable Housing Santa Monica has consistently tried to remove barriers and incentivize 100% affordable housing projects in all of its zone districts citywide through the following methods: • Greater FAR, density, and building height allowances • No limit to the number of stories within the maximum building height • Parking reductions • Ministerial permit processing • No City Planning application fees or development impact fees • Compliance with California Assembly Bill (AB) 1763 (addition of 3 stories or 33’ in height, four incentives/concessions, no parking requirements) Through new Housing Element programs and concepts, such as the Moderate Income Housing Overlay identified in Housing Element Program 2.A, Santa Monica will continue to provide and expand benefits for 100% affordable housing projects throughout the City. ii. Affordable Housing Production Program The City’s Affordable Housing Production Program (AHPP), implemented through Santa Monica Municipal Code (SMMC) Chapter 9.64, requires that residential and mixed-use projects of two or more units contribute to affordable housing production to assist the City in addressing its overall affordable housing needs. Figure E-5 summarizes the options for fulfilling the City’s AHPP requirements through a menu option. However, Housing Element Program 2.C proposes revisions to the City’s AHPP, including re-evaluation of the minimum required percentage of on- site or off-site units, to determine the best means of achieving the City’s housing goals, which may include increasing the threshold for providing on-site units, adding flexibility in meeting goals through an in lieu fee or hybrid option, and increases to the number of units to be produced per project. To the extent Program 2 .C proposes amendments to the AHPP to increase the number of units that must be produced per project to increase the number of affordable units throughout the City, Programs 1.F and 1.J will ensure that the new FARs and building heights for housing projects that comply with the minimum AHPP requirements will be feasible. Figure E-5 Affordable Housing Production Program Options Projects with 2-3 Ownership Units OR 2+ Rental Units Projects with 4-15 Ownership Units Projects with 16 or More Ownership Units On-site Option 5% extremely low income units (option currently unavailable until after February 28, 2022); or 10% very low income units, or 20% low income units, or 100% moderate income units 20% moderate or 20% low or 10% very low income units 25% moderate or 25% low or 15% very low income units Off-site Option Same as on-site option 25% more than required number of on-site units 25% more than required number of on-site units Affordable $36.49/SF for apartments Not Applicable Not Applicable 8.B.h Packet Pg. 633 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-15 Housing Fee (2020) $42.62/SF for condominiums Unit Development Cost: $382,795.00 iii. Community Benefits The purpose of community benefits is to implement LUCE policies that require community benefits in exchange for increased development parameters. As discussed above, for a housing project to receive Tier 2 or 3 increased building heights and/or densities/intensities, the project must provide community benefits as prescribed in SMMC Chapter 9.23 or SMMC Section 9.10.070 for projects located within the Downtown Community Plan area. Community benefits consist of the following: 1. Housing (Increased provision of Affordable Housing and Unit Mix requirements) 2. Transportation Impact Fee 3. Open Space (Additional fee or provision of publicly accessible open space) 4. Transportation Demand Management (Preparation of a Developer TDM trip reduction plan, Transportation Allowance equivalent to 75% the cost of a monthly transit pass, and on-site shared bicycles) While some community benefits require on-site features such as increased affordable units and unit mix requirements (prescribed percentages and ratios of studio, two, and three bedroom units) , others only require increases to development impact fees (an additional 14% applied only to the increase above Tier 1) . While community benefits can add additional requirements and fees to housing projects, they are an elective process (i.e., voluntary Tier 2 or Tier 3 projects) and are offset by increased development potential. Furthermore, Housing Element Program 1.J will be reevaluating and increasing development standards (FAR and building height) in mixed-use and commercial zones to support housing production. The new FARs and building heights for housing projects will be based on feasibility analysis that takes into account development costs inclusive of the requirements for community benefits, local fees, local building code requirements, as well as affordable housing requirements in the City’s AHPP. Additionally, 100% affordable housing projects are deemed to have satisfied the housing community benefit requirement and are not required to provide additional community benefits. iv. Parking Requirements Figure E-6 summarizes Santa Monica’s parking requirements for residential uses throughout the City except for those areas governed by the Bergamot Area Plan (BAP). Single-unit dwellings are required to provide a flat rate of two parking spaces, whereas for other residential uses parking is calculated on a per-bedroom basis and in some cases per bed for certain housing types. 8.B.h Packet Pg. 634 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-6 Parking Requirements for Residential Uses, Excluding the Bergamot Plan Area Residential Use/Facility Citywide (Excluding Parking Overlay Area 1, Downtown Community Plan Area, and Bergamot Area Plan Area) Parking Overlay Area 1 Downtown Community Plan Area (Maximum Parking Allowed) Single-Unit Dwelling 2 spaces per dwelling unit 2 spaces per dwelling unit, which may be tandem 2 spaces per dwelling unit Accessory Dwelling Unit 1 space per dwelling unit 1 space per dwelling unit N/A Junior Accessory Dwelling Unit N/A N/A N/A Multiple-Unit Dwelling Market Rate Units: Guest = 1 space per 5 units Studio, no bedroom = 1 space per unit 1 bedroom = 1.5 spaces per unit 2 or more bedrooms = 2 spaces per unit Deed Restricted Affordable Units: Studio, no bedroom = 0.5 space per unit 1 bedroom = 0.75 spaces per unit 2 or more bedrooms = 1 spaces per unit Market Rate Units: Guest = 1 space per 10 units Studio, no bedroom = 1 space per unit 1 bedroom = 1 space per unit 2 or more bedrooms = 1.5 spaces per unit Deed Restricted Affordable Units: Studio, no bedroom = 0.5 space per unit 1 bedroom = 0.5 spaces per unit 2 or more bedrooms = 1 spaces per unit Market Rate Units: Guest = 1 space per 15 units Studio, no bedroom = 0.5 space per unit 1 bedroom = 0.5 space per unit 2 or more bedrooms = 1 space per unit Deed Restricted Affordable Units: Guest = 1 space per 30 units Studio, no bedroom = 0.25 space per unit 1 bedroom = 0.25 spaces per unit 2 or more bedrooms = 0.5 spaces per unit Senior Citizen Multiple-Unit Dwelling 0.5 space per unit Guest = 1 space per 5 units Low and moderate income units = 0.25 space per unit 0.5 space per unit Guest = 1 space per 6 units Low and moderate income units = 0.25 space per unit 0.5 space per unit Guest = 1 space per 6 units Low and moderate income units = 0.25 space per unit Single-Room Occupancy See Multiple-Unit Dwelling See Multiple-Unit Dwelling See Multiple-Unit Dwelling Group Residential 0.5 space per bed 0.5 space per bed 0.5 space per bed Congregate Housing 1 space per 5 beds 1 space per 5 beds 1 space per 5 beds Senior Group Residential 0.5 space per unit Guest = 1 space per 5 units Deed restricted affordable = .025 space per unit 0.5 space per unit Guest = none required Deed restricted affordable = .025 space per unit 0.5 space per unit Guest = none required Deed restricted affordable = .025 space per unit Elderly and Long-Term Care 0.5 space per bed plus one visitor space per 5 beds 0.2 space per bed 0.2 space per bed Residential Care, General If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds Residential Care, Limited None required other than what is required for existing residence None required other than what is required for existing residence None required other than what is required for existing residence Residential Care, Senior If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence Hospice, General If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence Hospice, Limited None required other than what is required for the existing residence None required other than what is required for the existing residence None required other than what is required for the existing residence Supportive Housing If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence If more than 6 residents = 1 space per 5 beds If less than 6 residents = none other than what is required for the existing residence Transitional Housing None other than what is required for residential type None other than what is required for residential type None other than what is required for residential type Live-Work 1 space per unit plus 1 guest space per unit 1 space per unit plus 1 guest space per unit 1 space per 500 sq.ft. 8.B.h Packet Pg. 635 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element E-17 Realizing the constraint parking can have on housing projects, the City provides the following alternatives to relieve and/or lessen parking requirements for new development: • Reduced parking requirements for deed-restricted affordable housing units • No minimum parking requirements for 100% affordable housing projects located within 1/2 mile of a major transit stop consistent with State density bonus law (AB 1763) • Reduced parking requirements for projects located in close proximity to transit, identified as Parking Overlay Area 1 • Reduced parking requirements for the provisions of car-sharing parking spaces. Parking is reduced by two spaces for every one car-sharing space provided, up to a maximum of 25% of the required parking spaces, not exceed 10 spaces • Allowance for shared parking in nonresidential zone districts for projects within close proximity to each other • Elimination of parking requirements and the need to replace displaced existing parking in conjunction with the construction/establishment of Accessory Dwelling Units and Junior Accessory Dwelling Units • No minimum parking requirements in the Downtown area Additionally, Housing Element Program 1.D proposes to revise minimum parking requirements for housing projects. As for the Downtown area, instead of minimum parking requirements, the numbers provided in Figure E-6 stipulate parking maximums. This regulatory shift from parking minimums to parking maximums has allowed housing providers to right-size their parking needs including the option to provide no parking at all in the City’s Downtown area. Unlike the majority of the City where residential parking requirements are based on bedroom count, residential parking in the BAP is based on unit count. Additionally, the BAP provides both minimum and maximum parking requirements which gives developers the ability to provide the appropriate amount of parking to serve each development. Also unique to the BAP is the concept of requiring less parking per unit when the plan area reaches 5,000 new parking spaces after the plan was adopted, which was in 2013. This eventual reduction will further lessen the constraint parking places on housing projects within the plan area. Figure E-7 summarizes the parking requirements for residential uses in the BAP. Figure E-7 Parking Requirements for Residential Uses in the Bergamot Plan Area Stage of Plan Development Minimum Space Required per Unit Maximum Spaces Permitted per Unit Tier 1 & 2 Tier 3 Tier 1 & 2 Tier 3 At Plan Adoption 1.5, of which at least 1.0 must be reserved 1.5, of which at least 1.0 must be reserved and 0.5 must be shared 2.0, of which no more than 1.5 may be reserved (With voluntary shared parking) 2.0, of which no more than 1.5 may be reserved At 5,000 Net New Spaces 1.0, which may be reserved or shared 1.0, which must be shared 1.5, of which no more than 1.0 may be reserved (With voluntary shared parking) 1.5, of which no more than 0.5 may be reserved v. State Density Bonus State law (California Government Code Section 65915-65918) requires cities and counties to approve density bonuses for housing developments that contain specified percentages of affordable housing units or units restricted to occupancy by seniors. A density bonus is the allocation of development rights that allows a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned. Projects that qualify for a density bonus are also eligible for reduced parking standards and additional concessions or incentives and waivers of development standards. The legislature has 8.B.h Packet Pg. 636 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-18 made frequent changes to State density bonus law over the years, including AB 1763 which significantly increased density bonus provisions for 100% affordable projects and AB 2345 which increased density bonus provisions for housing development projects that are not 100% affordable but qualify for a density bonus. The City’s density bonus law is outlined in SMMC Chapter 9.22, was last updated in 2020, but does not reflect certain recent changes in State law that became effective in 2021. As currently written, Chapter 9.22, applies to projects in the City’s residential districts, and to 100% affordable housing projects located anywhere in the City. When Chapter 9.22 was updated in 2020, the City deferred including provisions for application of the State Density Bonus Law for projects other than 100% affordable projects in the City’s nonresidential districts, which do not implement a maximum density control, pending further study. Nevertheless, in accordance with State law and City Council direction given on June 15, 2021, the City is implementing State density bonus law in all districts for all housing projects. As described in Housing Element Program 2.D, the City will update its density bonus ordinance to be consistent with State law requirements. c. Downtown Community Plan The Downtown Community Plan (DCP), adopted in July 2017, is a specific plan to implement the LUCE goals and policies for the City’s Downtown core. The DCP addresses important issues in the Downtown including, but not limited to, historic preservation, high quality architecture, sensitive urban design, diverse housing opportunities, sustainability, expansion of cultural arts offerings, additional open spaces that support quality of life, walkability, additional office space to meet the needs of creative businesses, and integration with the Metro E light rail stations. Map E-3 Downtown Community Plan Zone District Classifications 8.B.h Packet Pg. 637 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-19 The DCP established six zone district classifications as shown in Map E-3. Similar to the LUCE and Zoning Ordinance, the DCP specifies land use regulations regarding where various types of housing can be developed and various development standards such as parcel size, FAR, building height, setbacks, and open space for the zone districts it governs. The DCP also established a tiered system for developments with housing and community benefits specific to the DCP. These community benefits, as described in SMMC Section 9.10.070, include increased affordable housing, unit mix requirements, Transportation Demand Management plans, and increased fees for transportation impacts, open space, and affordable housing commercial linkage. As with other commercial zone districts within the City, the DCP does not impose density limits, but rather density is controlled through a combination of maximum building heights, FAR limitations, and other massing/siting development standards, which has provided flexibility for housing projects. Additionally, similar to the Zoning Ordinance, minimum dwelling unit sizes and unit mix/bedroom counts are prescribed for affordable units to ensure their consistency with market rate units. Overall, the DCP standards largely allow for the greatest amount of flexibility and incentives for housing developments within the City. Housing projects in the Downtown are given additional FAR and building height as compared to commercial projects. However, development standards such as low FAR and building height limitations have been identified to be constraints on the City’s ability to meet its housing goals. Additionally, development standards such a minimum/maximum ground floor heights, active ground floor commercial use requirements, daylight plane, and maximum building footprint have been brought to the City’s attention as other possible constraints. In general, while these standards can be perceived as onerous for housing developers, they have not precluded the development of housing in the Downtown, as demonstrated by the 20 applications for housing projects in the Downtown over the past 5 years, However, Housing Element Program 1.F proposes to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production in the Downtown area Increases to FAR and building heights for housing projects through Program 1.F will be based on feasibility analysis which has taken into account development costs inclusive of the requirements for community benefits, local fees, local building code requirements, as well as affordable housing requirements in the City’s AHPP. Figure E-8 presents the main developments standards that control residential development within the DCP zone districts. 8.B.h Packet Pg. 638 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-8 Development Standards for Downtown Community Plan Zone Districts Development Standard Downtown Community Plan Zone Districts LT (East) LT (West) NV BC (Promenade) BC (2nd & 4th Streets) TA OT WT Minimum Parcel Size 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. Maximum FAR Tier 1 – Base Standard 1.25 1.25 1.75 1.75 1.75 1.75 1.75 1.5 Tier 1 – With Housing 1.5 1.5 2.25 2.25 2.25 2.25 2.25 1.5 Tier 2 – With Provisions of Community Benefits 1.75 2.25 2.75 2.75 3.0 3.0 2.25 1.75 Tier 2 – With Housing and Provisions of Community Benefits 2.25 2.75 3.5 2.75 3.5 3.5 2.75 2.25 Tier 2 – With Housing for parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core - - - - - - - 2.75 Tier 3 – With Provisions of Community Benefits - - - - - 3.5 - - Tier 3 – With Housing and Provisions of Community Benefits - - - - - 4.0 - - 100% Affordable Housing Projects 2.75 3.25 4.0 3.25 4.0 4.0 3.25 2.75 100% Affordable Housing Projects – Parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core - - - - - - - 3.25 Maximum Building Height Tier 1 – Base Standard 32’ 32’ 32’ 32’ 32’ 32’ 32’ 32’ Tier 1 – Projects Including On-Site Affordable Housing In Compliance with AHPP 39’ 39’ 39’ 39’ 39’ 39’ 39’ 39’ Tier 2 – With Provisions of Community Benefits 40’ 50’ 60’ 60’ 60’ 60’ 50’ 40' Tier 2 – With Housing and Provisions of Community Benefits 50’ 60’ 60’ 60’ 60’ 60’ 50’ 50’ Tier 2 – With Housing for parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core - - - - - - - 60’ Tier 3 – With Provisions of Community Benefits - - - - - 84’ - - Tier 3 – With Housing and Provisions of Community Benefits - - - - - 84’ - - 100% Affordable Housing Projects 60’ 70’ 70’ 70’ 70’ 84’ 60’ 60' Minimum Setbacks Interior Side and Rear if Adjacent to Residential District 10’ 10’ - - - - - 10’ Minimum Open Space (% of Buildable Area) Lot Width of 50’ or Less - - - - - - - - Lot Width between 52- and 150’ 20% 20% 20% - 20% 20% 20% 20% Lot Width greater than 150’ 25% 25% 25% - 25% 25% 25% 25% 8.B.h Packet Pg. 639 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element E-21 d. Bergamot Area Plan The Bergamot Area Plan (BAP), adopted in September 2013, is a specific plan that provides guidance on transitioning former industrial lands of the Bergamot Area into an arts-focused, mixed-use, pedestrian-oriented neighborhood. As shown on Map E-4, the BAP established two main zone district classifications, Bergamot Transit Village (BTV) and Mixed Use Creative (MUC), with two conservation districts, Conservation Arts Center (CAC) and Conservation Creative Sector(CCS). Similar to the LUCE and Zoning Ordinance, the BAP specifies land use regulations regarding where types of housing can be developed and development standards such as FAR, building height, and open space for the zone districts it governs. The BAP also requires a minimum mix of uses for developments within the MUC zone district. As with the DCP and other commercial zone districts, the BAP institutes a tiered system for developments that provide community benefits and controls density through maximum building heights and FAR limitations. Additionally, similar to the Zoning Ordinance, minimum dwelling unit sizes and unit mix/bedroom counts are prescribed for affordable units to ensure their consistency with market rate units. Map E-4 Bergamot Area Plan Zone District Classifications 8.B.h Packet Pg. 640 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-22 However, unique to the BAP, is the concept of flexible standards. While some development standards are mandatory, others are flexible if it is determined that the project promotes design creativity, architectural innovation, and the vitality of the street and sidewalk environment and setting. Mandatory standards include FAR and building height, while flexible standards include mix of uses and open space standards. However, this concept of having flexible standards has led to more discretionary process for projects. Therefore, Housing Element Program 1.E proposes to revise the design standards in the BAP for easier understanding and support of housing production. Since adoption of the BAP, the transit and job-rich Bergamot area has experienced a lack of housing production. Two potential reasons for this may include insufficient Tier 2 development standard increases that would otherwise incentivize housing over commercial development and a general concern about risk and predictability with the development agreement process that is required to access the heightened Tier 3 development standards. Therefore, Housing Element Program 1.J proposes to reevaluate development standards and regulations , both independently and cumulatively, to not only ensure housing projects are feasible, but that but that they also incentivize housing production in the BAP area to meet the City’s housing goals. This program includes, but is not limited to, increasing FAR and building height limits. Figure E-9 presents the main developments standards that control residential development within the BAP zone districts. Figure E-9 Development Standards for Bergamot Area Plan Zone Districts Development Standard Bergamot Area Plan Zone Districts BTV MUC CCS CAC Maximum FAR (Parcel 100,000 SF or Greater / Parcel Less Than 100,000 SF) Tier 1 1.75 / 1.75 (25% FAR bonus for projects providing additional affordable units) 1.5 / 1.5 (25% FAR bonus for projects providing additional affordable units) 1.5 1.0 / 1.0 Tier 2 2.0 / 2.0 (25% FAR bonus for projects providing additional affordable units) 1.7 / 1.7 (25% FAR bonus for projects providing additional affordable units) - 1.0 / 1.5 Tier 3 2.5 / 2.5 2.2 /2.5 - 1.0 / 2.5 Maximum Building Height (Standard / Variation) Tier 1 32’ / 39’ if housing is provided 32’ / 36’ if affordable housing is provided 32’ / 36’ if live/work component is provided 32’ / - Tier 2 – With Provisions of Community Benefits 60’ / - 47’ / - - 60’ / - Tier 3 – With Provisions of 75’ / 86’ with increase ground 57’ / - - 75’ / 86’ with increase ground 8.B.h Packet Pg. 641 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-23 Development Standard Bergamot Area Plan Zone Districts BTV MUC CCS CAC Community Benefits floor-to-floor height floor-to-floor height Minimum Open Space - % of Site Area (Site Greater than 80,000 SF / Site 40,000 SF – 80,000 SF / Site Less than 40,000 SF) Tier 1 20% / 15% / 10% 15% / 12% / 7% 15% - Tier 2 20% / 15% / 10% 15% / 12% / 7% 12% 15% Tier 3 25% / 20% / 15% 20% / 15% / 10% 7% 10% Minimum Required Mix of Uses for Parcels over 120,000 SF - 50% Commercial / 50% Residential (Ratio can vary up to 10%) - - e. Civic Center Specific Plan The Civic Center Specific Plan, adopted in June 2005 with subsequent amendments, is unique in that it established a vision that promotes civic buildings and public open spaces and also provided standards that are more building specific for one of its four special use districts. Currently the plan area is built out and development of additional residential units, which would likely come from the redevelopment of existing buildings, would require an amendment to the plan. However, Housing Element Program 4.A will be removing limitations on where housing can be located within the City, which will enable greater housing opportunities in areas such as the Civic Center Specific Plan areas. Map E-5 presents the Civic Center Specific Plan Special Use Districts. Map E-5 Civic Center Specific Plan Special Zone District 8.B.h Packet Pg. 642 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-24 f. Local Coastal Program The California Coastal Commission (Coastal Commission), in partnership with coastal cities and counties, plans and regulates the use of land, water, and coastal resources in the Coastal Zone. The Coastal Zone in Santa Monica encompasses the mean high tide line as the western border and generally up to 4th Street north of Pico Boulevard and Lincoln Boulevard south of Pico Boulevard. For projects in the Coastal Zone, a Coastal Development Permit (CDP) is required, which is issued by the Coastal Commission unless a local government has a Commission- certified Local Coastal Program (LCP). CDPs are required for development activities broadly defined by the Coastal Act to include (among others) construction of buildings, divisions of land, and activities that change the intensity of use of land or public access to coastal waters. Currently, the City is in the process of certifying an updated LCP to reflect the combined policies, goals, and objectives set forth in the City’s LUCE, Zoning Ordinance, and DCP (all of which were adopted after the City’s existing LCP was partially certified in 1992). In October 2018, the updated Land Use Plan was adopted by the Santa Monica City Council (the first step in the process), but is still awaiting certification from the Coastal Commission. The Implementation Plan, which began in June 2019, is currently in progress. As the City does not yet have a certified LCP, housing projects within the Coastal Zone are required to obtain a CDP from the Coastal Commission before receiving a building permit from the City. While this can add both an additional process and timing constraint on housing projects, the City currently has no control over this process. 2. Zoning for a Variety of Housing Types The City of Santa Monica encourages and facilitates the development of a variety of housing types beyond traditional single-unit and multiple-unit dwellings. These additional housing types include such uses as accessory dwelling units and junior accessory dwelling units, emergency shelters, employee housing, farmworker housing, group residential, low barrier navigation centers, manufactured homes and mobile home parks, residential facilities, single-room occupancy housing, and supportive and transitional housing, as well as accessible housing for the disabled [see Section A(3) below]. Figure E-10 presents a comprehensive matrix of land use regulations compiled from all City implementation plans (Zoning Ordinance, DCP, BAP) that specify where and how each housing type is permitted. Of the 32 zone districts within Santa Monica, all but one (OS) allow for some type of housing. How each housing type is processed is identified with either a “P” for when the use is permitted by right, an “L” for the when use is permitted if it complies with specific limitations such as location or size, or either an “MUP” or “CUP” for when the use requires discretionary approval [see Section 7(e) below]. If the use does not have a process identified it means that the use is not permitted, and if an “L” is coupled with another process it either means that the use must comply with both processes or if separated by a “/”, the use must comply with the second process listed if it cannot abide by the first. 8.B.h Packet Pg. 643 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-25 While Santa Monica has made efforts to remove barriers to all housing types, some land use classifications and zoning implementations might not be consistent with updates to State law that have occurred since the City adopted its comprehensive Zoning Ordinance update in 2015. Therefore, Housing Element Program 2.I states that the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints, including those for persons with disabilities. Additionally, Housing Element Program 4.A proposes to amend the Zoning Ordinance and all specific plans to add multi-unit housing as a permitted use in all non-residential zones where housing is currently prohibited. Housing Element Programs 1.F and 1.J will also be reevaluating other restrictions that prohibit the location of housing, such as limitations on the ground floor. 8.B.h Packet Pg. 644 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-10 Permitted Housing Types by Zone District Residential Uses R1 R2 R3 R4 OP1 OPD OP2 OP3 OP4 LT NV BC (Prom.) BC (2nd/4th) TA OT WT MUBL MUB GC NC BTV MUC CAC CCS IC OC HMU OF CC PL OS RMH Single-Unit Dwelling P P P P P P P P P L(1) L(1) L(1) L(1) L(1) L(1) L(1) P P P P - - - - - - P P - - - - Accessory Dwelling Unit P P P P P P P P P P P P P P P P P P P P P P P P - - P P P - - - Junior Accessory Dwelling Unit P P P P P P P P P P P P P P P P P P P P - - - - - - P P - - - - Duplex MUP P P P - P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P - - - - - - - P - - - - Multiple-Unit Structure - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Senior Citizen Multiple- Unit Residential - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Single-Room Occupancy Housing - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Group Residential - MUP MUP MUP - - MUP MUP MUP MUP MUP, L(3) MUP, L(1) MUP, L(1) MUP MUP MUP MUP MUP MUP MUP P P CUP - - - - MUP L(1) - - - Congregate Housing - P P P - - P P P P MUP, L(3) CUP, L(1) CUP, L(1) MUP MUP MUP P P P P P P CUP - L(1) L(1) P P L(1) - - - Senior Group Housing - P P P - L(2) P P P P MUP, L(3) MUP, L(1) MUP, L(1) MUP, L(1) MUP, L(1) MUP, L(1) P P P P P P CUP - CUP CUP P P L(1) - - - Elderly and Long-Term Care - CUP CUP CUP - - CUP CUP CUP P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - P P P - - - - Emergency Shelters - - CUP CUP - - CUP CUP CUP L(6)/ CUP L(6)/ CUP CUP/ L(1) L(1/6), CUP L(6)/ CUP L(6)/ CUP L(6)/ CUP L(3)/ CUP L(3)/ CUP L(3)/ CUP L(3)/ CUP P P CUP - L(2)/ CUP L(2)/ CUP L(2)/ CUP CUP - P - - Residential Care, General - MUP MUP MUP - - MUP MUP MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - - - - P L(1) - - - Residential Care, Limited P P P P P P P P P P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Residential Care, Senior - L(2)/ MUP L(2)/ MUP L(2)/ MUP L(2) L(2) L(3)/ MUP L(3)/ MUP L(3)/ MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Hospice, General - MUP MUP MUP - MUP MUP MUP MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - - - - - - - - - Hospice, Limited P P P P P P P P P P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P - - - - - Supportive Housing P P P P P P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Transitional Housing P P P P P P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Live-Work - - - - - - - - - L(13) L(3/13) L(1/13) L(13) L(13) L(1/13) L(13) L(14) L(14) L(14) L(14) P P CUP P L(14) CUP L(14) - L(1) - - - Existing Mobile Home Park - - - - - - - - - - - - - - - - - - - - - P - - - - - - - - - - Mobile Home Park - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - P “P” = Permitted by right without discretionary action. “L(#)” = Limited uses, which are permitted by right, provided they comply with specific limitation. “MUP” = Use classifications that are permitted after review and approval of a Minor Use Permit. “CUP” = Use classifications that are permitted after review and approval of a Conditional Use Permit. “-“ = Not permitted 8.B.h Packet Pg. 645 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element E-27 The following analysis details how the City facilitates specific special housing types consistent with State law requirements. a. Accessory Dwelling Units /Junior Accessory Dwelling Units Accessory Dwellings Units (ADUs) play an important role in the production of housing particularly within single-unit residential zoning districts where historically only one unit is permitted per parcel. In recognition of this, the State over the past four years has enacted laws to help spur the production of housing through the development of ADUs. Building off of initial State law passed in 2017 that began removing barriers to ADU production, three new State laws [AB 68, AB 881, and Senate Bill (SB) 13] came into effect on January 1, 2020 that significantly expanded potential ADU development. Statewide, these new laws revised development standards that sometimes limited ADU construction such as eliminating minimum parcel size, establishing larger unit sizes based on bedroom count, reducing minimum side and rear setbacks, and removing on-site parking requirements. In addition, the new laws extended ADUs into multiple-unit residential and mixed-use zoning districts, introduced the new concept of deed restricted Junior Accessory Dwelling Units (JADUs) when in conjunction with single-unit dwellings, and established a strict 60-day processing timeframe and development parameters for ADUs that must be approved ministerially. On September 8, 2020, the City approved an ordinance incorporating these State law requirements into a new ADU/JADU section of the Zoning Ordinance, SMMC Section 9.31.025: Accessory Dwelling Units and Junior Accessory Dwelling Units. Additionally, to further encourage the production of ADUs and JADUs, the City expanded upon the new requirements by exempting all ADUs and JADUs from parcel coverage or floor area calculations and requiring only a ministerial process for review and approval of ADUs and JADUs. Additionally, no development fees are collected for the construction or establishment of ADUs or JADUs. Figure E-11 summarizes the main development standards adopted for an ADU or JADU consistent with State law. Figure E-11 ADU and JADU Development Standards Standard Requirement Minimum Parcel Size No minimum parcel size Maximum Number of Units Single-Unit Development: • One ADU or one JADU is permitted per parcel, except that one JADU and one detached ADU may be permitted on a single parcel • JADUs are only permitted within single-unit zone districts Multi-Unit Development: • Two detached ADUs AND/OR • Any area not used as livable space and that can be brought up to State building standards for dwellings, can be converted to at least one ADU or to a maximum number that equals 25% of the existing unit count. 8.B.h Packet Pg. 646 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-28 Standard Requirement Maximum Size ADUs: • Studio/1 bedroom – 850 square feet • 2+ bedrooms – 1,000 square feet or 1,200 square feet for parcels greater than 10,000 square feet JADUs: • 500 square feet Parcel Coverage / Floor Area Exempt Setbacks Rear and side setbacks – 4 feet Unit Requirements ADUs: • No interior access between the ADU and primary dwelling is permitted • Exterior access separate from the primary dwelling shall be provided • Independent eating and cooking facilities including, but not limited to, a sink, refrigerator, and a stovetop and/or oven shall be provided • Independent sanitation facilities including, but not limited to, a sink, toilet, and a shower and/or bathtub shall be provided JADUs: • Exterior access separate from the primary dwelling shall be provided; however, interior connection is permitted. • An efficiency kitchen that includes a cooking facility with appliances and a food preparation counter and storage cabinets that are of reasonable size in relation to the size of the JADU shall be provided • May provide individual or share sanitation facilities with the primary dwelling Parking • Additional on-site parking is not required for an ADU • Converted parking spaces are not required to be replaced Since implementation of these new State laws, the City has seen an increase in ADU production and interest, averaging 56 ADUs per year between 2018 and 2021. Figure E-12 and Map E-6 below summarize ADU development and location within the City since 2018 when State law began to focus on incentivizing ADUs. Figure E-12 Santa Monica ADU Production Building Permit Issuance Year Permits Issued 2018 23 2019 60 2020 41 2021 102 TOTAL: 226 8.B.h Packet Pg. 647 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-29 Map E-6 ADU Locations While Santa Monica has taken steps beyond what is required by State law to streamline and incentivize the production of ADUs, Housing Element Program 4.C proposes an ADU incentive program for single-unit residential zone districts. The incentive program will allow a property owner the ability to construct an additional ADU if they deed restrict one of the ADUs as a rental unit. This incentive program would help achieve the Housing Element goal of affirmatively furthering fair housing by providing more housing opportunities that are affordable by design within single-unit residential zone districts, which are areas of the city that have largely been unaffordable to many. To further remove barriers and help facilitate ADU production, Housing Element Program 1.G proposes to develop an ADU Accelerator Program to simplify the ADU process by providing prospective ADU developers 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. Additionally, to ensure compliance with State law, Program 1.G also includes language regarding continuing to review State law and updating the City’s locally adopted ordinance as needed. 8.B.h Packet Pg. 648 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-30 b. Emergency Shelters State law [Government Code Section 65583] requires each jurisdiction to identify one or more zoning districts where emergency homeless shelters are allowed without a discretionary permit. Additionally, Government Code Section 65583(a)(4) limits the development standards and locational restrictions that can be applied to emergency shelters. Emergency shelters may only be subject to those development and management standards that apply to residential or commercial development within the same zone except that a local government may apply written, objective standards that include all the following: • The maximum number of beds or persons permitted to be served nightly by the facility; • Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone; • The size and location of exterior and interior onsite waiting and client intake areas; • The provision of onsite management; • The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart; • The length of stay; • Lighting; and • Security during hours that the emergency shelter is in operation. Emergency shelters are defined in the Zoning Ordinance as “a temporary, short-term residence providing housing with minimal supportive services for homeless families or individual persons where occupancy is limited to six months or less, as defined in Section 50801 of the California Health and Safety Code. Medical assistance, counseling, and meals may be provided.” As shown in Figure E-10, emergency shelters are permitted by-right in the BTV, MUC, and PL zone districts with no limitations and by-right up to 55 beds in 13 other mixed- use/commercial zone districts (identified by the L2, L3, and L6 designations) . Additionally, SMMC Section 9.31.130 of the Zoning Ordinance sets forth standards for emergency shelters to ensure they do not adversely impact adjacent parcels or the surrounding neighborhood and that they will be developed in a manner that protects the health, safety, and general welfare of the nearby residents and businesses while providing for the housing needs of a vulnerable segment of the community. The standards include provisions and limitations on lighting, laundry facilities, common facilities, security, outdoor activity, services (including lengths of stay), maximum unit density, and health and safety standards. In terms of density, emergency shelters that are located in residential zone districts, when not developed in an individual dwelling unit format, are not subject to the underlying zone district’s maximum unit density standard, but the number of beds are limited to three times the maximum number of dwelling units which would otherwise be permitted on the site. Temporary shelter is also available to residents for no more than six months with extensions up to 180 days available if the 8.B.h Packet Pg. 649 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-31 shelter operator determines that no alternative housing is available. Additionally, minimum parking requirement for emergency shelters is one space per 10 beds, which is less parking required compared to other similar type of special needs housing. Therefore, the City is in compliance with State law by allowing emergency shelters by-right in at least one zone district and is within the limits of all development and management standards. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. Revisions will also include, but are not limited to, updated parking requirements for Emergency Shelters pursuant to AB 139. i. Capacity for Emergency Shelters Government Code Section 65583(a)(4)(A) requires the Housing Element to demonstrate that the zones where emergency shelters are allowed by-right include sufficient capacity to accommodate the need for emergency shelter identified in the most recent point-in-time count conducted before the start of the planning period. According to the most recent annual point-in-time homeless count performed in 2020 (2021 count cancelled due to COVID-19 restrictions), a total of 907 individuals were counted on the streets, in cars and encampments, and in shelters and institutions within the City. In order to determine the City’s capacity for emergency shelters, properties on the Suitable Sites Inventory (SSI) with development potential to accommodate emergency shelters were evaluated based on size and location to transit and services. According to the SSI, there are 10 parcels within the BTV and MUC zone districts that can accommodate emergency shelters with no limitations on bed count and 118 parcels in the LT, NV, MUBL, MUB, and GC zone districts that limit emergency shelters to 55 bed per parcel. Existing facilities accommodating an approximate range of 16-70 beds have an average parcel size of 20,525 square feet, and of the 128 SSI parcels, 33 parcels would fall within this range. Therefore, it can be concluded that the parcel sizes on the SSI can accommodate emergency shelters of at least 55 beds. In order to quantify the number of beds that can be established on sites with no bed count limit, a 160 square foot per bed size was applied based on both local analysis and County of Los Angeles standards . As shown in Figure E-13, the City has capacity of 3,013 emergency shelter beds. Therefore, Santa Monica has sufficient capacity to accommodate its emergency shelter need based on the 2020 point-in-time count of 907. Figure E-13 Santa Monica Emegency Shelter Capcity Zone District Number of Parcels Total Land Area (SF) Emergency Shelter Bed Capacity LT** 2 43,996 110 NV** 1 22,651 55 MUBL** 13 467,399 715 MUB** 9 273,121 495 8.B.h Packet Pg. 650 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-32 GC** 3 81,457 165 BTV* 1 38,333 240 MUC* 4 197,327 1233 Total: 33 1,124,283 3,013 * No limitation on bed count (160 SF per bed applied) ** 55 bed limit per parcel c. Employee Housing The provisions of Section 17021.5 of the California Health and Safety Code state that employee housing for six or fewer employees must be treated as a single-unit dwelling in regards to land used designation, processing procedure, and fees. As the City does not regulate the occupancy of single-unit dwellings and there are no provisions in the City’s code to restrict employee housing for six or fewer employees, the City complies with this requirement. However, as discussed below in Section A(3), the City’s definition of “household” may present a constraint. Therefore, through Housing Element Program 2.1, regulations impacting special needs housing and residential land uses will be reviewed. d. Farmworker Housing While Santa Monica is highly urbanized and does not have any agricultural industries, according to the 2017 United States Department of Agriculture (USDA) Agricultural Census, there were 1,035 farms with 1,793 total producers within Los Angeles County. Additionally, the California Employment Development Department estimated that the 2020 annual average of agricultural employment was between 1,501 and 5,000 within the County. Therefore, within the region there is a need for farmworker housing, whether that be permanent or seasonal. In order to accommodate this need, Santa Monica provides a variety of housing types, such as employee housing and group residential, that are further discussed in this appendix that would be able to accommodate housing needs for these workers. e. Group Residential Group Residential is defined by the Zoning Ordinance as “shared living quarters without a separate kitchen or bathroom facilities wherein two or more rooms are rented to individuals under separate rental agreements or leases, either written or oral, whether or not an owner, agent or rental manager is in residence, offered for rent for permanent or semi-transient residents for periods generally of at least 30 days.” This land use classification includes rooming and boarding houses, dormitories, fraternities, convents, monasteries, and other types of organizational housing, and private residential clubs but excludes extended stay hotels intended for long-term occupancy and residential facilities. As shown in Figure E-10, group residential is allowed in the same zone districts as multiple-unit structures but typically requires discretionary approval of a Minor or Conditional Use Permit. 8.B.h Packet Pg. 651 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-33 Within the land use category of group residential, the subcategories of Congregate Housing and Senior Group Residential have special standards and are treated separately. Congregate Housing is defined as “a residential facility with shared kitchen facilities, deed- restricted or restricted by an agreement approved by the City for occupancy by low- or moderate-income households, designed for occupancy for periods of six months or longer, providing services that may include meals, housekeeping, and personal care assistance as well as common areas for residents of the facility." Similar to the requirement for transitional housing, the Zoning Ordinance establishes maximum density limitations for beds in congregate housing facilities that is three times the maximum number of dwelling units that would otherwise be permitted, as well as requiring a management plan for the facility. Senior Group Residential is defined as “a residential facility that provides residence for a group of senior citizens as defined in Health and Safety Code Section 1569.2(k) with a central kitchen and dining facilities and a separate bedroom or private living quarters.” To ensure that senior group residential does not “adversely impact adjacent parcels or the surrounding neighborhood and are developed in a manner that protects the health, safety, and general welfare of nearby residents, while providing for the housing needs of an important segment of the community,” the land use must adhere to standards related to location, development, and operation. This includes such standards as maximum number of private living quarters, kitchen and laundry facilities, common area facilities, security, minimum age requirements, minimum private living quarter sizes, and outdoor living area requirements. As shown in Figure E-10, unlike the rest of the group residential land use, both subcategories are permitted by right in all multiple-unit residential and mixed-use districts and only need discretionary approvals in the DCP and employment zone districts. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. f. Low Barrier Navigation Centers AB 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multiple-unit uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a “housing first, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing”. Housing Element Program 5.B proposes to amend the Zoning Ordinance to comply with this new land use requirement. g. Manufactured Homes and Mobile Home Parks State law requires jurisdictions to allow the placement of manufactured homes (also referred to as factory-built homes and modular homes) meeting Federal construction standards and 8.B.h Packet Pg. 652 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-34 manufactured home subdivisions in single-unit neighborhoods. Government Code Sections 65852.3 through 65852.5 require that manufactured homes be permitted in single-unit districts subject to the same land use regulations as conventional homes. In accordance with State law, the City’s Zoning Ordinance includes manufactured housing units within its single-unit dwelling land use classification. This allows manufactured homes to be permitted wherever single-unit dwellings can be located which is in all residential, commercial, and DCP zones districts (single-unit dwellings are not a permitted land use within the BAP area). As manufactured homes are considered single-unit dwellings, they must be compatible in design and appearance with other residential structures in the vicinity and be built on a foundation as well as meet other standards regarding roofing materials, siding, and skirting. Santa Monica defines the “Mobile Home Park” land use as “any area or tract of land where 2 or more lots are rented, leased, or held out for rent or lease, to accommodate mobile homes used for human habitation.” There are only two remaining mobile home parks located within Santa Monica: (1) the Village Trailer Park that consists of 10 units and is located in the MUC zone district and (2) the Mountain View Mobile Home Park. Mountain View, with an approved capacity of 105 units, is located in the specially zoned “Residential Mobile Home Park District” which was established to preserve and protect existing mobile home parks as developments that offer alternative types of residential units and opportunities for affordable housing with special development standards and processes specific to the zone. h. Residential Facilities The City of Santa Monica’s Zoning Ordinance classifies a group home as a “Residential Facility”, which is defined as follows: “Facilities that provide permanent living accommodations and 24-hour primarily non-medical care and supervision for persons in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living. Living accommodations are shared living quarters with or without separate kitchen or bathroom facilities for each room or unit. This classification includes facilities that are operated for profit as well as those operated by public or not- for-profit institutions, including group homes for minors, persons with disabilities, people in recovery from alcohol or drug addictions, and hospice facilities.” Within the Residential Facility classification, the use is divided between five subtypes with the following distinctions: • Residential Care, General: A residential facility licensed by the State of California providing care for more than 6 persons. • Residential Care, Limited: A residential facility licensed by the State of California providing care for 6 or fewer persons. • Residential Care, Seniors: housing arrangement chosen voluntarily by the resident, the 8.B.h Packet Pg. 653 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-35 resident’s guardian, conservator, or other responsible person, where residents are 60 years of age or older and where varying levels of care and supervision are provided as agreed to at the time of admission or determined necessary at subsequent times of reappraisal. This classification includes continuing care retirement communities and life care communities licensed for residential care by the State of California. • Hospice, General: A facility that provides residential living quarters for more than 6 terminally ill persons. • Hospice, Limited: A facility that provides residential living quarters for up to 6 terminally ill persons. California State law mandates that State-licensed group homes of six or fewer residents must be regulated in the same manner as single-unit dwellings for zoning purposes. As shown in Figure E-10, Santa Monica is consistent with State law as Residential Care Limited is permitted in the same zone districts and/or to the same locational standards as single-unit dwellings and in some cases even where single-unit dwellings are not permitted such as in the BTV, MUC, CAC, IC, and OC zone districts. As for Residential Care General, the use is permitted by right in most of the City’s mixed-use and commercial zone districts that allow for larger development, but it is only permitted if certain locational standards are met or if the use obtains approval of either a Minor or Conditional Use Permit in the City’s multiple-unit residential zone districts. As Residential Care Facilities are treated as residential uses, they are subject to the same development standards as any permitted residential use of the same housing type in the district in which they are located. However, Residential Care General is required to be located a minimum distance of 300 feet from any other Residential Facility. Hospice Limited and Hospice General generally follow the same approval process as their Residential Care counterparts, whereas Residential Care Senior follows the approval process based on the number of residents the facility holds. While Santa Monica is in compliance with State law for group homes of six or fewer residents, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure compliance with all State laws and to remove any unintended constraints, such as when and how land uses are permitted. This would include reviewing requirements for group homes with seven or more residents. i. Single-Room Occupancy Housing Single-Room Occupancy (SRO) housing is defined in the City’s Zoning Ordinance as “multiple- unit residential buildings containing housing units that may have kitchen and/or bathroom facilities and are guest rooms or efficiency units as defined by the State Health and Safety Code.” Additionally, SROs are only permitted to be “occupied by no more than two persons,” must be “offered on a monthly rental basis or longer,” and are subject to specific standards that all SROs must abide by as set forth in SMMC Section 9.31.330. These standards include the following: 8.B.h Packet Pg. 654 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-36 • Maximum Occupancy. Each SRO unit shall be designed to accommodate a maximum of two persons. • Minimum Size. An SRO unit must have at least 150 square feet of floor area, excluding closet and bathroom. No individual unit may exceed 375 square feet. • Minimum Width. An SRO of one room shall not be less than 12 feet in width. • Entrances. All SRO units must be independently accessible from a single main entry, excluding emergency and other service support exits. • Bathroom. An SRO unit is not required to but may contain partial or full bathroom facilities. A partial bathroom facility shall have at least a toilet and sink; a full facility shall have a toilet, sink and bathtub, shower or bathtub/shower combination. If a full bathroom facility is not provided, common bathroom facilities shall be provided in accordance with the California Building Code for congregate residences with at least one full bathroom per floor. • Closet. Each SRO unit shall have a separate closet. • Common Area. Four square feet per living unit shall be provided, excluding janitorial storage, laundry facilities and common hallways. At least 200 square feet in area of interior common space provided as a ground floor entry area that provides a central focus for tenant social interaction and meetings. • Tenancy. Tenancy of SRO units shall be for 30 or more days. • Facility Management. An SRO structure with ten or more units shall provide full-time on-site management. An SRO structure with fewer than ten units shall provide a management office on-site. SROs are classified by the City’s Zoning Ordinance under the multiple-unit dwelling land use classification and are therefore permitted wherever and however multiple-unit structures are allowed; however, it is important to note that since 2019, SROs are only permitted if they are 100% affordable housing projects, elderly and long-term care, emergency shelters, residential facilities, supportive housing, or transitional housing. This change was made in response to a threat of over-proliferation of market-rate SROs that would have been inconsistent with the City’s longstanding commitment to providing a range of housing types. This is not a constraint given the wide range of alternatives available. j. Supportive/Transitional Housing Consistent with the State Health and Safety Code, the City defines supportive housing as “housing with no limit on length of stay, that is occupied by the target population, and that is linked to on-site or off-site services that assist the supportive housing resident in retaining the housing, improving their health status, and maximizing their ability to live and, when possible, work in the community.” The target population for supportive housing is defined as persons, including persons with disabilities, and families who are homeless or who are homeless youth. 8.B.h Packet Pg. 655 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-37 While transitional housing is similar to supportive housing, transitional housing units are meant to be for a limited length of stay and “are operated under a program requiring recirculation to another program recipient at some future point in time.” Transitional housing may be designated for homeless or recently homeless individuals or families transitioning to permanent housing, and the classification includes domestic violence shelters. Also, unlike supportive housing, transitional housing has maximum density limitations for beds that is three times the maximum number of dwelling units that would otherwise be permitted and requires a management plan for the facility. In compliance with Government Code Section 65583, both land uses are considered residential uses and are subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. Therefore, supportive and transitional housing are both permitted uses without discretionary action within the City wherever and however single or multiple-unit dwellings are permitted and even in the IC and OC zone districts where most housing is not currently permitted as demonstrated in Figure E-10. Additionally, pursuant to recent changes in State law to Government Code Section 65651 (AB 2162), the City must allow 100% affordable housing projects that include at least 25% or 12 units of supportive housing by right where multiple-unit and mixed-use developments are permitted, including nonresidential zones permitting multi-unit uses. Santa Monica is already in compliance with this requirement as all affordable housing projects of any housing type mix are permitted where multi-unit structures are permitted. Additionally, as shown in Figure E-10, Supportive Housing on its own is a permitted use without discretionary action in all multi-unit zones and commercial zones where multi-unit housing is a permitted use. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. 3. Zoning Regulations and Practices for Persons with Disabilities The City of Santa Monica recognizes the importance of addressing the housing needs of persons with disabilities. This section reviews potential governmental constraints to the development and improvement of housing for persons with disabilities. a. Definition of a Family Local governments may unintentionally restrict access to housing for households failing to qualify as a “family” by the definition specified in a zoning code. Specifically, a restrictive definition of “family” that limits the number of and differentiates between related and unrelated individuals living together may impermissibly limit the development and siting of group homes for persons with disabilities but not housing for families that are similarly sized or situated. 8.B.h Packet Pg. 656 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-38 Santa Monica’s Zoning Ordinances does not include a definition of “family”, nor is family used in any of the City’s land use classification titles. Instead, it defines the persons who occupy a housing unit as a “household”. A household is defined as follows: “One or more persons living together in a single dwelling unit, with access to and use of all common living and eating areas and all common areas and facilities for the preparation and storage of food and who maintain a single mortgage, lease, or rental agreement for all members of the household.” This definition of household does not refer to related or unrelated persons who may occupy a housing unit. Therefore, the zoning regulations do not discriminate against unrelated individuals with disabilities who reside together in a congregate or group living arrangement. However, the provision of requiring a “single mortgage, lease, or rental agreement” may inadvertently be a constraint on housing options for persons with disabilities. Therefore, Housing Element Program 2.I will be evaluating all special needs housing types and all provisions related to housing access for persons with disabilities to ensure consistency with State law and to remove any unintended constraints. b. Definition of Disability With the adoption of the updated Zoning Ordinance in 2015, Santa Monica incorporated the following definition of “disability” consistent with the Federal Fair Housing Act: “Physical or mental impairment that substantially limits one or more of a person’s major life activities or a record of having an impairment, but the term does not include current, illegal use of, or an addiction to, a controlled substance. Current users of illegal controlled substances, persons convicted with illegal manufacture or distribution of a controlled substance, sex offenders, and juvenile offenders are not considered disabled under the Fair Housing Act, by virtue of that status.” The addition of this definition provides consistency with Federal law and brings clarity to land use classifications within the Zoning Ordinance. c. Reasonable Accommodation Both the Federal Fair Housing Act and the California Fair Employment and Housing Act direct local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. One of the primary reasons for a reasonable accommodation procedure is to provide a way – other than through a discretionary entitlement – for residents with disabilities to request a modification from zoning, building, and land use rules, standards, policies, practices, and procedures. 8.B.h Packet Pg. 657 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-39 In the 2015 Zoning Ordinance update, Santa Monica adapted reasonable accommodation procedures (SMMC Chapter 9.49) that specify the applicability of eligible applicants and requests, application requirements, reviewing authority and procedures, findings and decisions, appeal process, and the duration limits of the accommodation. The findings for approval include: 1. That the housing or other property which is the subject of the request for reasonable accommodation will be used by an individual or organization entitled to protection; 2. The request for accommodation is necessary to afford an individual with a disability an equal opportunity to use and enjoy a dwelling or common areas of the premises; 3. The request for accommodation would not impose an undue financial or administrative burden on the City; and 4. The request for accommodation would not require a fundamental alteration in the nature of the City’s land use and zoning or building program. Generally, a reasonable accommodation is a self-certified process consisting of a simplified application with limited information requested by the City in order to approve a request. On average, the City receives two applications per year, and both the findings above and the overall process have never presented a constraint. To date, a reasonable accommodation has never been denied. 4. Building Codes and Code Compliance Building codes regulate the construction of dwellings and apply to plumbing, electrical, and mechanical systems. The purpose of building codes and their enforcement is to protect the public from unsafe conditions associated with faulty construction. a. Building Code Implementations The City of Santa Monica enforces State building code standards for all structures subject to the Code, including the construction and rehabilitation of housing, and has adopted the 2019 California Building Standards Code (based on the 2018 International Building Code), the 2019 California Green Building Standards Code, and the 2019 California Residential Code. For historic resources, the City allows determinations to be made based on the State Historical Building Code. The State Building Standards Code establishes accessibility requirements in Chapters 11A (Housing Accessibility) and 11B (Accessibility to Public Buildings, Public Accommodations, Commercial Buildings and Publicly Funded Housing). Consistent with the Federal Fair Housing Act, the Code requires all multiple-unit structures with four or more units built after March 13, 1991 to provide accessible routes throughout the property, and “adaptable” dwelling units to allow conversion to a fully accessible unit without significant costs and the need to make significant structural modifications. In multiple-unit structures with an elevator, 100% of the units must meet the accessibility requirements, whereas in buildings without an elevator, all of the 8.B.h Packet Pg. 658 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-40 ground floor units must be accessible. The Code requires compliance with the following seven basic design and construction requirements for accessible routes and unit adaptability: 1. Accessible building entrance on an accessible route 2. Accessible and usable public and common-use areas 3. Usable doors by a person in a wheelchair 4. Accessible route into and through the dwelling unit 5. Light switches, electrical outlets, thermostats, etc. in accessible locations 6. Reinforced bathroom walls for later installation of grab bars 7. Usable kitchens and bathrooms for persons in a wheelchair These accessibility requirements pertain to new construction only and not renovations or remodels. However, the Building Code applies a more stringent standard for publicly funded housing requiring 20% of public funds utilized on renovation, structural repair, alterations, or additions to existing multiple-unit buildings be allocated towards removal of architectural barriers. Section 504 of the Federal Rehabilitation Act of 1973 adds additional accessibility requirements for projects receiving federal funds such as the HOME Investment Partnership Program (HOME) or Community Development Block Grants (CDBG). In federally assisted new construction or substantially rehabilitated housing with five or more units, 5% of the units, or at least one unit, must be accessible for persons with mobility disabilities. An additional 2% of the dwelling units, or at least one unit, must be accessible for persons with hearing or visual disabilities. These units must be constructed in accordance with the Uniform Federal Accessibility Standards (UFAS) or a standard that is equivalent or stricter. UFAS generally defines an accessible housing unit as a unit located on an accessible route that can be approached, entered, and used by individuals with disabilities. b. Local Amendments In 2019, along with the adoption of the California Building Code, the City adopted various local amendments. Local amendments provide for higher orders of seismic safety, structural safety, fire safety, occupant safety, and environmental conservation. The local amendments are reasonably necessary given the City’s local climactic, geological and topographical conditions, particularly the specific seismic conditions of Santa Monica with known earthquake faults and the special environmental conditions of the City’s beach community. The majority of the amendments, particularly for the Building Code and Residential Code, were discussed, conceived, and authored by the collaborative group of building officials in Los Angeles County. City staff participated in each of the committees of this collaborative group, and staff determined that the technical suggestions of the collaborative group were applicable to Santa Monica. 8.B.h Packet Pg. 659 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-41 In accordance with local amendments to the California Energy Code, new buildings in Santa Monica have two design pathways: all-electric design and mixed-fuel design. As an incentive to design all-electric buildings, a higher level of energy efficiency is required for mixed-fuel buildings. All-electric buildings are not subject to higher levels of energy efficiency and may be built to the State’s standard design requirements. For residential projects specifically: • New single-family, duplex, and multi-family residential buildings up to three stories: o All-Electric Building: shall be designed to code established by the 2019 CEC. o Mixed-Fuel Building: shall be designed to CalGreen Tier 1 established by the 2019 CEC. CalGreen Tier 1 buildings have additional integrated efficiency and on-site renewable energy sufficient to achieve a Total Energy Design Rating of 10 or less. • New multi-family buildings, four stories and greater: o All new buildings shall have a solar photovoltaic system with a minimum rating of 2 watts per square foot of the building’s footprint. o All-Electric Building: shall be designed to code established by the 2019 CEC. o Mixed-Fuel Building: shall be designed to be 5 percent more efficient than the code established by the 2019 CEC. (The change from the current Energy Reach Code, which requires these buildings to be 10 percent more efficient is the result of a cost-effectiveness study.) In accordance with local amendments to the Green Building Standards Code, major additions to one- and two-unit dwellings shall install a solar photovoltaic system with a minimum total wattage of 1.5 times the square footage of the addition. All major additions to multi-family and non-residential buildings are required to install a solar photovoltaic system with a minimum total wattage of 2 times the square footage of the addition’s footprint. Local amendments to the 2019 California Energy Code and 2019 California Green Building Standards Code are reasonably necessary because of local climatic, geological, topographic, and environmental conditions. The amendments are consistent with the City’s Climate Action & Adaptation Plan and establish requirements to increase energy efficiency and the use of renewable energy, including in particular solar energy, which will reduce demands for local energy and resources, reduce regional pollution, and promote a lower contribution to greenhouse gases. Cost effectiveness studies prepared by the California Statewide Investor Owned Utilities Codes and Standards Program in conjunction with consultants and cities (collectively known as the “Reach Code Team”), demonstrate that the local amendments are cost-effective and do not result in buildings consuming more energy than is permitted by the 2019 California Energy Code. In addition to local amendments to the Building Code, Stata Monica has specific High-Rise Safety Code requirements for buildings over 55 feet in height. In contrast, State law (Health & Safety Code Section 13210(b)) classify buildings over 75 feet in height as high-rise. The local 8.B.h Packet Pg. 660 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-42 high-rise amendment was put in place after the 1994 Northridge earthquake when there were multiple building fires and collapses. With limited resources at the time and since the City is surrounded on all sides by the City of Los Angeles, there were inadequate resources coming into the City in a timely manner. Since the City is very compact in many sections, especially in the downtown area, the purpose of this local amendment to the high-rise definition is to provide an extra level of occupant safety and fire protection in the event of a citywide emergency that might overwhelm the Fire Department’s ability to respond. Essentially, buildings over 55 feet high are required to add a higher level of safety to the building to ensure greater reliance on the built- in safety systems. While this can be a cost constraint on housing projects over 55 feet, it is a necessary safety precaution to ensure protection of human life. c. Compliance and Enforcement Santa Monica’s Building and Safety Division ensures compliance with all State building and accessibility requirements as part of the plan check process. During the construction phase, building inspectors conduct site visits to ensure the project adheres to the approved project plans and required accessibility specifications prior to signing off on the final certificate of occupancy (CofO). Code enforcement can be a potential fair housing concern because code compliance actions may create disproportionate impacts on protected groups such as minority populations. In Santa Monica, however, code enforcement is triggered by complaints, and the City seeks voluntary code compliance through administrative processes that allow for retroactive compliance. In some cases, proactive campaigns are also undertaken when a widespread problem or a specific life/health/safety concern is identified. In conjunction with inspecting and noticing property owners regarding a violation, Code Enforcement personnel inform property owners of assistance provided through the City’s various housing rehabilitation programs. 5. On- and Off-Site Improvements Various City departments implement on- and off-site improvement requirements, including standards for street construction, sidewalks, curbs, gutters, on-street parking and bicycle lanes. Residential development may also necessitate constructing water, sewer, and drainage improvements. All improvements are generally required as conditions of approval and are developer financed. Complying with certain infrastructure improvements may be perceived as a constraint on the provision of housing for all income levels. For infill projects, the SMMC Section 7.04.800 requires the construction of standard improvements that may include repair of defective sidewalks, construction of standard driveways, and maneuvering areas. The Code also requires dedication and improvement of full-street or alley frontages. The City's respective departments may approve variances from City standards based on hardship considerations on a case-by-case basis per City Code. Although infrastructure requirements represent a cost to developing housing, these 8.B.h Packet Pg. 661 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-43 improvement standards are not unreasonable nor do they represent a significant constraint. However, the City recognizes there are issues with infrastructure adequacy in certain areas of the City, including infill areas with aging infrastructure. These infrastructure deficiencies are a recognized constraint for infill development. 6. Entitlement and Development Impact Fees Similar to other cities throughout California, Santa Monica collects various impacts fees, charges, and taxes on new residential development. Charges for such things as entitlement applications or development impact fees are set at rates designed to recover the cost of permit processing and to provide public services to residents as well as to mitigate certain development impacts (e.g., parks and open space and affordable housing). The City annually reassesses its fees to ensure they reflect the actual cost of providing services with most user fees adjusted annually based on the change in the Consumer Price Index (CPI). The City has been active in meeting State requirements of Government Code Section 65940.1(a)(1)(A) to increase transparency and predictability of fees. All entitlement application and development impact fees, as well as building permit and plan check estimates, are posted on the City’s Finance Department website. Figure E-14 and E-15 summarize the City’s adopted entitlement application processing fees and potential development impact fees for new housing developments, respectively. The cost of development impact fees is determined by the type of development or uses proposed, the size of the project (square footage or unit count), and the development tier of a project as described above in Section A(1). When a housing development project requires multiple entitlement applications, the City charges 100% of the cost for the highest application fee and 50% of the cost of associated applications filed concurrently or after the initial filing for the project. It should be noted that while some entitlements are listed in Figure E-14, such as Conditional/Minor Use Permits, Variances, and Modifications, these fees are either not required for typical housing projects within Santa Monica or are self-imposed by a developer. Conditional Use Permits (CUPs) are not required for typical multiple-unit residential projects. CUPs are unusual for residential use classifications in the Zoning Code and a CUP for a residential use has not been requested in the past 10 years. Application fees, including CUPs, are based on cost recovery of services provided (i.e. staff time spent processing the permit), which typically requires significant analysis and development of conditions to mitigate potential impacts (e.g. noise, circulation, loading) on surrounding land uses. Additionally, as discussed below in Section 7, Entitlement and Permit Processing, housing projects in Santa Monica are largely processed ministerially and will continue to be with implementation of Housing Element Program 1.A, which has removed the need for a Development Review Permit. Furthermore, all application fees and development impact fees are waived for 100% affordable housing projects. 8.B.h Packet Pg. 662 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-44 Figure E-14 City Planning Residential Development Application Fees, Fiscal Year 2020-2021 Most planning and construction fees and taxes are due at building permit issuance, but some fees and charges such as the in-lieu AHPP fee may be paid at the end of the construction process (e.g., Certificate of Occupancy). In limited cases, off-site improvements may be required to mitigate project impacts (e.g., street, utility, or sewer capacity improvements), to repair public facilities damaged during project construction (e.g., sidewalk and curb reconstruction or alley repaving), and to protect the public health, safety and general welfare of city residents, businesses, and visitors. Entitlement Application Type Total Fee Amount Administrative Approval: Non-Downtown $7,990.46 Administrative Approval: Downtown – Non-residential Projects Up to 10,000 SF $7,990.46 Administrative Approval: Downtown – Housing Projecting up to 75,000 SF $13,947.51 Architectural Review Board: New Construction $4,563.52 Coastal Zone (Approval in Concept) $190.38 Conditional Use Permit $19,727.12 Deed Restrictions $887.68 Development Review Permit $28,539.79 Final Subdivision Map $1,993.13 Major Modification $5,486.47 Minor Modification $2,027.74 Minor Use Permit $8,065.39 Pre-Submittal Review $3,553.16 Tentative Subdivision Map $9,001.05 Variance $15,120.46 Waiver of Zoning Ordinance $5,486.47 Waiver of Parcel Map $3,042.71 8.B.h Packet Pg. 663 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-45 Figure E-15 Development Impact Fees, Fiscal Year 2020-2021 Transportation Impact Fee Parks and Recreation Development Impact Fee Land Use Adopted Fee Fee Basis Land Use Adopted Fee Fee Basis Area 1 Area 2 Area 3 Residential Residential Single Unit $8,901.19 $9,135.43 $9,135.43 per unit Single Unit $8,584.88 per unit Multi-Unit $3,045.14 $3,864.99 $3,045.60 per unit Multi-Unit (Studio/1 BR) $4,652.20 per unit Non-Residential Multi-Unit (2+ BR) $7,493.22 per unit Retail $24.60 $35.25 $35.25 per SF Non-Residential Office $11.36 $12.65 $12.65 per SF Office/Creative Office $2.60 per SF Medical Office $32.91 $34.90 $34.90 per SF Medical Office/Hospital $1.43 per SF Hospital - $17.22 $17.22 per SF Retail/Auto Sales $1.68 per SF Lodging $4.21 $4.21 $4.21 per SF Hotel $3.50 per SF Industrial $1.40 $1.53 $1.53 per SF Industrial $1.46 per SF Auto Sales Display $1.40 $1.53 $1.53 per SF - - - Cultural Arts Contribution Affordable Housing Commercial Linkage Fee Land Uses Onsite In-Lieu Fee Basis Land Uses Adopted Fee Fee Basis New Residential/ Commercial 2% of $200 1% of $200 per SF Office $12.60 per SF Commercial Tenant Improvement 2% of 50 1% of $50 per SF Creative Office $10.78 per SF Childcare Linkage Fee Medical Office $7.75 per SF Land Use Adopted Fee Fee Basis Hospital $6.91 per SF Residential $156.54 per unit Retail $10.96 per SF Office $7.43 per SF Hotel $3.45 per SF Retail $5.31 per SF Industrial $8.47 per SF Hotel $3.73 per SF Institutional $11.50 per SF Santa Monica’s AHPP allows eligible housing projects of three or fewer units to pay an affordable housing fee in-lieu of providing units on-site or off-site. Calculations resulting in a fractional unit of less than 0.75 can also be met through payment of a unit development cost fee. The unit development cost fee reflects the average cost to the City to develop an affordable housing unit and is adjusted annually based on changes in land and construction costs. Figure E- 16 provides the affordable housing in-lieu fee costs. 8.B.h Packet Pg. 664 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-46 Figure E-16 Affordable Housing In-Lieu Fee, Effective November 1, 2020 Affordable Housing In-Lieu Fees Apartment Developments $36.49 per sq. ft. of entire project Condominium Developments $42.62 per sq. ft. of entire project Unit Development Cost $382,795.00 As a means of assessing the total cost that fees contribute to development in Santa Monica, Figure E-17 provides a breakdown of individual and cumulative costs of City permit fees, charges, and taxes applicable to three typical housing development types: (1) a mixed-use development, (2) a three-unit condominium development, and (3) a single-unit dwelling. As Figure E-17 shows, total development fees are approximately $27,155.75 per unit ($23.04 per square foot) for the mixed-use development, $124,588.59 per unit ($64.66 per square foot) for the three-unit condominium development, and $35,870 ($10.63 per square foot) for the single- unit dwelling. Figure E-17 Development Fees Applicable to Prototypical Residential Development Projects Fees Mixed-Use Development 3-Unit Condo Development Single-Unit Dwelling Zone MUBL R2 R1 Stories 3 2 2 Market Rate 25 units 3 units 1 unit Affordable 3 units 0 units N/A Total Units 28 units 3 units 1 unit Residential Floor Area 24,000 SF 5,780 SF 3,375 SF Ground Floor Commercial 9,000 SF Retail N/A N/A Avg. Unit Size 704 SF per Unit 1,926 SF per unit N/A Tenure Type Rental Ownership Ownership # Parking Spaces 49 spaces 6 spaces 2 spaces Entitlement and Development Impact Fees Administrative Approval $7,990.46 Exempt Exempt Subdivision Map Exempt $10,994.63 Exempt Architectural Review Board: New Construction $4,563.52 $4,563.52 Exempt CEQA analysis Exempt Exempt Exempt Aff. Housing In-lieu Exempt $246,343.603 Exempt Aff. Housing Comm. Linkage $4,393.96 Exempt Exempt Parks & Rec. $146,110.38 $14,986.44 Exempt Transportation Impact Fee $115,085.58 $7,729.98 Exempt Cultural Arts $66,000.00 Exempt Exempt Childcare Linkage $52,173.12 $469.62 Exempt Construction Fees Plan Check $34,353 $11,156 $7,773 Building Permits/ Inspections $41,581 $10,152 $6,203 Water Meter1 $8,429 $8,429 $8,429 Fireline Meter2 $84,292 $26,973 $0 Wastewater Capital Facilities $128,492 $13,767 $ 4,589 8.B.h Packet Pg. 665 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-47 Fees Mixed-Use Development 3-Unit Condo Development Single-Unit Dwelling Other Requirements and Taxes School Facilities Fee $66,900 $15,201 $8,876 Condo Tax $0 $3,000 $0 Total Fees and Taxes $760,361.02 $373,765.79 $35,870 Total Fees/Unit $27,155.75 $124,588.59 - Total Fees/ Sq. Ft. $23.04 $64.66 $10.63 1 Assume 1 inch water meter 2 Assumes 4 inch Fireline meter 3 Only required when a developer choses to not provide an on-site affordable unit In 2021, the average cost to develop an apartment unit in Santa Monica is approximately $735,0001, including construction and land costs. Given that cost, the percentage of cumulative development fees the City imposes on an apartment unit is approximately 3.7% of the construction cost. Additionally, using the mixed-use development prototype above, the cost City fees contribute to an 100% affordable housing project is approximately $364,047 (mixed- use development total minus all entitlement and development impact fees) or $13,001.68 per unit. As of November 2020, with the average cost for the City to develop an affordable housing unit at $382,795.00, it can be assumed that applicable City fees amount to approximately 3.4% of the cost to construct an affordable unit. Similarly, it is estimated that one condominium unit in a three-unit development in Santa Monica costs approximately $1.6 million2 to develop in some areas of the City. Given this cost, the percentage of cumulative development fees the City imposes is approximately 7.8% of the development cost of one condominium unit. However, it should be noted that the main reason City fees are high for the above prototype is because typically developers of three-unit condominium developments elect to pay an affordable housing in-lieu fee. This fee could be avoided if a developer provided an affordable unit on-site, which would lower the total fee amount to $127,422.79 or $42,474.26 per unit, which is 2.6% of the total development cost for one condominium. Therefore, this fee in a self-imposed constraint and the City provides an alternative to not pay it. As for single-unit dwellings, the development cost range is too wide and varied to approximate a realistic cost. However, as detailed in Section E of Appendix B, the average price in 2019 for a single-unit dwelling within Santa Monica was $3,966,251. Given this price, the percentage of cumulative development fees the City imposes is approximately 0.9% of the average single- unit dwelling sales price. Given the percentages that City fees represent of average development and sales prices, combined with the fact that the volume of new housing construction in the last housing cycle exceeds the City’s regional housing need, it can reasonably be concluded that the City’s permit fees and other development charges and taxes do not impose an undue constraint on the 1 From investigation of total development cost for market-rate housing by HR&A in 2021 2 From investigation of total development cost for 3-unit condominium projects by HR&A in 2021 8.B.h Packet Pg. 666 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-48 production of new housing. However, in addition to development standards, Housing Element Programs 1.F and 1.J propose to review all development impact fees applied to housing projects. 7. Entitlement and Permit Processing Housing development in Santa Monica is subject to varying ministerial and discretionary processes depending on such parameters as size, development tier, and land use. Below is a description of typical processes, thresholds, requirements, and timeframes housing projects may encounter. a. Processes and Thresholds New housing developments within Santa Monica are reviewed through one of three processes based on size, use, and location thresholds – Building Permit review, Administrative Approvals, or Development Review Permits. In August 2020, an Interim Zoning Ordinance (IZO) was adopted that temporarily revised the processing thresholds for most housing projects. The intent behind the IZO was to streamline and incentivize housing projects, especially those that are subject to the protections of the Housing Accountability Act (HAA), by making projects that were once discretionary now ministerial. This has had the effect of shortening project approval time as well as allowing for housing projects to be exempt from the environmental review process mandated by the California Environmental Quality Act (CEQA). Housing Element Program 1.A proposes to make these interim process thresholds permanent and to expand the streamlining applicability to housing projects that are granted deviation from certain zoning ordinance objective standards through the minor modification process. Figure E-18 and E-19 summarize the IZO thresholds and typical processes for housing projects within the City, respectively. With these IZO thresholds, the vast majority of housing projects fall into a ministerial (by-right) process which alleviates the processing time and discretionary review barriers that provide constraints for housing production in Santa Monica. Figure E-18 Entitlement Application Thresholds Review Process Entitlement Development Thresholds Ministerial Building Permit Review Only • Projects in residential zone districts • Single-Unit Dwellings Administrative Approval • Projects more than 1,000 sq. ft. in nonresidential zone districts • All 100% affordable housing projects • Any project that meets the definition of “housing development project” under the HAA, up to Tier 2 maximum limits and meets all objective standards* Discretionary Development Review Permit Projects that exceed: • Tier 2 maximum limits in the DCP and BAP • Tier 1 maximum limits for projects that do not meet the definition of “housing development project” under the HAA or do not meet all 8.B.h Packet Pg. 667 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-49 objective standards* • 10,000 sq. ft of floor area located in Residential Zone Districts • 7,500 sq. ft. of floor area in the NC and OF Zone Districts • 15,000 sq. ft. of floor area located in Nonresidential Zone Districts (Not including NC and OF) • 30,000 sq. ft. of floor area in projects containing no more than 15% commercial floor area located in Nonresidential Zone Districts (Not including NC and OF) • 7,500 sq. ft. feet of floor area located in the Pico Neighborhood Area * The Housing Accountability Act defines a “housing development project” as a project that is either (1) residential units only, (2) a mixed-use development consisting of residential and nonresidential uses with at least two-thirds of the square footage designated for residential use, or (3) transitional or supportive housing. Figure E-19 Housing Development Project Processes Step in Entitlement Process Building Permit Review Only Administrative Approval Development Review Permit Application Submittal X X X ARB Preliminary Review X (DCP only) X Staff Administrative Review and Approval X Planning Commission Review and Approval X ARB Formal Review and Approval X X X Plan Check / Building Permit Approval X X X b. Ministerial Approvals Housing projects that require either an Administrative Approval or only a building permit are processed ministerially for conformance with objective development standards with no discretion exercised by the Community Development Director, Planning Commission, or City Council, although certain projects are required to receive design review approval by the Architectural Review Board (ARB) [see Section 7(d) below]. Below is a description of these processes. i. Administrative Approvals The Administrative Approval (AA) entitlement is intended to allow for the approval of projects which conform to the standards established for the applicable zone district in which the project is located and do not require discretionary review or approval by the Director, Planning Commission, or City Council. AAs provide for an administrative review and assessment of the proposed development project in light of explicit standards which have been designed to ensure that the completed project will be in harmony with existing or potential development in the surrounding area consistent with the goals, objectives, and policies of the LUCE. Generally, the AA process consists of the following steps: 1. Application submittal 2. ARB preliminary review for Downtown projects only 8.B.h Packet Pg. 668 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-50 3. Staff review and approval 4. ARB review and approval 5. Plan Check/Building Permit approval For an AA to be issued, only approval from the City Planning, Mobility, and Resource Recovery and Recycling Divisions are required, and the following findings must be made in the affirmative: 1. The proposed development conforms precisely to the development standards for the area and the Santa Monica Municipal Code and General Plan. 2. The proposed development does not require discretionary review or approval as outlined in the Municipal Code. The typical processing time for an AA is approximately three months, not including building permit or ARB review and approval. This timeframe coupled with the lack of discretionary review does not present a constraint on housing development projects. The lack of discretionary review also means that AA projects cannot be appealed. ii. Building Permit Only Projects Projects that only require building permit approval consist of single-unit and multiple-unit dwellings in residential districts. However, ARB review is required for all multiple-unit structures and in limited cases, for single-unit dwellings. Building permit review time varies based on project type, but due to the lack of discretionary approval these projects are not constrained by the building permit process. Building permit projects also cannot be appealed. c. Discretionary Approval Housing developments that fall within the discretionary category for processing are required to obtain approval of a Development Review Permit (DRP). Below is a description of the DRP process and requirements. i. Development Review Permit A DRP is intended to allow for the construction of certain projects provided that the building design, siting, and use are compatible with the site and neighborhood, and the project does not result in an adverse impact on the surrounding area. DRPs are reviewed and approved by the Planning Commission, and as part of the review, consideration is given to the location, size, massing, and placement of structures on a site as well as to the location of proposed uses within a project. A DRP review also consists of an evaluation of a project’s compliance with the development standards of the Zoning Ordinance, and approval of a DRP takes into account the potential impacts of a project, as evaluated under the aforementioned aspects of review, and weighs it against the public need for benefits derived from the project. 8.B.h Packet Pg. 669 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-51 Generally, the current DRP process consists of the following steps, subject to compliance with SB 330 limitations on number of hearings: 1. Application submittal 2. ARB preliminary review 3. Planning Commission review and approval 4. ARB review and approval 5. Plan check/Building permit approval A DRP will only be granted if the Planning Commission determines that the following findings of fact can be made in support of the project as submitted or modified. The inability to make one of the following required findings is grounds for denial of an application. 1. The physical location, size, massing, setbacks, pedestrian orientation, and placement of proposed structures on the site and the location of proposed uses within the project are consistent with applicable standards and are both compatible and relate harmoniously to surrounding sites and neighborhoods; 2. The rights-of-way can accommodate autos, bicycles, pedestrians, and multi-modal transportation methods, including adequate parking and access; 3. The health and safety services (police, fire etc.) and public infrastructure (e.g., utilities) are sufficient to accommodate the new development; 4. The project is generally consistent with the Municipal Code, General Plan, and any applicable Specific Plan; 5. Based on environmental review, the proposed project has no potentially significant environmental impacts or any potentially significant environmental impacts have been reduced to less than significant levels because of mitigation measures incorporated in the project or a Statement of Overriding Considerations has been adopted; 6. The project promotes the general welfare of the community; 7. The project has no unacceptable adverse effects on public health or safety; and 8. The project provides Community Benefits consistent with SMMC Chapter 9.23. In granting a DRP, the Planning Commission (or the City Council if appealed) must make findings that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or in such modifications thereof, as may be deemed necessary to protect the public health, safety, and general welfare and secure the objectives of the LUCE and the Zoning Ordinance. They may also impose any other conditions as deemed necessary to achieve these purposes and to support the findings for approval. The typical time to process a DRP takes between six to nine months not including building permit or ARB review and approval. Given the discretionary process of DRPs, the lack of predictably 8.B.h Packet Pg. 670 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-52 and timing can be a constraint on housing production. Additionally, DRP approvals can also be appealed which results in a project having an additional public hearing before a higher decision- making body (City Council) adding more time and uncertainty to the overall process. However, with the IZO thresholds in place and the intent to make them permanent through Housing Element Program 1.A, DRPs for housing projects are only required in very limited circumstances when a projects is greater than 75,000 square feet in the Downtown Community Plan area. Additionally, it should be noted that if a project is compliant with the Housing Accountability Act as described further below, the City is unable to deny a housing project. The DRP process also triggers environmental review requirements under CEQA. In the past, many housing projects were subject to a rigorous environmental review process (such as preparation of an Environmental Impact Report) that could take up to 2 years or more. However, with passage of new CEQA legislation in recent years, most housing projects in the City are determined to be CEQA exempt. d. Architectural Review Board The Architectural Review Board’s (ARB) role in the development of housing is to preserve existing areas of natural beauty and cultural importance, and to assure that buildings, structures, signs, or other developments are in good taste, good design, harmonious with surrounding developments and in general contribute to the preservation of Santa Monica’s reputation as a place of beauty, spaciousness, and quality. The ARB’s purview relative to housing production is over all new multiple-unit and mixed-use developments within the City and only single-unit dwellings if they are located on sloped parcels. Currently, for housing projects in residential zone districts that only require a building permit or for housing developments that only require an AA, the ARB’s review and approval happens either before the building permit process or after the AA is approved. When it comes to housing development projects that require DRPs, in addition to the formal ARB review and approval after the entitlement is approved, a preliminary review takes place prior to the discretionary public hearing in order to provide initial design feedback that can be considered by the Planning Commission. This preliminary review also serves to provide the project applicant feedback on their design as the project advances through the entitlement process. In order for the ARB to approve a project, the following findings must be made: 1. The plan for the proposed building or structure is expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity, and individuality. 2. The proposed building or structure is not of inferior quality such as to cause the nature of the local neighborhood or environment to materially depreciate in appearance and value. 3. The proposed design of the building or structure is compatible with developments on land in the general area. 8.B.h Packet Pg. 671 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-53 4. The proposed development conforms to the effective guidelines and standards adopted pursuant to Chapter 9.55 – Architectural Review Board, and all other applicable ordinances insofar as the location and appearance of the buildings and structures are involved. Projects that are subject to ARB review are typically approved on the first or second round of review which can take approximately six weeks to three months. The City does not prohibit applicants from submitting an application for a building permit prior to obtaining ARB approval, but there is risk that the ARB process may result in changes to the building permit application. While good design is a priority to the City, the ARB process can add a constraint on housing projects as it adds a discretionary process to otherwise ministerial projects or another level or review to projects that are already going through one discretionary process. ARB approvals can also be appealed which results in a project having to go to an additional public hearing at a higher decision-making body (Planning Commission) adding more time and uncertainty to the overall process. Additionally, while the design review process focuses only on project design and cannot be used to reduce density or deny a housing project, the approval findings can be perceived as not objective. To help remove barriers to some housing projects, the City has made recent revisions to staff- level ARB review and approval thresholds. Projects such as exterior remodels and the addition of new housing units in the rear of the parcel can now be reviewed and approved by staff. However, Housing Element Program 1.B stipulates adoption of additional streamlining efforts to expedite ARB review for housing projects. This includes expansions to the staff-level approvals, shifting the design review process to occur before or be concurrent with entitlement review, placing time and hearing limits on projects, review and establish mechanisms to promote approval certainty, and developing objective design standards. Together, these efforts will help remove constraints on housing projects by reducing processing time and will bring increased certainty for housing providers. e. Use Permits and Other Processes Additional processes are described below that some residential land use types may need to adhere to. i. Conditional and Minor Use Permits As shown in Figure E-10, the only kinds of residential use classifications that require approval of a Conditional Use Permit (CUP) are elderly and long-term care facilities and emergency shelters. Residential use classifications that require approval of a Minor Use Permit (MUP) in some zones are group residential, residential care general, residential care senior, and hospice general. These uses are not typical multiple-unit residential uses in that they typically consist of shared living quarters and provide care for persons in need of personal services, supervision, 8.B.h Packet Pg. 672 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-54 protection, or assistance for sustaining the activities of daily living. These use permits and the processes they require are to help ensure that the uses being proposed are consistent with the purposes of the zone district in which they are located and that special consideration is given to the design, location, and operation of the use in a manner that will not interfere with the use and enjoyment of surrounding properties. Both use permits are required to be reviewed by a decision-making body (Planning Commission for a CUP and the Community Development Director for a MUP) and can only be granted if the following findings can be made in the affirmative: 1. The proposed use is conditionally allowed within the applicable Zoning District and complies with all other applicable provisions of the Zoning Ordinance and all other titles of the Municipal Code. 2. The proposed use is consistent with the General Plan and any applicable specific plan. 3. The subject parcel is physically suitable for the type of land use being proposed. 4. The proposed use is compatible with any of the land uses presently on the subject parcel if the land uses are to remain. 5. The proposed use is compatible with existing and permissible land uses within the District and the general area in which the proposed use is to be located which may include but not be limited to size, intensity, hours of operation, number of employees, or the nature of the operation. 6. The physical location or placement of the use on the site is compatible with and relates harmoniously to the surrounding neighborhood. 7. Based on environmental review, the proposed project has no potentially significant environmental impacts or any potentially significant environmental impacts have been reduced to less than significant levels because of mitigation measures incorporated in the project or a Statement of Overriding Considerations has been adopted. 8. The proposed use and related project features would not be detrimental to the public interest, health, safety, convenience, or general welfare. In granting a CUP or MUP, the decision-making body shall require that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or in such modifications thereof, as may be deemed necessary to protect the public health, safety, and general welfare and secure the objectives of the General Plan and the Zoning Ordinance. The decision-making body may also impose any other conditions as may be deemed necessary to achieve these purposes and to support the findings of approval. Typically, a CUP or MUP is processed concurrently with other associated entitlements that are being proposed but on their own can take approximately three months to process. However, use permit approvals can be appealed which results in a project having to go to an additional 8.B.h Packet Pg. 673 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-55 public hearing at a higher decision-making body (City Council for CUP appeals and Planning Commission for MUP appeals) adding more time and uncertainty to the overall process. These timeframes can add a constraint on certain types of housing that require a use permit, but as shown in Figure E-10, the vast majority of residential land uses are permitted by right and therefore, would not be required to go through any of these processes. However, through Housing Element Program 2.I, the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. ii. Subdivision Maps For some housing projects, such as condominiums or mixed-use developments that have commercial and residential components, developers may choose to subdivide the airspace rights of individual units or uses. For example, this typically happens when a housing developer wants to develop for-sale housing units. Additionally, a developer may also choose to process a subdivision map in order to vest current development standards at time of application. The process is conducted in two steps: a Tentative Map that is approved by the Planning Commission and a Final Map that is approved by City Council. The Tentative Map may be denied by the Planning Commission on any of the grounds provided by City ordinances or the California Subdivision Map Act. The Planning Commission may deny approval of the Tentative Map if it makes any of the following findings: 1. The proposed map is not consistent with applicable general and specific plans as specified in Government Code Section 65451. 2. The design or improvement of the proposed subdivision is not consistent with applicable general and specific plans. 3. The site is not physically suitable for the type of development. 4. The site is not physically suitable for the proposed density of development. 5. The design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat. 6. The design of the subdivision or the type of improvement is likely to cause serious public health problems. 7. The design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements for access or for use will be provided, and that these will be substantially equivalent to ones previous acquired by the public. This subsection shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or 8.B.h Packet Pg. 674 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-56 use of property within the proposed subdivision. 8. The proposed subdivision is inconsistent with any ordinance or law of the City of Santa Monica. The subdivision process can add a time constraint on a housing project, but a subdivision map is only a requirement if the developer is selecting to develop for-sale units, wants to divide the uses within a building for financing reasons, or wants to vest development standards.. While the processing time for a subdivision map is approximately 50 days, the approval can also be appealed which results in a project having to go to an additional public hearing at a higher decision-making body (City Council). This possibility adds more time and uncertainty to the overall process. However, the requirements of the Subdivision Map Act cannot be waived or amended by local ordinance when a subdivision of airspace or land is a part of the proposed project. f. State Law Existing and new State laws have an impact on housing developments and how they are processed. Below is a description of three pertinent laws. i. Senate Bill 330 Senate Bill (SB) 330, “The Housing Crisis Act of 2019”, established a statewide housing emergency to be in effect until January 1, 2025 (“housing emergency period”). During the housing emergency period, the City of Santa Monica, as an urban area, is generally prohibited from enacting any development policy, standard, or condition that would have the effect of the following: 1. Changing the land use designation or zoning to a less intensive use or reducing the intensity of land use within an existing zoning district below what was allowed on January 1, 2018; 2. Imposing or enforcing a moratorium on housing development; 3. Imposing or enforcing new non-objective design standards established on or after January 1, 2020; or 4. Establishing or implementing certain limits on the number of permits issued for housing development projects or the population of Santa Monica. SB 330 also limits the demolition of existing housing units in conjunction with a housing development project, as that term is defined for purposes of SB 330, unless replacement units are provided and only allows the demolition of affordable, rent-controlled, or other protected units if certain tenant protections are met. 8.B.h Packet Pg. 675 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-57 Additionally, new specific requirements and limitations on development application procedures have been established by SB 330. Housing developers may now submit a “preliminary application” for a housing development project that requires a specified subset of information prior to providing a formal application. Submittal of the preliminary application secures the applicable development standards and fees adopted at that time. The project is considered vested unless the project changes substantially or no formal entitlement application is filed within 180 days. SB 330 also limits the processing time of housing development projects to 60 or 90 days depending on environmental review requirements and limits the number of public hearings to no more than five including Planning Commission, Architectural Review Board, and City Council. To facilitate this process, Santa Monica has developed a preliminary application form consistent with SB 330. ii. Senate Bill 35 Senate Bill (SB) 35, passed in 2017, requires jurisdictions that have not approved enough housing projects to meet their Regional Housing Needs Allocation (RHNA) to provide a streamlined, ministerial entitlement process for housing developments that incorporate affordable housing. Pursuant to SB 35, if a jurisdiction has not approved enough market rate or affordable housing units to meet its RHNA, review and approval of proposed projects with at least 10% affordability or 50% affordability must be based on objective standards and cannot be based on subjective design guidelines, respectively. However, to be eligible, projects must also meet a long list of other criteria including prevailing wage requirements for projects over 11 units. In order for applicants to take advantage of SB 35, per Government Code Section 65913.4 (10)(b)(1)(a)(et seq.), they need to submit a Notice of Intent, and jurisdictions need to give Native American tribes an opportunity for consultation. The City is currently not subject to SB 35 under the 5th Cycle Housing Element reporting period (2013-2021) because the City meet its RHNA targets. Nevertheless, the City will be undertaking the development of objective design standards and written procedures for implementation of SB 35’s streamlined review should the City become subject to SB 35 in the coming 6th Cycle Housing Element reporting period (2021-2029) as part of Housing Element Programs 1.A and 1.B. It should also be noted that the City has enacted an interim ministerial approval process for nearly all housing projects that meet objective standards of the Zoning Ordinance, and Housing Element Program 1.A proposes to make those interim process thresholds permanent. iii. Housing Accountability Act The Housing Accountability Act (Government Code Section 65589.5) ( HAA) is a State law that restricts the City's ability to deny, reduce the density of, or make infeasible any housing development project that complies with objective general plan, zoning, and subdivision standards and criteria (collectively, "Objective Standards") in effect at the time that the housing development's application is determined to be complete. The HAA has been in effect since 1982 and has undergone several amendments to further reinforce the state legislature's intent to 8.B.h Packet Pg. 676 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-58 increase the supply of residential housing stock. The most recent amendments went into effect on September 25, 2020. In essence, the HAA precludes the City from denying or imposing any conditions upon any housing project (including residential units only or mixed-use projects with at least two-thirds of square footage designated for residential use) unless specific findings are made. However, the HAA does not preclude the City from exercising its discretion and imposing design conditions as part of its review as long as any such conditions does not have the effect of reducing the number of residential units and/or the residential density of this mixed-use project. The City reviews all housing development projects that meet objective LUCE, zoning, and subdivision standards and criteria in accordance with the limitations set forth in the HAA. As discussed above, the City expanded its ministerial processing thresholds for housing development projects to now include all Tier 2 projects that meet the definition of “housing development project” under the HAA and all Objective Standards. This expansion was to not only acknowledge that the HAA limits the ability to deny or reduce the density of such housing development projects but, also was a way to further streamline the vast majority of new housing projects in the City. In addition, Housing Element Program 1 A will expand this streamlining to projects that seek and are granted deviation from certain objective standards through the ministerial Minor Modification process. 8. Local Measures, Propositions, Rent Control Law, and Ordinances The following section focuses on key policies in Santa Monica which serve to promote the production and preservation of housing for all residents, many of which have been in place during prior Housing Elements cycle. As evidenced by the robust housing development the City has seen in recent years, these policies are not impeding housing production and should not prevent the City from achieving its quantitative housing goals. a. Santa Monica City Charter Section 615 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. The 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. 8.B.h Packet Pg. 677 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-59 Housing Element Programs 1.F and 1.J propose 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. b. Rent Control Santa Monica Rent Control was adopted by the voters in April 1979 in response to a shortage of housing units, low vacancy rates, and rapidly rising rents. The law was intended to alleviate the housing shortage and to ensure that owners received no more than a fair return. Regulations were adopted by the Rent Control Board to implement and enforce the Rent Control Law. Changes to the City Charter can only be made by the voters, whereas changes to the implementing Regulations are made by the Board. The City’s Rent Control Law does the following: • Controls the amount that may be charged for a rental unit during a tenancy and provides remedies for the collection of excess rent. • Determines the amenities and services that are included as part of the rent and provides remedies for removal or reduction of those amenities. • Limits the reasons why tenants may be evicted. • Limits removal of controlled units from rental market. The following units are covered under the Law: • Most residential rental buildings in the City constructed prior to April 10, 1979 and certain units constructed after that date (e.g., those on properties on which a rent- controlled building stood within the last five years) are covered by Rent Control. • In addition to apartment buildings, Rent Control also applies to some single-unit dwellings and condominiums used as rentals. • Duplexes and triplexes where one unit is occupied by the owner are eligible for an exemption from rent control. The services of the Rent Control Agency are financed by a per unit annual registration fee charged to owners of controlled rental units. Owners who are in compliance with the law may pass through half of the fee to the tenant(s) on a monthly basis. The Rent Control Board provides waivers of Rent Control registration fees to units occupied by their owners, subsidized by HUD (Section 8 or HOME program), or occupied by low-income tenants who are at least 62 years old or who are disabled. There are also fee waivers for condominiums and single-unit dwellings on 8.B.h Packet Pg. 678 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-60 which rent restrictions have been lifted pursuant to the Costa-Hawkins’ Rental Housing Act and in mobile home parks for units where tenants have signed long-term leases. i. Vacancy Decontrol The Costa-Hawkins Rental Housing Act, passed by the State Legislature in 1995, has had a significant impact on local rent affordability. Under this State law, a unit’s rent is decontrolled at the end of a tenancy. The owner can set a new rent for the next tenancy which is then recontrolled using the new rent as the base leading some to characterize Costa- Hawkins as a system of “vacancy decontrol-recontrol.” The following highlights some of the major effects Costa Hawkins’s has had on the Santa Monica rental market during its 22 years of implementation (1999- 2020)3: • Since the passage of Costa-Hawkins, nearly 20,000 controlled units have received vacancy increases, representing 73% of the City’s total rent-controlled housing stock. Market-rate rents are on average roughly double that of long- term controlled rents. • Median rents for decontrolled-recontrolled apartments have gone up by well over 200% between 1999-2020 • 84% of Santa Monica’s rental units that have now been re-rented at least once were affordable to low income households (<80% AMI) prior to Costa Hawkins with 73% of the rental stock decontrolled-recontrolled as of 2020 due to tenant turnover. Even moderate-income households (<120% AMI) are challenged to afford the majority of rental housing in the community. The impact of this increase in rents on lower income households is significant. For example, many young people earning entry-level pay will be unable to afford to live in Santa Monica, and those living on fixed incomes—principally seniors and the disabled—will likely be unable to continue to live here if they lose their long-term rent-controlled housing. As passed by Santa Monica voters, the Rent Control Law provides Just Cause Eviction protections to help protect existing tenants in rent-controlled housing from unfair evictions. The voters expanded these protections in 2010 through Measure RR to most residential tenants regardless of rent control status. The City Council has also enacted Tenant Anti-Harassment laws to protect all renters in the city. ii. Just Cause Eviction Santa Monica’s Rent Control Law establishes “Just Cause Eviction” provisions and defines procedures that a property owner must follow to lawfully evict a tenant. These local provisions 3 Santa Monica Rent Control Board, 2020 Annual Report, March 2021 8.B.h Packet Pg. 679 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-61 are in addition to State regulations on landlord and tenant rights and responsibilities. The Rent Control Law identifies the following permissible grounds for eviction: • Fault-Based Evictions o Nonpayment of rent o Materially and substantially breaching the lease o Causing or permitting a substantial nuisance or damage to the unit o Being convicted of using the unit for an illegal purpose o Refusing to renew or extend the lease on the same terms as the original lease when lawfully asked to do so by the landlord o Refusing to grant the landlord reasonable access to the unit to make necessary or agreed-upon repairs or improvements, or show the property for sale o Subletting in violation of the lease • No Fault Evictions o The landlord seeks possession of a unit in good faith for use and occupancy by herself or himself, or her or his children, parents, grandparents, brother, sister, father-in-law, mother-in-law, son-in-law, or daughter-in-law o The landlord seeks to recover possession to demolish or otherwise remove the controlled rental unit from rental residential housing use after having obtained all proper permits from the City of Santa Monica. o The landlord seeks to recover possession of the unit to remove the rental unit permanently from rental housing use pursuant to the Ellis Act enacted by the State Legislature. In November 2010, Santa Monica voters passed Measure RR amending the City Charter to further strengthen tenant protections against eviction in the following three ways: • Extending “just cause” eviction protections to all tenants in multi-unit apartment buildings that are permanently exempt from rent control, as well as two- and three- unit owner-occupied properties, and newly constructed rental units. • Requiring owners to give tenants a reasonable opportunity to correct an alleged lease violation, nuisance activity, or failure to provide lawful access before serving a three- day notice to perform or quit. • Forbidding owners to evict for owner occupancy any tenant who has occupied a rental unit for at least five years and is 62 or older, disabled, or terminally ill, unless the owner (or qualified relative intending to occupy the unit) meets at least one of these same criteria. 8.B.h Packet Pg. 680 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-62 The strengthened eviction protections under Measure RR have had a noticeable impact. From 2005 to 2010, the Rent Control Board received on average copies of 109 eviction notices per year for reasons other than non-payment of rent. By comparison, the Board received on average 85 notices annually after Measure RR took effect (excluding 2020 when eviction moratoria related to the COVID-19 pandemic reduced the number to just 31). iii. Tenant Harassment Protections In 2002, the City Council adopted a Tenant Harassment Ordinance to protect tenants in rent- controlled units from landlords’ conduct in derogation of tenants’ rights. The ordinance prohibits the following acts by landlords if they are done with the intent to harass: • Taking away services provided for in the lease (such as parking or laundry) • Failure to perform repairs and maintenance required by law • Entering the apartment without proper notice • Using lies or intimidation intended to make a tenant move out • Giving a “3-day notice” or other eviction notice that is based on false charges where the landlord does not intend to take the case to court • Threatening the tenant, by word or gesture, with physical harm • Intentionally disturbing a tenant’s peace and quiet • Interfering with a tenant’s right to privacy • Refusing to acknowledge receipt of a tenant’s rent payment without justification • Violating any law which prohibits discrimination based on race, gender, sexual preference, sexual orientation, ethnic background, nationality, religion, age, parenthood, marriage, pregnancy, disability, Acquired immunodeficiency syndrome (AIDS), or occupancy by a minor child In December 2011, the City Council extended these tenant harassment protections to all tenants covered by just cause eviction rules. Tenant harassment complaints are referred to the City Attorney’s Office for investigation and enforcement of the law. As a neutral enforcer of the law, the City cannot represent tenants directly and refers tenants requiring representation to Legal Aid (located near City Hall) and the Santa Monica Bar Association. iv. Relocation Assistance Under the City’s Municipal Code, a property owner is required to pay relocation assistance to a tenant when terminating a tenancy for any of the following reasons: • The owner seeks to withdraw all rental units from the rental market as provided for under the Ellis Act • The owner seeks to recover possession of a rental housing unit for use by the owner or 8.B.h Packet Pg. 681 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-63 family member • The landlord seeks to demolish or otherwise withdraw a rental housing unit from residential rental housing use, including units that were illegally converted to residential use, after having obtained the proper permits from the City Santa Monica had not increased its permanent relocation benefit amounts (other than cost of living increases) since 2007, during which time rent levels in the city had increased and vacancies had decreased. In December 2011, the City Council adopted increased relocation fees. In addition, the City established augmented relocation amounts to households with seniors, disabled persons, and children because these households are particularly vulnerable. It increased the assistance amounts again effective February 2019 to mitigate the financial impacts of involuntary displacement and to keep pace with living costs. Figure E-20 presents the City’s adopted relocation amounts effective July 1, 2020. The fees are adjusted each July to reflect increases in the cost of living. Figure E-20 Residential Relocation Fee Amounts, Fiscal Year 2020/2021 v. Rent Control Dispute Resolution The Rent Control Law provides processes for filing of petitions, complaints, and applications to resolve disputes between landlords and tenants. • Excess rent complaints are reviewed by staff, and the owner is given a chance to resolve the complaint. Complaints which are unable to be resolved administratively are referred to the Hearings Division for mediation and/or hearing. • Owner-occupied exemption applications are reviewed by staff and granted or denied by the Rent Control Board. If staff review indicates an exemption may be recommended to be denied, or if a tenant challenges the granting of an exemption, it is referred to the Hearings Division for an evidentiary hearing and for preparation of a recommendation to the Board. • The Hearings Division provides mediation services as part of the decrease and excess rent processes, as well as for issues involving lack of maintenance, loss of housing services, and unreasonable construction impacts. Mediators have been very Unit Size Fee Amount Augmented Fee Amount* Single or Studio $16,500 $17,200 One bedroom $22,700 $24,250 Two or more bedrooms $31,550 $33,650 Source: City of Santa Monica, Ordinance #2383 *Eligible households include those with a senior citizen, occupant with a disability, or an occupant with whom a minor child resides. 8.B.h Packet Pg. 682 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-64 successful in settling a large percentage of these cases. The City has found that mediation may be particularly useful when a building is purchased. For example, new owners may want to fix up the building and make improvements in the common areas yet may be unaware of how the Rent Control Law affects those changes such as proper notice being required before entering the tenants’ units or the tenants being entitled to certain amenities. The tenants may be concerned about changes to their home and disruptions to the longstanding practices or “culture” of a building and may not know how to communicate their concerns effectively. Mediation is often appropriate and helpful in this type of situation. 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 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 future for up to 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 the production of affordable housing. Housing Element 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. 8.B.h Packet Pg. 683 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-65 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 are 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. d. Home Sharing (Short-Term Rental) Ordinance In response to the increase in vacation rentals due to the popularity of Airbnb and other online platforms, the City desired to reaffirm its long-standing prohibition of vacation rentals in Santa Monica while allowing individuals to be able to rent a spare room in their homes for periods of thirty days or less (“home-sharing”). Therefore, on May 12th, 2015, the City adopted the "Home- Sharing Ordinance" adding Chapter 6.20 to the SMMC to expressly adopt and confirm its longstanding prohibition against short-term vacation rentals and establish regulations for home-sharing. This law became effective on June 12th, 2015, and was subsequently amended by ordinances adopted on January 24, 2017, June 27, 2017, and September 24, 2019. The Home- Sharing Ordinance allows eligible residents (owners and long-term residents) to apply for a home-sharing permit and business license so that they can home-share their primary residence. In addition, the September 24, 2019 amendments to the ordinance contain listing and advertising requirements, restrictions on the number of group bookings, occupancy and visitor vehicle limitations, and other prohibitions. These amendments took effect on October 24, 2019 and apply to all home-shares including those operating under business licenses obtained prior to the effective date of the ordinance. The Home-Sharing Ordinance provides for regulations of two types of Short-Term Rentals: • “Home-Sharing” – The rental of 30 consecutive days or less of one or more bedrooms in the home that is the primary residence of the host while the host lives on-site in the home throughout the visitor’s stay. The Home-Sharing Ordinance authorizes home- sharing. • "Vacation Rental” – A vacation rental is the rental of 30 consecutive days or less of a home, in whole or in part, for exclusive transient use. The visitor enjoys the exclusive private use of the unit. The Home-Sharing Ordinance restates and clarifies the City’s 8.B.h Packet Pg. 684 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-66 longstanding prohibition against Vacation Rentals. The City’s Home-Sharing Ordinance does not present a constraint on the production or preservation of housing. e. Residential Leasing Requirements Ordinance To protect the City’s rental housing stock for use as long-term permanent housing, the City enacted a Residential Leasing Requirement Ordinance on September 8, 2020. The ordinance established the following new leasing requirements which apply to all rental housing units in Santa Monica: • Units must be rented only to natural persons • Units must be rented only to tenants intending the unit to be their primary residence • Units must be rented for an initial term of not less than 1 year • Units must be rented unfurnished Subsequent to adoption, on October 13, 2020 the requirements were amended to allow the following limited exemptions to the residential leasing regulations: • Leases of owner-occupied rental housing units for more than 30 days and less than a year no more than twice a year for a total period of 6 months. This would not apply to a unit that had been the subject of an Ellis Act or owner-move-in eviction within the last ten years. • Leases that provide temporary relocation for tenants who are subject to a temporary relocation order under the City’s tenant projection laws. • Leases of ADUs and JADUs for which plans are submitted for plan check before December 2020 for more than 30 days and less than one year. This would only apply if the ADU or JADU is located on a parcel with an owner-occupied single-unit dwelling and the owner of the single-unit dwelling resides onsite throughout the duration of the lease. The City’s Medium-Term Housing Ordinance does not present a constraint on the production of housing and helps preserve the City’s rental housing supply. 8.B.h Packet Pg. 685 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-67 f. City Anti-Discrimination Ordinances Santa Monica maintains the following anti- discrimination protections within its Code: i. Sexual Orientation or Domestic Partnership Chapter 4.40 of the Municipal Code prohibits housing discrimination against persons based upon sexual orientation or domestic partnership. Specifically, the Code prohibits unlawful real estate practices, generally defined as the refusal to treat persons fairly in the sale, lease, or rental of housing; the provision of credit or insurance; the advertisement of housing; and the provision of tenant services. In addition, the Code prohibits evictions against any tenant on the grounds that he or she has breached a rental agreement if the alleged breach arises from an increase in the number of occupants due to the domestic partnership of the tenant provided that the occupancy by the tenant’s domestic partner and children of the domestic partner is otherwise lawful. ii. Persons Living with AIDS Passed by the City Council in 1988 as one of the first ordinances in California to address AIDS discrimination, Chapter 4.52 of the Municipal Code prohibits housing discrimination against a person with AIDS, a history of AIDS, or those regarded as having or transmitting AIDS. Specifically, the Code prohibits unlawful real estate practices, which are generally defined as the refusal to treat persons fairly in the sale, lease, or rental of housing; the provision of credit or insurance; the advertisement of housing; and the provision of tenant services. The only exception applies to the rental or leasing of any housing unit in which the owner or lessor or any member of his or her family occupies one of the living units and it is necessary for the owner or lessor to use a bathroom or kitchen facility in common with the prospective tenants. iii. Families with Children Chapter 4.28 of the SMMC establishes the following actions as unlawful for any person offering for rent, leasing, or listing any housing accommodation, or any authorized agent or employee of such person: • Refuse to rent or lease a housing accommodation, allow access to or use of the common areas and facilities, serve a notice of termination of tenancy, commence an unlawful detainer action or otherwise deny or withhold a housing accommodation on the basis of age, parenthood, pregnancy, or the actual or potential occupancy of a minor or child. • Advertise, represent, or include in any contract with regard to a housing accommodation offered by that person a statement that indicates any preference, limitation, or discrimination with respect to age, parenthood, pregnancy, or the potential actual occupancy of a minor child. 8.B.h Packet Pg. 686 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-68 • Include in any rental agreement or lease for a housing accommodation a clause providing that as a condition of continued occupancy, the tenants shall remain childless or shall not bear children or otherwise not maintain a household with a person or persons of a certain age. • Threaten to commence or commence eviction proceedings against any tenant head of household on the grounds of breach of a rental agreement due to an increase in the number of occupants arising out of the marriage of the tenant, or the birth, adoption, or change of legal custody of a minor child of whom the tenant head of household or his or her spouse is the parent or legal guardian. Exceptions to this chapter include housing designed and operated exclusively for senior adults and their spouses, or any nursing, convalescent, or retirement home. g. Rent Control Bootleg Unit Ordinance In the past, City regulations regarding the status of certain units that had been illegally created and then registered with Rent Control caused conflict. To address this, the City passed an ordinance in 2008 that set forth terms to allow these “bootleg units” to become legal, non- conforming. Pursuant to SMMC Section 9.27.090, a “bootleg unit” is defined as “a rental unit registered with the Santa Monica Rent Control Board, which was built or created without City planning or building permits.” Typically, these units do not meet applicable development standards, but the ordinance allows for the unit to not be required to meet setback and density requirements if the unit is or can be made habitable pursuant to the Building Code. While the legalization of these units might require the addition of parking for the unit, if the Community Development Director determines it is not feasible, the requirement may be waived. The Rent Control Bootleg Unit Ordinance does not present a constraint on housing as it provides a path forward to legalize existing units. h. Water Neutrality Ordinance In response to the State emergency proclamations in 2014 and the Governor’s drought-related executive orders in 2014 and 2015, the City developed a water neutrality ordinance in order to counterbalance increasing potable water demand from new development. Adopted in 2017, the City’s water neutrality ordinance, which is codified in SMMC Section 7.16.050 (the “Water Neutrality Ordinance”), imposes a land use requirement that new development offset net new potable water demand through on-site water saving measures or, alternatively, by installing equivalent off-site improvements (such as water saving toilets and shower heads) or paying an in-lieu offset fee, which is used by the city to fund off-site improvements. The City of Santa Monica is an urban water supplier. Urban water suppliers are required to prepare and implement an Urban Water Management Plan (UWMP) and a Water Shortage Continency Plan (WSCP) in accordance with California Water Code, §10610-10656 and §10608. The Water Neutrality Ordinance is an effective water conservation tool that is considered an 8.B.h Packet Pg. 687 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-69 integral part of the City’s UWMP and WSCP. These plans support the City’s long-term resource planning to ensure that adequate water supplies are available to meet existing and future water needs. The City’s UWMP and WSCP were last updated and adopted by the City Council on June 8, 2021. The Water Neutrality Ordinance applies to new development, including new housing development. A 1:1 offset of the new potable water demand is required for new development, however, the ordinance allows a lower offset of 0.5:1 for new affordable housing development and new ADUs New development projects with projected usage equal to or less than their calculated baseline water demand (i.e. the average annual water demand the previous five years) are not required to offset water usage. Therefore, these projects are not impacted by the Water Neutrality Ordinance at all since they do not generate net new water demand. In reviewing the Water Neutrality Offset Fees assessed to multi-family and mixed-used developments over the past four years, the actual fee assessed in comparison to the development's job value is minimal or insignificant. Thirty-six projects were analyzed with an average valuation of approximately $7.2 million. For these thirty-six projects, the average Water Neutrality Offset Fee assessed was $67,585, or less than 1% of the valuation for the development. City staff is not aware of any development project that has been reduced in scope or not built due to Water Neutrality Offset Fees, nor has any project appealed the fees due to undue hardship. In addition to the minimal Offset Fee to project valuation percentage described above, the following factors also contribute to minimizing or reducing any perceived constraints of Water Neutrality compliance on housing developments: • When older developed sites are redeveloped, the impact of Water Neutrality Offset Fees on the development can be insignificant or non-existent as the redevelopment will use new high-efficiency water saving fixtures (e.g., low flow toilets and high efficiency faucets) that will replace older, higher water consumption fixtures. • Projects that choose to, or may be required to in the future, use recycled water, will have a significant reduction in potable water demand, resulting in a corresponding reduction, or elimination, of the Water Neutrality Offset Fee. • 100% Affordable Housing projects have a reduced offset of 50% of the projected new potable water demand, thus lowering the Water Neutrality Offset Fee accordingly. • ADU projects (conversions or additions) for both single-unit and multi-unit properties are exempt from Water Neutrality Offset Fees if the total water demand for the parcel (including the demand created by the new ADU) is below the property’s Water Conservation Threshold. • If an ADU project is not exempt from the Water Neutrality Offset Fee (per the previous bullet), the new water demand offset is reduced to 50%, thus lowering the Water Neutrality Offset Fee accordingly. 8.B.h Packet Pg. 688 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-70 Water Neutrality Fees are assessed on a case-by-case basis since the baseline water usage (the average annual water demand the previous five years) is specific to each site and its land use. The City recognizes that there may be potential sites where the Water Neutrality Offset Fee could potentially pose impactful constraints such as redeveloping an existing parking lot (i.e., where the baseline is typically zero) or a single-story commercial site for housing purposes (i.e., a change of use with a relatively low baseline for the new project). The City is in the process of evaluating potential impacts and identifying mitigation measures (e.g., reduced offsets, default baseline values), if necessary, in such cases and balance that with water supply availability to ensure the community has access to a reliable and affordable water supply. B. NON-GOVERNMENTAL CONSTRAINTS State law [California Government Code, Section 65583(a)(6)] requires Housing Elements to contain an analysis of nongovernmental constraints to the maintenance, improvement, or development of housing for all income levels including cost of construction, the price of land, and the availability of financing. Potential nongovernmental constraints are largely determined by market conditions over which local jurisdictions have little control. However, local governments can influence market conditions and their associated costs even if only indirectly. 1. Construction Costs A number of factors, such as the type of construction, site conditions, application of parking, unit size, fire safety requirements, and amenities, all impact the cost of housing. In general, multiple- unit housing projects are less expensive to construct than single-unit housing. However, construction costs vary significantly depending on the size of the unit and the number and quality of amenities offered. These include features such as parking supply, swimming pools, rooftop gardens, gyms, and other less obvious decisions based on the types of flooring, appliances, light fixtures, and quality of cabinetry and woodwork. Based on recently completed affordable housing projects built in the City, Santa Monica Housing Office data indicate that total development costs average $480,000 per unit4. Of these total costs, it is estimated that $300,000, or 69%, are “hard costs” related to construction. Total development costs have increased in the past several years due to labor and material availability constraints. Based on construction cost estimates prepared by a third-party City consultant and interviews with market-rate developers, total development costs of apartment projects are approximately $799,000 per unit. Of these total costs, it is estimated that $413,000, or 52%, are “hard costs” related to construction5. Though construction costs comprise a large portion of the total development cost of a project, the costs in Santa Monica are not atypical 4 November 20, 2019 HR&A Feasibility Analysis 5 HR&A Advisors and MGAC 2021 8.B.h Packet Pg. 689 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element E-71 compared to Los Angeles County and therefore, would not constitute an actual constraint on housing production. 2. Land Costs and Availability Land costs include the cost of acquiring land. Land costs typically account for a large share of the total housing production costs. In Santa Monica, one of the primary market constraints to producing market rate and affordable housing is land cost. This is directly attributable to the City’s desirable location and limited availability of vacant and developable land for residential development. Land costs can vary depending on which area of the City the project is located, ranging from $690 per square foot in Downtown to $430-$435 on Lincoln Boulevard/Main Street and the Boulevards. Land costs on recent affordable housing projects in the city averaged $180,000 per unit6 comprising 37% of the total unit development cost. Land costs for market- rate apartment projects are approximately $233,000 per unit comprising 29% of the total unit development cost7. The persistent demand for housing and competition for limited available land has kept Santa Monica residential land values high for many years. The combination of non-governmental constraints (e.g. high land costs) and governmental constraints (low-density development standards) are a constraint to new residential development. It is often challenging to find sites that are large enough to accommodate projects at a preferred development scale (i.e., 60- to 100-unit projects at four to five stories). To the extent that total development costs can be reduced through changes in zoning, development standards, City-imposed development costs, and/or permit processing time, affordability goals can be better accomplished. 3. Availability of Financing The availability of financing is a critical factor that can influence the cost and production of housing. There are generally two types of financing used in the multi-unit housing market: (1) construction financing used for initial site preparation and construction; and (2) permanent financing used to purchase existing buildings or to pay off more-expensive construction financing. Both of these products are generally distinguished from financing available to purchasers of single-unit dwellings as they are commercial real estate products, and there is less government involvement to stabilize rates and availability of debt. The availability and cost (i.e., interest rates) of financing can substantially impact housing production either because it adds cost to a project or because it reduces the value or attractiveness of the sale/purchase of a completed project. Generally, the cost of development in Santa Monica and associated risks present challenges for developers to secure financing for new multiple-unit buildings. The COVID-19 pandemic has also had an impact broadly on the 6 November 20, 2019 HR&A Feasibility Analysis 7 HR&A Advisors and MGAC 2021 8.B.h Packet Pg. 690 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-72 availability of financing although less so for multiple-unit developments. While interest rates remain reasonably low, lenders have been underwriting projects more conservatively during the pandemic leading to tightened credit despite affordable interest rates. These impacts are likely to ease as pandemic conditions continue to improve and the economy recovers. 4. Requests for Housing Development at Reduced Densities State law requires the Housing Element to include an analysis of requests to develop housing at densities below those anticipated in the sites inventory. In Santa Monica, density is controlled differently between residential and nonresidential zone districts. In residential zones, density limitations are traditionally prescribed, whereas in nonresidential zones, density is controlled through a combination of building height and FAR development standards. Through a review of projects within these different zone types, projects in residential zones have typically been developed at or below density maximums. This is largely due to when the City’s Affordable Housing Production Program (AHPP) requires affordable units to be provided on site versus when a developer can pay an in-lieu fee. While this can be viewed as a constraint on housing production, it must be weighed against the need for affordable housing. However, Housing Element Program 2.C proposes to reevaluate the City’s AHPP in comparison to achieving the City’s housing goals., and Programs 1 F and 1 J will ensure that housing development projects remain feasible, taking into consideration any AHPP requirements. As for the City’s nonresidential zones, it is rare for developers to not maximize the allowable development potential of a parcel, and therefore, it can be assumed that developers are not under-densifying their developments. Additionally, as described throughout this appendix, the City has implemented several measures to streamline housing projects, which limits or removes the City’s discretion to reduce densities. The sites inventory analysis takes into account past production trends when calculating the capacity for residential redevelopment amongst various zone districts throughout the City. 5. Length of Time Between Project Approval and Applications for Building Permits State law requires an analysis of the length of time between receiving approval for a housing development and submittal of an application for a building permit. On average, the time between these two stages of a housing project varies between three to six months for smaller projects, and sometimes up to a year or more for larger mixed-use projects. This time between approval and applying for a building permit can be contributed to the applicant preparing necessary construction drawings, finalizing construction financing, and retaining various contractors, amongst other actions. 8.B.h Packet Pg. 691 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F: Report on Suitable Sites Inventory Analysis ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●● ● ● ● ● ● ●●● ● ● ● ● ● 8.B.i Packet Pg. 692 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-1 Introduction Santa Monica’s Regional Housing Needs Allocation for the October 2021 through October 2029 planning period is 8,895 units broken down as follows: Income Level % of AMI* Units % of RHNA Allocation Very Low 31-50% 2,794 31% Low 51-80% 1,672 19% Moderate 81-120% 1,702 19% Above Moderate 120%+ 2,727 31% Total 8,895 100% Source: http://SCAG.ca.gov.gov/Housing/rhna.htm * AMI – Area Median Income. Note: SCAG’s RHNA does not include the income level of Extremely Low Income (ELI) (0-30% AMI) units, which are required by the City’s AHPP. ELI units produced in the City are counted towards SCAG’s Very Low Income category. The housing element of the general plan must include an inventory of land suitable and available for residential development to meet the locality’s regional housing need allocation (RHNA) by income level. This inventory is known as the Suitable Sites Inventory (SSI) and is used to demonstrate that there is sufficient land at appropriate densities and development standards to accommodate the RHNA at the income levels specified. This document has been prepared to outline the methodology used for identifying potential housing sites for the City of Santa Monica’s 6th Cycle Housing Element SSI. The methodology follows State Housing Element Law and the guidance of the Housing Element Site Inventory Guidebook prepared by the Housing and Community Development Department (June 2020). Overview of the City’s Suitable Sites Inventory Per State law, the City’s SSI consists of sites that are reasonably likely to be redeveloped into residential during 6th Cycle planning period. The SSI includes sites with approved/pending projects, underdeveloped sites that were identified, and non-site-specific accessory dwelling unit potential. A total of 340 sites are identified. Under current zoning, the SSI has an anticipated unit potential of 7,596 units with capacity for 4,064 affordable units. Therefore, the City will have an anticipated shortfall of 1,109 lower income units and 1,003 moderate units. State law dictates that if sufficient capacity to meet the RHNA cannot be demonstrated based on existing zoning, the City is required to rezone sites on the inventory by October 15, 2024 to demonstrate the ability to meet sufficient capacity. The rezoning programs are Programs 1.F, 1.J, 1.K, and 4.A. With these rezoning programs, the City’s 8.B.i Packet Pg. 693 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-2 SSI capacity is estimated to be approximately 13,600 units which includes capacity for 8,044 lower income units and 1,901 moderate income units. Methodology for Suitable Sites Inventory The City of Santa Monica maintains a comprehensive land use inventory that includes details for every parcel within City limits. The methodology for the Suitable Sites Inventory consists of a multistep process that narrows down the list of suitable sites from the City’s Land Use Inventory. The Land Use Inventory was first created in 2010 during preparation of the City’s Land Use and Circulation Element, and is a master inventory of each parcel in the City that identifies existing uses, ownership, building age, zoning, and other information. The Land Use Inventory is updated every two years using assessor land use information, the City’s building permit database (for demolitions and new construction), and site visits to confirm existing uses. The SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning and general site constraints such as historic designations and land use. After screening out unavailable sites, City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, market factors, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. The methodology is described step by step below: 8.B.i Packet Pg. 694 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-1 Step 1: Identify Available Multi-Unit Residential Zoned Parcels • Difficult to identify Single Unit parcels for SSI Step 2: Site Screening • Properties with Residential Unlikely to Redevelop (rent control units, condos, multifamily, SB330 replacement requirements) Step 3: Assess Suitability of Sites Review Residential Potential with Consideration to: • Parking lots (or A-lots) associated with Commercial fronting parcels • Parking lots associated with religious institutions • Vacant sites City Land Inventory 1. Filter out: Single Family, Ocean Park Single Family, Ocean Park Duplex, Residential Mobile Home Commercial and City Parcels Residential Parcels 2. Remove properties based on Site Constraints & Other Known Factors Screened Commercial and City Parcels 4. Assess Suitability of Sites based on Factors Step 3: Categorize Potential Sites Categorize Potential Sites that have highest potential for turnover Step 1: Identify Available Commercial Zoned Parcels & City Owned Properties • Ensures No Net Loss • Consistent with Housing Preservation goals and policies • Consistent with LUCE Neighborhood Protection goals and policies Step 2: Site Screening Remove sites based on Factors That Impede Residential Redevelopment • Government Open Space • Historic Landmarks • Affordable Housing & Condominiums • Unique land uses (cemetery, hospital, parks, libraries, fire/police stations etc) • Under Construction or Recently Constructed Projects • Newer buildings (constructed post 1980) • Right-of-ways (such as medians/transportation corridors) Step 4: Assess Suitability based on Site Specific Evaluation Review Residential Redevelopment Potential with Consideration to: • Physical Attribute - Sites with these factors are most suitable: • Sites of 15,000 sf or more • Corner parcels • Existing Use - Sites with these factors are most suitable: • Parking lots (if site is completely or partially developed as parking) • One story building • Vacant (no tenants) or Less than 2 Tenants • Redevelopment Potential – Sites with these factors are most suitable • AVR less than 0.5 • Ownership by known housing provider • Developer interest based on current or past discussions with City staff • Other Local Knowledge – Sites are removed if • Existing tenants have longevity (eg, well known successful tenant with long term lease) • Significant improvements and investments have occurred on the site within the past 4 years 1. Approved/Pending Projects 2. Prior SSI properties 3. Downtown Community Plan buildout 4. City Owned Sites 5. Vacant & Parking Lots 6. Auto Dealership Inventory Lots 7. Recently sold/for sale 8. Large parcels (15,000 sf +) 9. Development Potential of 20K sf 10. Remaining parcels less than 0.5 ILR 3. Categorize Potential Sites SSI Sites *Identified as high potential sites meeting the suitability factors of Existing Use, Physical Attribute, and Development Potential 2. Remove properties if there are existing residential uses Screened Residential Parcels 3. Assess Suitability of Sites SSI Sites *Identified as A lots associated with commercial fronting parcels or those associated with religious institutions 8.B.i Packet Pg. 695 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-3 Step 1: Identify Available Commercial and Residential Parcels As a first step in the SSI process, parcels that are not available for residential redevelopment due to zoning were removed from consideration. Parcels in the City’s single unit zones (R1, OP1, and OPD) were filtered out from the SSI process for the following reasons: • Lack of vacant parcels in these zones • Difficulty in identifying specific parcels for the inventory since there are no known factors that could assist in determining which parcels would be redeveloped. • Even if parcels were identified, redevelopment would likely consist of demolition and replacement of existing on-site units • Parcels in the Residential Mobile Home (RMH) and Open Space (OS) districts are also removed from the SSI process since these parcels are protected by the City for low income housing and open space uses respectively. Step 2: Site Screening for Non-Suitable Parcels As a second step in preparing the SSI, parcels in the City that are not potential candidates for housing development during the Housing Element planning period were screened out based on a set of criteria. Since housing development on residential and commercial parcels are influenced by different sets of factors, residential and commercial parcels were separately screened. Commercial Parcels In general, commercial parcels meeting any of these criteria were determined to not be suitable as a housing site and screened out from the SSI: • Historic Designations: Designated historic resources, including Landmarks and/or Structures of Merits, are protected by the City’s Landmark Ordinance and the California Environmental Quality Act. Demolition of historic resources are only permitted with a Certificate of Hardship. While there have been instances where new residential development is proposed on larger parcels in conjunction with the preservation or adaptive reuse of historic resources, such instances are uncommon. Therefore, the presence of historic resources is presumed to preclude new housing development on the site. • Under Construction or Recent Construction Projects: Parcels that are under construction or have recently completed projects are not available for redevelopment into housing and therefore, are screened out from the SSI process. • Commercial Entitlements: Parcels that have approved or pending entitlements for solely for commercial uses are screened out from the SSI process since these parcels will be redeveloped into commercial. • Government or Institutional Uses: Parcels that have unique land uses such as governmental or institutional uses are unavailable for redevelopment and are also screened out from the SSI process. These include parcels with uses such as the Civic Center government uses (Santa Monica City Hall, Los Angeles County Courthouse, Civic Auditorium), UCLA and Providence Saint John hospitals, Santa Monica Cemetery, 8.B.i Packet Pg. 696 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-4 SMUUSD schools, Santa Monica College, public parks, utilities, libraries, police/fire stations, transportation infrastructure/Metro Expo Light Rail and the Santa Monica Airport. The City and institutions are unable to remove these uses in this housing element cycle as they are necessary to serve the community. • Residential Uses: The City filtered the inventory to remove parcels that are currently occupied by residential uses. In particularly, parcels developed with affordable housing, condominium units, and rent control units are highly unlikely to be redeveloped. Affordable housing is protected by long term deed restrictions, and therefore were screened out. Condominium units are common interest properties with multiple owners, and therefore, are screened out due to infeasibility of acquiring all condo ownership parcels. Rent control units are governed by the City’s Rent Control laws that limit the removal of such units and are therefore screened out from the inventory. • Newer Buildings: Parcels with newer buildings developed post 1980 are highly unlikely to be redeveloped as supported by a review of current approved and pending projects (see Attachment 1, Table 2). Residential Parcels The City screened the inventory to remove residential parcels that are currently occupied by residential uses. This approach is conservative since the City’s general plan emphasizes the protection of existing residential units and because parcels with residential uses are governed by SB330 unit replacement requirements. Furthermore, parcels developed with affordable housing, condominium units, and rent control units are unlikely to be redeveloped. Affordable housing is protected by long term deed restrictions, condominium units are common interest properties with multiple owners, and rent control units are governed by the City’s Rent Control laws that limit the removal of such units. 8.B.i Packet Pg. 697 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-5 Step 3: Categorizing Sites After screening out parcels that are not available for redevelopment, the remaining list of sites were categorized. Commercial Parcels Based on this first set of screening criteria, 1,368 potential commercially zoned sites and City- owned sites were initially identified. These sites were then categorized according to the figure below: Figure F-1 Category of Potential Commercially Zoned and Mixed Use Zoned Sites Category Description Count of Parcels Land SF 1 Approved and Pending Housing Projects 172 3,222,092 2 Prior SSI Sites 46 1,015,545 3 DCP Buildout 12 180,263 4 City-Owned Sites 106 3,723,505 5 Parking Lots 116 1,026,709 6 Auto Inventory Lots 41 407,651 7 Parcels with recent/active sales 47 385,129 8 Underutilized Sites (20,000 excess sf development potential) 183 5,953,899 9 Large Parcels (15,000 sf+) 66 2,268,697 10 Remaining Sites less than 0.5 ILR 579 3,721,870 Category 1 Sites: Pending/Approved Housing Entitlements The RHNA projection period for the 2021-2029 Housing Element begins on June 30, 2021. Therefore, pipeline housing projects that are pending or have received approved entitlements but did not receive a building permit as of July 1, 2021 are expected to count toward the 6th Cycle RHNA. Category 2 Sites: Prior Sites listed in the 2013-2021 5th Cycle Housing Element 83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have undergone entitlements but the remaining have not. These are categorized as Category 2 Sites. Category 3 Sites: Downtown Buildout Sites As part of the Downtown Community Plan (DCP), sites in the Downtown were identified for potential redevelopment. A number of these sites have already undergone pending and 8.B.i Packet Pg. 698 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-6 approved entitlements (captured in Category 1), and as such, are eliminated from further consideration. In addition, a small number were previously identified in the prior SSI for the 5th Cycle Housing Element (hence are captured in Category 2). The remaining DCP sites are classified as Category 3. Category 4 Sites: City-owned Sites An important strategy for the City to meet its RHNA targets is the utilization of existing City owned sites for housing, particularly affordable housing. All City owned sites that are not currently developed with open space/parks, community centers, civic uses, utilities, etc. are categorized as Category 4 sites. Public parking structures such as Parking Structure (PS) #3, PS#1, PS#2, and PS#4 are reviewed in this category since these structures require seismic retrofit improvements for their continued operation. Additionally, the City’s parking lots on Main Street are reviewed as potential housing sites. Category 5 Sites: Parking Lots There are no vacant sites in the City as it is highly urbanized. No vacant sites are located in the commercial and mixed use zones. However, a number of sites in the City are developed as surface parking lots. Surface parking lots are very underutilized and represent the greatest opportunity for new housing without displacement of existing uses. Redevelopment of these lots are considered with the commercial uses they serve. Category 6 Sites: Auto Inventory Lots These are parcels currently being utilized almost entirely as auto inventory surface lots, with the majority occurring on the eastern end of Santa Monica Boulevard. Auto dealerships have indicated interest in turning over these large surface lots into redevelopment opportunities as they are rethinking their sales operations. Category 7 Sites: Recent/Active Sales Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites (such as Loopnet), a number of properties have recently sold during 2019-2021 or have active sales listings. These sites could have redevelopment potential. Category 8 Sites: Underutilized Sites (20,000 sf excess development potential) Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to have a net new development potential of 20,000 sf or greater (based on their existing built area compared against the maximum floor area permitted). Category 9 Sites: Remaining Large parcels Category 9 sites are all remaining sites that are 15,000 sf and larger. Category 10 Sites: Remaining Parcels with 0.5 ILR or less Category 10 sites are all the remaining sites (not meeting Category 1-9) with an improvements to land value ratio (ILR) of 0.5 or less. 8.B.i Packet Pg. 699 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-7 Residential Parcels For residentially-zoned parcels, sites that were not screened out are categorized as religious institutional uses, or parking lots. Approximately 38 parcels were identified as parking lots that are associated with religious institutions and 97 parcels are surface parking lots for adjacent street fronting commercial uses. Figure F-2 Category of Potential Residentially Zoned Sites Category Description Count of Parcels Land SF 11 Religious Institutions 38 555,589 12 A-Lots and Residentially Zoned Parking Lots 97 911,847 Category 11 Sites: Religious Institutions Category 11 sites are properties of religious congregations (churches, synagogues, etc.). AB1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. A number of religious institutions with large surface parking lots are located throughout the City. These lots could play an important part in providing affordable housing. Program 4.B of the Housing Element would amend the Zoning Ordinance to create special standards for housing projects on sites owned by community assembly uses so that these sites would be incentivized for the production of housing. Category 12 Sites: A-Lots and Residentially Zoned Parking Lots “A-Lots” are residentially-zoned (R1/R2/R3/R4) parcels with an “A” Off-Street Parking Overlay. Within the City, there are 42 A-lots. Zoning regulations prevent their use to enable the expansion of associated commercial uses, but also effectively prevent their redevelopment for housing. Additionally, there are other residentially-zoned parcels without the A-Lot overlay that are similarly developed as surface parking lots. These surface parking lots are intended to support the parking needs of commercial corridors and neighborhood commercial areas, and to serve as a buffer between commercial and residential uses. The existing multi-unit residential zones have density caps of 4-6 units regardless of the size of the property, which limits their capacity for housing potential. 8.B.i Packet Pg. 700 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-8 Step 4: Evaluating Suitability of Nonvacant Sites for Housing Potential Government Code section 65583.2(g)(1) requires that, where non-vacant sites comprise over 50% of the Suitable Sites Inventory, existing uses are presumed to impede development unless findings with substantial evidence are provided that the use is likely to be discontinued. Santa Monica is a dense, urban coastal community and is entirely built out with little to no vacant land remaining. Therefore, the methodology used to identify the suitability of non-vacant sites for housing potential must consider factors such as site physical characteristics, existing uses, improvements to land value ratio, ownership, development interest, location and context, local knowledge, and environmental constraints. Methodology Once all the screened sites were categorized, all individual sites in Category 1-10 were reviewed by the City’s Housing Policy team using Google Streetview, City Accela permit database, and if necessary, in-person site visits. All of the sites are non-vacant, and have an existing use or are developed as parking lots. The City focused the list of non-vacant sites to those that are underutilized and primarily located within the mixed use and commercial districts where the City has encouraged housing. These districts include, but are not limited to, the Downtown districts, the Bergamot Area, and the corridors of Santa Monica Boulevard, Wilshire Boulevard, Colorado Avenue, Broadway, and Lincoln Boulevards. Recent project applications that have been filed by the City support the assumption that there is a strong housing demand in these districts. Each site was analyzed to determine its likelihood and suitability for residential redevelopment based on a set of site-specific factors. These factors were selected based on City Staff’s experience and long standing knowledge of the current projects in the pipeline and development interest in certain areas of the City. Interviews with local developers and architects from the Housing Production Technical Working Group and the general public confirmed also informed the factors and assumptions in the Site Inventory. The criteria and factors for the City’s Housing Element site inventory was presented to the public, Planning Commission, and City Council where all agreed these are appropriate criteria. The City also verified its assumptions by analyzing recent project application since adoption of the LUCE to assess development trends. Since July 2010, 152 residential and mixed use residential development applications have been received for more than 5,553 new housing units – all of which have occurred on non-vacant sites. A review of these past and current housing projects support the use of these site specific factors (see Attachment B), which are described below: Per HCD, a vacant site is a site without any houses, offices, buildings, parking lot, or other significant improvements on it. The City of Santa Monica is a dense, urban coastal community and is entirely built out with no vacant land remaining. Nonvacant, underutilized sites will be relied on to achieve the 6th Cycle RHNA. This is supported by past residential development trends which has primarily consisted of new multi-unit buildings replacing older one-story buildings on infill sites (see Attachment 1). 8.B.i Packet Pg. 701 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-9 • Site Physical Characteristics - Sites were reviewed for physical characteristics that could make them more amenable to residential development, such as size, location relative to the urban grid, and shape of the site. o Size: Based on a review of past and current housing projects (see Attachment 2), housing projects have occurred on commercial and mixed used zoned sites that are as small as 7,500 sf. This includes 100% affordable housing projects where site sizes have ranged from 7,500 sf to 30,000 sf. Housing development trends in the City indicate that a site that is 15,000 sf is generally considered sufficiently sized for residential redevelopment in the mixed-use, commercial zones (see Attachment 2). Since the majority of the housing projects (more than 90%) have occurred on sites that are 15,000 sf or greater, City staff used a size threshold of 15,000 sf for the SSI process. Sites as small as 7,500 sf may be appropriate for certain projects such as those in the Downtown and/or 100% affordable housing projects which do not require parking. Individual parcels less than 15,000 sf are unlikely to be developed. However, if two smaller adjacent parcels share common ownership, there could be potential for housing development depending on the remaining factors. The City does not have any restrictions on lot consolidations for the commercial or mixed use zoning districts, and consolidation is a common practice. Housing developers have historically consolidated lots for development and such consolidations are administratively approved as part of the plan check process. o Corner Parcels or Parcels with Alleys: As a general policy, the City’s General Plan discourages vehicular access from the main boulevard. Therefore, based on City staff experience as well as current trends of development, sites with corner parcels are more likely to be redeveloped given that vehicular access can be taken from the side street or from the alley. o Other Factors: Sites were reviewed for any other potential physical characteristics that could preclude residential development, such as narrow depth/width, grade, and other physical constraints such as lack of access. • Existing uses – Due to the built up nature of the City, past and currently proposed housing projects have all occurred on non-vacant sites. These sites were built or proposed on sites with existing uses consisting of older buildings or surface parking lots as listed in Attachment B. Using Google Streetview supplemented with site visits as necessary, existing uses on the site were assessed to determine its future viability and likelihood for the uses to be discontinued. Based on past experiences as well as review of approved/pending projects (see Attachment 1, Table 2), City staff determined that sites with these existing uses are most suitable: o Parking lots (if site is completely or partially developed as parking) - Sites that are developed as parking lots are considered more likely to be redeveloped than sites with existing building improvements. 8.B.i Packet Pg. 702 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-10 o One story building - Sites that are developed with one story buildings are also more likely to be redeveloped as they are considered underutilized. o Vacant (no tenants) or Less than 2 Tenants - Similarly, sites that are vacant or have only a single tenant are more likely to turn over than multiple tenant sites. • Redevelopment Potential – Sites were also reviewed using redevelopment potential factors such as the improvements to land ratio based on assessor’s value of land to improvements ratio, ownership information, and known developer interest. o Improvements to Land Value Ratio - A low improvements to land value ratio (ILR), which is the ratio of improvement value to the land value, is a strong indicator of the likelihood that a site has a high probability of being redeveloped.1 A review of current pending and approved projects show that these projects have occurred almost all on commercial/mixed use zoned parcels with ILR less than 0.5 (see Attachment 1, Table 2). o Ownership – Ownership of properties was also considered in the analysis. As previously stated, if two smaller adjacent parcels share common ownership, there is a high potential for housing development. The City does not have any restrictions on lot consolidations for the commercial or mixed use zoning districts, and will continue to facilitate consolidation through administrative lot tie agreements as part of the plan check process. Therefore, adjacent parcels that are held by the same owner could be developed jointly as evidenced in the City’s list of approved and pending projects (see Attachment 1, Table 2). Furthermore, parcels that are owned by known housing developers, for example, are very likely to be redeveloped. Several underutilized sites in the City are owned by State entities, institutions, and public utility companies that have the potential to accommodate housing, including the Department of Motor Vehicles (DMV) site at 2235 Colorado Ave, Santa Monica Municipal Unified School District (SMMUSD) former district offices at 1651 16th St, and the University of California, Los Angeles (UCLA)-owned parking lots at 1521 & 1601 Santa Monica Blvd. The City initiated discussions with these entities to inquire about their potential interest in housing development. Both the DMV and UCLA indicated that they had no plans for future housing on their properties. However, the SMMUSD indicated their intent and interest in developing housing for their staff at their former district offices (see Attachment 4). If State controlled sites are included in the SSI, HCD requires documentation be provided that shows that housing can be accommodated with the Housing Element planning cycle. 1 The Institute of Urban and Regional Development (IURD) at the University of California, Berkeley suggests that a ratio of improvement value to land value that is below 1.0 is an appropriate factor to identify potential housing sites on infill commercial properties. 8.B.i Packet Pg. 703 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-11 o Known Developer Interest – If a developer has expressed interest in developing a site either through a pre-submittal meeting with the City or through general inquiry, then there is a higher likelihood that the site will be redeveloped. • Location and Context – The location of the site was also considered in terms of its access to schools, jobs, transit, residential amenities such as parks/open space, health care services, and retail shops such as grocers. Many of the sites south of Olympic Boulevard lack access to these amenities and services, and, as such, were determined to not be suitable. Additionally, existing/past housing development trends in the site surrounding area were considered – reviewing if the project is located in an area where there is significant residential growth. • Other Local Knowledge – City Staff have in-depth local knowledge of properties that could preclude site development. For example, specific parcels were removed if: o Existing tenants have longevity (eg, well known successful tenant with long term lease) - For example, uses that are more unique in a particular location (such as a successful grocer in a residential neighborhood, a popular restaurant, long-standing reputable business, etc.) have demonstrated longevity, and, as such, may be considered an impediment to redevelopment of the site. o Significant improvements and investments have occurred on the site within the past 4 years – Where there has been significant investments and improvements that have been made to a site, the site is unlikely to be redeveloped in the near term. • Environmental and Infrastructure Constraints –HCD requires that cities identify any environmental constraints (e.g., fault hazard zones, flood areas, landslide zones, very high fire hazard severity zones) and infrastructure limitations that have the potential to impact the development viability of the identified sites. These constraints can include natural resources, hazards/safety concerns, or lack of sufficient infrastructure capacity. All parcels included in the sites inventory were reviewed for any known environmental constraints, such as flood zones, steep slopes, and other possible constraints to development feasibility. The sites included in the inventory are not constrained by topography, known environmental factors, or other site-specific constraints that would limit development. As summarized in Attachment 3, environmental concerns do not pose a constraint to housing production. Infrastructure upgrades would be necessary to accommodate the development of 8,895 units in the next 8 years but these are anticipated to occur with the City’s Capital Improvements Program or in conjunction with housing projects. Therefore, infrastructure systems do not pose a constraint to housing. Evaluation City staff reviewed the current status of each site and evaluated the sites using the factors above. Sites were given a rating of whether they had low, medium, medium high, and high 8.B.i Packet Pg. 704 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-12 potential for housing redevelopment. The table below show the qualifying factors for each rating. Staff did extensive research on the site, reviewing physical conditions, existing uses and other factors and removed any identified sites with demonstrated impediments. Finally, staff also conducted additional market research to support assumptions around parcel turnover at the sites. In general, as shown in the table, high potential sites include those that are adequately sized or have common ownership with adjacent parcels, are occupied with single tenants, are underutilized and occupied with aging, one story buildings, and are located in proximity to other recent housing projects. Figure F-3 Sites Inventory Evaluation Factors Factors Utilized Redevelopment Potential High Medium High Medium Low Physical Attribute Sites of 15,000 sf or more x x x Corner parcels x x Existing Use Parking lot or One Story x x Vacant or Less than 2 tenants x Redevelopment Potential ILR less than 0.5 At least one x Ownership by Developer Known Developer Interest Location Near transit/amenities x x x Other Local Knowledge Existing uses have longevity x Recent investments x The Suitable Sites Inventory is comprised of 341 high potential sites categorized as follows. Category 1 Sites: Pending/Approved Housing Entitlements As of May 2022, there were approximately 2,594 approved units (of which 637 are affordable) and 2,550 pending units (of which 420 are affordable). All approved and pending projects are considered high potential sites. Category 2 Sites: Prior Sites listed in the 2013-2021 5th Cycle Housing Element The parcels listed in the 5th Cycle 2013-2021 Housing Element were re-evaluated to determine suitability for housing potential. Parcels were determined to have low potential if they are inadequately sized (less than 7,500 sf), have undergone recent tenant improvements, or are occupied with newer tenants (indicating long term leases). Remaining sites were evaluated and considered high potential if they are adequately sized and if there is a low ILR of less than 8.B.i Packet Pg. 705 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-13 1.0 FAR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or unoccupied, etc). Category 3 Sites: Downtown Buildout Sites As part of the Downtown Community Plan (DCP), sites in the Downtown were identified for potential redevelopment. All these sites have low ILR and have older buildings, indicating high potential. The Downtown is one of the most attractive areas for housing development due in part to higher development standards for housing, access to a variety of amenities, proximity to transit, and no parking minimums. In general, the limiting factor is site size. Based on discussions with developers from the Housing Element Housing Production working group, single lot parcels (generally consisting of 7,500 sf) are infeasible to develop. Therefore, sites within the DCP that are 7,500 sf or smaller were eliminated. The remaining DCP sites are considered high potential. Category 4 Sites: City-owned Sites City staff reviewed all City-owned land to determine if there is potential for housing development. A number of City-owned sites have the highest potential to accommodate the production of affordable housing. These sites do not have long-term leases with outside parties that extend beyond the 6th Cycle Housing Element planning period and do not have existing uses that are non-City operated, and therefore are considered high potential. High potential City-owned sites include the parcels serving as the parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Public Parking Structure 3, and the Bank of America/Chase bank site at 4th Street/Arizona. Category 5 Sites: Parking Lots As previously stated, there are a number of sites in the City that are developed as surface parking lots. Many of these lots serve one-story commercial uses. These surface parking lots were considered in conjunction with the commercial uses they serve, if any. Sites were considered high potential if they are adequately sized, if there is common ownership with adjacent commercial parcels they serve, the existing buildings on the site are more than 40 years old, there is known developer interest, and if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, on-site business is not well known in the community, etc.). Category 6 Sites: Auto Inventory Lots Santa Monica has a number of auto dealerships with large surface parking lots used for auto inventory. In some cases, auto dealerships span multiple parcels with some on adjoined lots and some on separate lots. Some of the parcels serve as inventory parking for used cars or new cars. Sites were considered high potential if they are adequately sized, there is common ownership with adjacent parcels, there are other multiple parcels located elsewhere that are also owned by the same owner (if so, they can adequately serve as inventory for both used and new cars), or if there has been known developer interest. 8.B.i Packet Pg. 706 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-14 Category 7 Sites: Recent/Active Sales Properties that have recently sold during 2019-2021 or have active sales listings were evaluated and considered high potential if they are adequately sized and located in an area where residential has occurred or occurred nearby. Recently sold sites that are occupied with new tenants were excluded and determined to have low potential. Category 8 Sites: Underutilized Sites (20,000 sf excess development potential) Category 8 sites have a net new development potential of 20,000 sf or greater (based on their existing built area compared against the maximum floor area permitted). Sites were evaluated and considered high potential if they are adequately sized and if there is a low ILR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc). Category 9 Sites: Remaining Large parcels Category 9 sites are all remaining sites that are 15,000 sf and larger. Sites were evaluated and considered high potential if they are adequately sized and if there is a low ILR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc.). Category 10 Sites: Remaining Parcels with 0.5 ILR or less Category 10 sites are all the remaining sites (not meeting Category 1-9) with an improvements to land value ratio (ILR) of 0.5 or less. Based on the assessment of sites using the above factors and methodology, there are 137 parcels that have approved and pending projects for residential development (Category 1) and 185 non-vacant commercial/mixed use zoned parcels (Categories 2-10) in the City identified to have high potential for residential redevelopment. An additional 22 residentially zoned sites developed as surface parking lots are identified as having high potential, and therefore are also included in the SSI. The Housing Element includes Program 1.C to adopt standards that will incentivize A-Lots and residentially zoned parking lots to be developed in support of multi-unit housing development. Together these 340 parcels comprise approximately 5.2 million sf of land area and are included in the SSI. Figure F-4 Summary of Commercial and Mixed Use Zoned Sites in SSI High Potential for Redevelopment Category Description Total Land Area Count of Parcels 1 Approved and Pending Housing Projects 1,921,522 138 2 Prior SSI Sites 466,371 21 3 DCP Buildout 94,015 7 4 City-Owned Sites 778,481 24 5 Vacant Sites/Parking Lots 164,891 21 8.B.i Packet Pg. 707 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-15 6 Auto Storage Lots 206,212 23 7 Parcels with recent/active sales 168,576 17 8 Underutilized Sites (20,000 excess sf development potential) 767,643 30 9 Large Parcels (15,000 sf+) 135,267 6 10 Remaining Sites with less than 0.5 ILR 210,996 31 Grand Total 4,913,974 318 Figure F-5 Summary of Residentially Zoned Sites in SSI High Potential Residentially Zoned Sites Category Description Total Land Area Count of Parcels 11 Religious Institutions 149,307 7 12 A-Lots/Residentially Zoned Parking Lots 168,609 15 Grand Total 317,916 22 Reliance on Nonvacant Sites to Accommodate more than 50 percent of RHNA The City of Santa Monica is a dense, urban coastal community and is entirely built out with little to no vacant land remaining. As such, this Housing Element relies on nonvacant sites to accommodate 100 percent of its RHNA for lower income households. Based on analysis of the factors discussed above for each category of sites (such as age of buildings, known developer interest, low ILRs, size of sites, development trends, market conditions, ownership information), the City anticipates that the existing uses on the SSI sites will likely be discontinued during the planning period. Pursuant to Government Code Section 65583.2(g)(2), as part of its resolution adopting this Housing Element, the City will include findings stating that uses on nonvacant sites identified in the SSI to accommodate the RHNA for lower income is likely to be discontinued during the planning period. Replacement of Affordable Units Excluding approved and pending housing projects (Category 1 sites), two sites on the SSI have existing residential uses. As required by Government Code Section 65915(c)(3), this Housing Element includes Program 3.A, which would require new housing projects on sites with existing residential units or within the last 5 years, that have or had residential units that are lower income, rent control, or affordable units to replace those units at the same or lower income level. 8.B.i Packet Pg. 708 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Map F- 1 Suitable Sites Inventory 8.B.i Packet Pg. 709 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-17 Step 5: Realistic Capacity Analysis of Suitable Sites 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. Category 1 – Approved and Pending Projects As previously stated, as of May 2022, there were approximately 2,594 approved units (includes 637 affordable) and 2,550 pending units (includes 420 affordable). These sites are listed in Appendix A. A review of the past 5th Cycle Housing Element show that 15% of approved and pending projects are withdrawn, have had permit approvals expire, or have not pulled building permits within 8 years of project approval (i.e., housing element cycle). It is not possible for City staff to predict which specific approved and pending projects would be withdrawn or ultimately not developed. Eliminating some projects and not others would be arbitrary and speculative. However, based on information from the prior Housing Element cycle, a 15% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 2,205 approved units and 2,168 pending units that are projected to be counted towards the 6th Cycle Housing Element. Figure F-6 Approved and Pending Projects Housing Capacity # of Units # Units Counted for SSI (w/ 10% discount) Category 1 Approved 2,594 2,205 Category 1 Pending 2,550 2,168 Category 4 – City-Owned Sites The City-owned sites determined to have the highest potential to accommodate the production of affordable housing include parcels serving as parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Parking Structure 3, and the site at 4th Street/Arizona. All parcels are developed as public parking or have uses with expiring lease terms during this 6th Cycle planning period, which provide for the most housing development potential. Furthermore, these sites do not have any existing residential uses. However, the existing density standards and FARs limit housing potential. For example, the public parking parcel on Main Street is zoned R3 and has a density cap of 5 units on a parcel. Therefore, this 6th Cycle Housing Element includes Program 2.E, which would commit City-owned sites for the development of affordable housing through a public process, which would include necessary rezoning to accommodate the estimated realistic capacity for these sites. To determine the estimated realistic capacity, the City engaged with HR&A advisors and local architects who considered existing constraints, including, but not limited to, lease terms for commercial uses on the property located at 4th/Arizona and Property Management Agreement with associated annual leases at the Bergamot Arts Center, financial feasibility, available funding sources, etc. 8.B.i Packet Pg. 710 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-18 Based on an assumption that affordable housing would likely not be greater than 6-7 stories (due to increasing costs associated with construction type – e.g., Type 3 vs. Type 4 construction), it is estimated that the City-owned sites could accommodate a density of 150 units per acre. Therefore, applying a density factor of 150 units/acre, City-owned sites have the potential for accommodating 1,880 units. To ensure that City-owned SSI sites can be counted towards meeting the RHNA, Program 2.E commits the City to plan for a target of 1,880 affordable units across City-owned sites which may include, but shall not be limited, to rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. 8.B.i Packet Pg. 711 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-19 Figure F-7 City-Owned SSI Sites Address Parcel Nos. GP Designation Zoning Existing Use Existing Base Allowable Density or FAR Proposed Density with Program 2.E Land Area (sf) Unit Capacity with Program 2.E Other Info 1146 16th St 4281005900 Low Density Residential R2 Public parking lot 8 behind Café Zella 1 unit/2000 sf or 4 units (whichever less) 150 units/acre 7,500 26 No leases – parking is City operated 1217 Euclid St 4282004900 Medium Density Residential R3 Public parking lot 7 1 unit/1500 sf or 5 units (whichever less) 150 units/acre 7,500 52 No leases– parking is City operated 1217 14th St 4282003900 Medium Density Residential R3 Public parking lot 12 behind Petco 1 unit/1500 sf or 5 units (whichever less) 150 units/acre 22,500 52 No leases– parking is City operated 4282003901 Main St between Ocean Park Blvd and Kinney St 4288009900 High Density Residential R3/R4 Public parking lots 9, 10, and 11 on Main St (excludes alleys) 1 unit/1500 sf or 5 units (whichever less) 150 units/acre 167,388 577 No leases– parking is City operated; but replacement parking will be necessary (Coastal Zone) 4288010900 4288014901 4288011900 4288012902 4288013905 4288015901 1333 4th St 4291011909 Bayside Conservation BC Bank of America; Chase bank 2.25 FAR 150 units/acre 52,489 181 Bank of America’s lease ends in 2026 and Chase Bank has requested to extend their lease to 2026 and terminate alongside the BofA lease. 4291011910 1324 5th St 4291011900 Neighborhood Village NV Public parking lot 27 2.25 FAR 150 units/acre 52,470 181 No leases– parking is City operated 4291011901 4291011902 8.B.i Packet Pg. 712 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Address Parcel Nos. GP Designation Zoning Existing Use Existing Base Allowable Density or FAR Proposed Density with Program 2.E Land Area (sf) Unit Capacity with Program 2.E Other Info 4291011903 4291011904 4291011905 4291011908 1318 4th St 4291012900 Bayside Conservation BC Parking Structure 3 2.25 FAR 150 units/acre 30,000 104 City Council authorized exclusive negotiation agreement on 1/22/2022 with EAH for development of affordable housing; Demolition began March 2022 4291012901 2500 Olympic 4268013919 Conservation Arts Center CAC Bergamot Arts Center1 1.0 FAR 150 units/acre 205,000 707 Property Management Agreement until April 2027. City has annual leases with 30 businesses (expiring 12/31) that will be renewed each year until redevelopment 4268014900 Total Estimated Capacity 1,880 1 The 205,000 sf land area accounts for half of the Bergamot Arts Center parcel being occupied by an existing leased R&D building which precludes housing development on this portion of the site 8.B.i Packet Pg. 713 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-21 Category 11 and 12- Religious Congregations and Parking Lots Surface parking lots located in the multi-unit residential zoning districts have the ability to accommodate housing. These include parking lots associated with religious congregations and parking lots associated with street-fronting commercial uses. Discussions with religious congregation leaders have indicated that there is a strong desire to develop affordable housing on the parking lots of sites owned by religious congregations. Program 4.B in this Housing Element would amend the Zoning Ordinance to allow housing projects on these religious congregation sites to be developed to unlimited density, no minimum parking requirements, and an additional 33 feet of building height, provided that 50% of the units are provided as affordable. However, based on discussions with affordable housing developers, it is unlikely that affordable housing projects will be built greater than 5 stories. Therefore, housing capacity of sites owned by religious congregations were analyzed assuming a height of 5 stories. Surface parking lots in residential zones have housing potential but their potential is limited by existing residential unit caps. The Housing Element includes Program 1.C which would amend the Zoning Ordinance to eliminate the maximum unit caps within these residentially-zone surface parking lots and to create special standards for housing projects on these sites. The capacity analysis applies the following factors to calculate realistic capacity of Category 11 and 12 sites: • Typical Density: Parking lots owned by religious congregations would be developed with affordable housing projects and as such, would be afforded new development standards that would give it increased height as compared to other sites in the residential zones. However, as stated above, such projects would likely be limited by the number of stories. Affordable housing developers have indicated that they will likely build no more than 5-6 stories due to construction costs and prevailing wages requirements for projects constructed at greater heights. Therefore, the capacity analysis assumes a maximum of 5 stories for parking lots associated with religious congregations. For surface parking lots, the capacity analysis assumes removal of the unit caps and applies the density factors of the underlying zones as well as the maximum building height. • Realistic capacity of Site: Application of the maximum parcel coverage permitted based on the underlying multi-unit zoning. • Land Use Controls and Site Improvements: Incorporation of the Zoning Ordinance’s requirements for unit size and unit mix requirements which could reduce maximum residential yield. • Infrastructure Availability and Environmental Constraints: No application of environmental constraints and infrastructure constraints, per the discussion in Attachment 3. 8.B.i Packet Pg. 714 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) • Income levels: Some religious congregational leaders have indicated that there may be a need to provide some market rate units as part of housing redevelopment to ensure revenue. Therefore, these sites assume 50% of the total unit capacity could be accommodated at affordable low-income levels consistent with Program 4.B. With this methodology, Category 11 sites yielded an estimated housing capacity of 257 units and Category 12 sites yielded an estimated housing capacity of 96 units. Figure F-8 Example Capacity Calculation for Multifamily Parcel Site Attribute Zoning R2 Site Area (SF) 10,000 Typical Density Max # Stories 5 Density unlimited Realistic Capacity Parcel Coverage (Maximum % of site area) 0.45% Ground Floor Parcel Coverage Floor Area (GSF) 6,750 SF Land Use Controls Upper Story Parcel Coverage (% of ground floor parcel coverage) 90% Upper Story Floor Area [(6,750 SF*.90)*4 stories] = 24,300 SF Capacity Total Floor Area 31,050 SF Average GSF per Unit based on Unit Mix requirements 1,050 Max # of Units 30 All Remaining Sites – Categories 2, 3, 5, 6, 7, 8, 9, 10 The City of Santa Monica’s General Plan and Zoning Ordinance implements a Zoning Ordinance using floor area ratios (FAR) and heights to determine maximum development. The Housing Element includes Programs 1.F and 1.J, which would amend the Downtown Community Plan and Zoning Ordinance to establish new increased FARs and heights for housing projects. • Assumptions of Residential Probability vs Commercial  Development Trends – In the past decade, development in Santa Monica has trended towards new residential development rather than new commercial development (see graphic below). This is particularly true in the Downtown district, where housing projects are incentivized with greater FARs than commercial projects. Housing is in high demand in the southern California region, particularly in Santa Monica, which has seen a significant increase in development applications for residential and mixed use projects. This trend is expected to continue to increase during the timeframe of the Housing Element. The City allows standalone, multi-unit residential development as a use permitted by-right (without discretionary approvals) in most mixed-use, commercial, and industrial zones throughout the City. These zones also allow for a broad range of other nonresidential uses. For example, a review of project applications in the City revealed that approximately 15% of projects were commercial only while the 8.B.i Packet Pg. 715 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-23 overwhelming majority were residential or mixed-use with a large residential component. As such, the City developed assumptions for the realistic capacity for the likely mix of residential and non-residential (e.g., retail, office, hotel, employment) projects on commercially and mixed use zoned sites.  Market Conditions - The Housing Element will continue to incentivize commercial projects over residential projects across the City through Program 1.J, which will rezone the mixed-use and commercial zoning districts with higher maximum allowable FAR and height for housing projects. The FARs for housing projects will be at least 75% greater than the commercial FARs. Financial feasibility testing conducted by the City’s economic consultant indicates that with the new higher FARs and heights, housing projects will be more likely to occur than commercial projects. All the sites selected on the SSI will be rezoned with the new higher FARs and heights for housing projects. Therefore, it is highly likely that the sites will be redeveloped for residential rather than commercial. However, to be conservative,  Availability of Regulatory Incentives – The City has also most recently adopted regulatory incentives to encourage residential development, including adopting an Emergency Interim Ordinance on March 10, 2020, allowing 100% affordable housing projects and housing projects up to Tier 2 maximums that are subject to the protections of the Housing Accountability Act to be reviewed through a by-right administrative process. Program 1.A would make this streamlining provision permanent and expand the 4 7 7 8 4 10 19 17 23 15 18 44 2 4 3 1 3 6 2 2 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021# OF PROJECTSAPPLICATION YEAR Number of New Construction Commercial and Residential Projects by Application Year Residential Commercial 8.B.i Packet Pg. 716 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) applicability to other housing projects, including projects that are granted minor modifications. • Site Capacity Calculation To assess the housing capacity of the remaining Category 2-10 sites that have been identified for the SSI, the realistic capacity of the sites was assessed by applying the new rezoned heights and FAR for housing projects as listed in Programs 1.F and 1.J. The capacity analysis applies the following factors to calculate realistic capacity of sites within Category 2, 3,5, 6, 7, 8, 9, and 10:  Typical Density: The maximum allowable Tier 1 FARs for housing project is utilized for the site capacity analysis. This assumption is supported by past production trends which demonstrate that all residential developers will utilize the maximum FAR for residential and mixed-use projects, especially given high land cost and construction cost. Attachment 1 provides a list of approved and pending projects which show that almost all developers have proposed the maximum allowable FAR. Additionally, in the past (prior to the City’s 2017 adoption of the Downtown Community Plan), a couple of approved housing projects were processed as development agreements and therefore, proposed FARs exceeded the established maximum FARs in the Zoning Ordinance. For the purposes of this SSI analysis, Tier 2 FARs and Tier 3 FARs (which are greater than Tier 1) are not utilized since these are considered elective and require project developers to contribute community benefits.  Realistic capacity of Site: The capacity analysis assumes that 80% of the site area will be developed given setback and open space requirements based on a review of past housing projects.  Land Use Controls and Site Improvements: Incorporation of the Zoning Ordinance’s requirements for active ground floor use (for example retail) and unit mix requirements which could reduce maximum residential yield.  Commercial Likelihood: To account for the possibility that commercial use could be built, a 15% discount factor was applied to the capacity calculation. The 15% is based on the percentage of commercial projects vs residential projects that have occurred in the past 8 years. With this discount factor, the assumed capacity on the sites in the inventory is significantly lower than the actual housing development potential that is allowed on the sites per the Zoning Code and General Plan. For example, a 0.23 acre site that is zoned MUBL (Mixed Use Boulevard Low) with a max FAR of 2.25, has a maximum development potential of 22 units. However, this site is a mixed use-zoned site that allows 100% commercial projects, so to account for market feasibility and the potential for commercial development on the site, the inventory only counts 19 units on the parcel.  Infrastructure Availability and Environmental Constraints: No application of environmental constraints and infrastructure constraints, per the discussion in Attachment 3. 8.B.i Packet Pg. 717 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-25 Site Capacity Calculation Step 1: Apply Max FAR to site area Maximum Building Floor Area Step 2: Apply Site Coverage Factor (80% buildable) Realistic Buildable Floor Area Step 4: Apply Unit Mix Requirement Residential Floor Area Step 3: Assume Ground Floor Commercial Max # of Units Step 5: Apply Commercial Probability Factor Realistic Number of Units 8.B.i Packet Pg. 718 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-26 Figure F-9Example Capacity Calculation for Mixed Use and Commercial Parcel 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) 8,000 SF Ground Floor Use Retail Commercial Floor Area (NSF) 6,960 SF Capacity Upper Floor Uses Residential Residential Floor Area (NSF) 15,540 SF Average NSF per Unit based on Unit Mix requirements 688 Max # of Units 22 units Commercial Probability 15% 19 units Max Density Capacity Max # units/acreage of site (19 units/0.23 acres) = 83 units/acre The unit capacity that resulted with this calculation was spot checked against the typical densities of housing projects that have occurred in the past 10 years which is shown in the table below. Figure F-10 Typical Densities of Housing Projects by Zoning since LUCE City Areas Zoning District Housing Current Tier 1 FARs Parcel Sizes of Housing Projects (SF) % of Max FAR or Density1 Typical Densities Units/acre Bergamot BTV 1.75 35,000 92% 77-110 MUC 1.50 20,000 –145,000 95-100% 103-107 CCS 1.50 -- -- -- CAC 1.0 -- -- -- Blvd MUBL 1.50 7,500-203,000 88-150% 58-129 MUB 1.50 7,500 82-135% 52-197 GC SMB 1.25 13,000 100-125% 79-108 GC Lincoln/ Pico 1.50 14,000-32,000 92-150% 63-114 NC 1.50 15,000-30,000 100-137% 97-113 NC (Main, Montana) 1.00 -- -- -- Industrial IC Not -- -- -- Office OC Not -- -- -- Hospital HMU 1.50 -- -- -- Downtown LT 1.50 15,000-37,000 80-100% 87-192 NV 2.25 7,500-18,500 89-100% 116-349 BC 2.25 15,000 189% 160 TA 2.25 7,500 – 108,000 100-163% 161-390 8.B.i Packet Pg. 719 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-27 OT2 2.25 -- -- - WT 1.50 15,000 100% 122 Multi-family OF 1 unit/1500 sf 23,000-45,000 100% 41-80 OP2 1 unit/2000 sf 4,700-11,000 100% 22 OP3 1 unit/1500 sf 7,500-18,000 100% 29 OP4 1 unit/1250 sf 24,500 100% 35 R2 2,000 (or 4 total units)* 7,500-29,000 100% 22 R3 1,500 (or 5 total units)* 5,000-22,000 100% 29 R4 1,250 (or 6 total units)* 19,000 200% 74 Step 6: Assessing Appropriateness of Sites to Accommodate Lower Income levels For the City of Santa Monica, California Government Code Section 65583.2 states that a density of 30 units per acre is appropriate to enable lower income housing. In the City’s mixed-use and commercial districts, the Zoning Ordinance uses FAR rather than the density factor of units per acre. Therefore, to determine how many units per acre are possible on each SSI site, the number of units possible was first calculated based on the current Tier 1 FARs and new allowable FARs established in Programs 1.A and 1.J. The number of units was then translated into units/acre based on the parcel size of each site. Under current development standards and with the rezoning in Programs 1.F and 1.J, all the SSI sites that are zoned mixed-use or commercial can accommodate housing at greater densities than default density of 30 units per acre. Therefore, per HCD, all the mixed-use and commercial zoned sites are considered as having capacity for Low-Income units. Accommodating for Very Low- and Low-Income Housing The State uses the density allowed on a site as a “proxy” for determining whether a site can accommodate housing at lower-income levels. • Very Low- and Low-Income. State law establishes a “default density standard” of 30 units per acre for lower-income units in the City of Santa Monica. This means that if a site’s zoning allows for a density that is greater than 30 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households. Under current standards and with the rezoning in Programs 1.F and 1J, all the non-vacant, commercially zoned sites in the SSI can accommodate housing at greater densities than default density of 30 units. Therefore, per HCD, these sites can be identified as lower-income sites that have the capacity to accommodate lower-income units. • Moderate-income. Since all the identified SSI sites that are commercially zoned can accommodate lower- income units, the City has also determined that each of these sites can accommodate moderate-income housing since units affordable to lower-income households would also be affordable to moderate- income households. 8.B.i Packet Pg. 720 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-28 Step 7: Summary of Capacity to Accommodate the RHNA Without rezoning, the sites in the inventory can accommodate 7,596 units, resulting in a shortfall in total capacity which includes a shortfall in lower income capacity. While HCD requires that only candidate sites need to be rezoned to accommodate the shortfall, the HE includes programs to rezone entire districts, rather than individual sites. This approach is conservative and allows for the potential for candidate sites to be removed or sites to be added over the Housing Element cycle. With rezoning, the sites in the inventory can accommodate 13,600 units. All of the sites are non-vacant, and almost all are consolidated sites. The City will continue to administratively process lot tie agreements as part of the plan check process. After accounting for consolidation, only 4 sites identified in the SSI accommodate less than 15 units (inclusive of lower income). These sites are vacant parcels located in the R2/R3 zones which have a density limit of 4 to 5 units. Capacity to Accommodate the RHNA by Income Under Current Zoning Based on current FARs and densities in the City’s Zoning Ordinance, Bergamot Area Plan, and Downtown Community Plan, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate 7,596 units, a shortfall of 15% below the City’s RHNA of 8,895 units. This includes a shortfall of 1,109 units in all lower-income categories (ELI, VI, and LI) and 1,003 units in the moderate income category. Figure F-11 Summary of Capacity Analysis – Under Current Zoning Standards Total Capacity Capacity for Affordable Units # Units Total Affordable Capacity ELI VLI LI Moderate Category 1 Approved 2,205 637 127 162 148 148 Category 1 Pending 2,168 420 24 321 41 41 Category 4 City Sites 808 808 269 269 269 - Category 11 Religious Sites 29 0 0 0 0 0 Category 12 Parking Lots 61 0 0 0 0 0 All Remaining Categories 1,950 1,950 488 488 488 488 ADUs 376 249 56 8 162 23 Total 7,596 4,064 964 1,247 1,146 700 RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702 Shortfall (1,299) (2,104) (433) (150) (526) (1,003) -15% Capacity to Accommodate the Shortfall of Sites by Income Under Proposed Rezoning Programs 1.F and 1.J would amend the Zoning Ordinance, LUCE, and associated specific and area plans to allow for increased FARs and heights in the mixed use and commercial districts in the City in order to incentivize greater housing production. Additionally, Program 4.A would 8.B.i Packet Pg. 721 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-29 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. Under current zoning, the City has a shortfall of 1,109 lower income units. The City-owned sites can accommodate 1,880 lower income units, sufficient to meet this shortfall. To ensure compliance with Government Code section 65583.2, subdivisions (h) and (i), the HE includes Program 1K which requires that development on City-owned sites identified in the SSI must be at minimum 50% residential uses and flexibility to have 100% residential use. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. With the rezoning programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate at least 13,600 units providing a 53 percent buffer above the City’s RHNA of 8,895 units as shown in Figure F-8. The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing. The land inventory includes capacity for 2,521 extremely low, 2,891 very low income, 2,703 low income, and 1,901 moderate income units. Figure F-9 provides a summary breakdown of the SSI by zoning and income levels. Figure F-12 Summary of Capacity Analysis – With New Development Standards Under HE Rezoning Programs Total Capacity Capacity for Affordable Units # Units Total Affordable Capacity ELI VLI LI Moderate Category 1 Approved 2,205 637 127 347 148 15 Category 1 Pending 2,168 420 24 224 41 131 Category 4 City Sites 1,880 1,880 627 627 627 - Category 11 Religious Sites 257 130 32 32 32 34 Category 12 Parking Lots 96 9 - - 9 - All Remaining Categories 6,619 6,619 1,655 1,655 1,655 1,655 ADUs 376 249 56 8 162 23 Total 13,600 9,944 2,521 2,819 2,703 1,901 RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702 Buffer +4,705 +3,776 + 1,124 + 1,495 + 1,031 +199 53% 8.B.i Packet Pg. 722 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-30 Figure F-13 Summary of SSI Sites Capacity by Zoning (excludes Category 1 Approved/Pending Projects) City Areas Zoning District # Units Capacity Lower Income Moderate Income Above Moderate Bergamot Area Plan BTV 156 39 39 78 CCS 25 6 6 13 MUC 888 223 217 448 CAC 707 707 - - Blvd GC 967 254 225 488 MUB 1,334 334 325 675 MUBL 2,368 604 574 1,190 NC 157 40 35 82 Downtown NV 381 233 48 100 BC 285 285 - - LT 270 72 63 135 Industrial IC 54 14 13 27 Office Campus OC 59 15 13 31 Multifamily R2 306 109 26 171 R3 655 604 8 43 R4 99 99 - - Total 8,852 3,674 1,626 3,552 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 approximately 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 of 8,895 units is more than twice than the planned amount of units anticipated under City plans and zoning. 8.B.i Packet Pg. 723 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-31 Step 8: Assessment of Sites to Affirmatively Furthering Fair Housing This section analyzes the distribution of sites in the inventory by fair housing metrics and provides a comparison to the distribution of existing households in the City within each census tract. A disproportionately high number of units are within the mid-City and Downtown area, which reflects the City’s General Planning strategy of focusing new housing in areas served by transit, consistent with planning best practices and state guidelines for reducing greenhouse gas emission emissions. Census tracts in the mid-City and Downtown have a higher share of low-income units within it compared to other unit income categories. In contrast, a relatively low share of all units, including low-income units, are identified within the North of Montana and Northeast neighborhoods, which are discussed in Chapter 2 as being higher-resourced, whiter, and more wealthy. These areas are being underrepresented in the SSI given limited opportunity for high-density growth. Additional units are anticipated in these areas through lower-scale development such as Accessory Dwelling Units or “missing middle” housing, but are not reflected on the site inventory. The R2/R3/R4 zones also has a lower share of units allocated to it compared to its proportion of existing housing stock, but this reflects the city’s focus on preserving existing housing, particularly rent-controlled housing. Effects of Sites on Segregation and Integration The City’s suitable sites inventory was evaluated to determine how sites planned for future development could further affect patterns of segregation and integration relative to racial concentrations and income levels. As previously discussed in Chapter 2, the City is generally more homogenous than the other nearby cities in Los Angeles. Within Santa Monica, there are more predominant populations of Hispanic/Latino residents in the Pico Neighborhood while the remaining areas of the City are predominantly White. Most of the identified sites are in the Downtown and in Mid-City, which have predominantly White households. The table below shows that the census tracts with most of the available lower-income sites identified in the SSI are in areas with white predominance. About 11 percent of the lower-income capacity is identified in census tracts with a Hispanic/Latino majority. The distribution of low income and moderate unit capacities correspond generally to existing racial patterns. Therefore, the sites would not exacerbate ongoing patterns of segregation by race in the City. Figure F-14 Sites Distribution by Racial Predominance Racial Predominance White Hispanic Total City Existing % 78% 13% SSI Lower Income Units 89% 11% SSI Moderate Income Units 88% 12% SSI Above Moderate Unit 96% 4% 8.B.i Packet Pg. 724 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-32 Map F-2 Distribution of Sites by Racial Predominance 8.B.i Packet Pg. 725 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-33 Map F-3 Site Capacity Increases by Racial Predominance Relative to segregation based on household income, the sites are distributed across a number of census blocks with various median household income levels (Map F-3). The census tracts with most of the available lower-income SSI sites have lower median income levels. This is mostly due to the availability of land suitable for higher density development along the I-10 freeway such as the Downtown and Bergamot Plan areas. Development on the identified sites in the inventory has the potential to add housing of all income levels, including low-income housing. There are 115 sites identified in the census tracts with more than 55% low- to moderate-income populations, which include the Downtown, Pico Neighborhood and the Bergamot Area. While development of low-income housing on these sites could moderately exacerbate ongoing patterns of segregation, it is very unlikely that all these sites would develop as low-income particularly given the higher land cost in the Downtown. Furthermore, these sites are located in areas that are the most accessible to the Metro E light-rail stations, jobs, and other resources including schools (Santa Monica College). Therefore, while the Sites Inventory does not actively improve conditions, the sites would not exacerbate ongoing patterns of segregation by race in the City. 8.B.i Packet Pg. 726 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-34 Figure F-15 Sites Distribution by Median Income Map F-4 Distribution of Sites by Median Household Income Median Income Less than $69K $69K to $81K $81K to $107 $107 to $136,500 > $136,500 Existing Citywide Households 21% 4% 42% 30% 3% SSI Lower Income Units 54% 8% 26% 12% 0% SSI Moderate Income Units 59% 11% 17% 13% 0% SSI Above Moderate Unit 65% 3% 14% 18% 0% 8.B.i Packet Pg. 727 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-35 Map F-5 Site Capacity Increases by Median Income Figure F-16 Sites Distribution by Lower Moderate Income Households Lower Moderate Income Households 0-25% 25.1-35% 35.1% to 45% 45.1% to 55% 55.1% + Existing Citywide Households 14% 13% 52% 4% 17% SSI Lower Income Units 2% 9% 35% 13% 41% SSI Moderate Income Units 2% 10% 28% 16% 43% SSI Above Moderate Unit 4% 14% 17% 6% 60% 8.B.i Packet Pg. 728 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-36 Map F-6 Distribution of Sites by Low to Moderate Income Households 8.B.i Packet Pg. 729 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-37 Map F-7 Site Capacity Increases by Low to Moderate Households Effects of Sites on Displacement Potential and Disproportionate Housing Needs Reflecting the geographic analysis above, the tracts designated as more stable or exclusive, which are primarily located in the North of Montana and Northeast neighborhoods, are underrepresented in the inventory. While not large in numbers, the sites inventory do show some unit capacity in these areas, representing a small step towards opening up these areas to new housing at all income levels and reducing gentrification and displacement pressure from other areas in the City. Additionally, the sites inventory show a greater proportion of lower income and moderate income capacity within areas that are classified as “advanced gentrification” or “at risk”. This has a greater potential to protect vulnerable residents from being displaced under changing market pressures and ensure that these areas do not become exclusive. The identified sites would not exacerbate disproportionate housing needs. As described in Chapter 2, the significant contributing factors to disproportionate housing needs in the City are: displacement due to economic pressures, high housing cost, lack of affordable accessible housing, and land/zoning laws that limit density. The sites would not contribute to these factors but rather would result in improved conditions since housing development on these sites would 8.B.i Packet Pg. 730 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-38 minimize displacement of existing rent controlled units,2 provide new housing choice and affordability to high opportunity areas, produce new inclusionary affordable units as part of the City’s Affordable Housing Production Program, and contribute to increased residential density. Figure F-16 Sites Distribution by Displacement Potential Displacement Typology Advanced Gentrification Stable Moderate At Risk Becoming Exclusive Stable Exclusive Existing Citywide Households 10% 17% 35% 17% 21% SSI Lower Income Units 25% 25% 31% 15% 3% SSI Moderate Income Units 29% 22% 37% 9% 3% SSI Above Moderate Unit 16% 48% 17% 4% 15% 2 With the exception of two sites, sites that have existing residential uses included in the SSI consist of approved/pending housing projects. The other two sites were included in the SSI because of identified developer interest. All remaining sites in the inventory are developed with commercial uses or surface parking. 8.B.i Packet Pg. 731 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-39 Map F-8 Sites Capacity Increases by Displacement Potential Effects of Sites on Access to Opportunity As shown in the Figure F-9 below, the identified sites would increase housing opportunities throughout the City, furthering fair housing in areas of high resources and opportunity. The identified sites would have access to low-cost transportation, jobs, and neighborhood-serving commercial uses that serve residential. Additionally, almost all of the identified sites (with the exception of the approved/pending projects) are on properties that are developed with underutilized commercial buildings and/or parking lots and therefore, would generally, minimize displacement potential. With the proposed development standards in Program 1.J, the identified sites would all have sufficient densities to accommodate lower-income units. Additionally, the City’s Affordable Housing Production Program requires housing projects to include inclusionary, affordable units, thereby expanding housing opportunities for lower- income households. 8.B.i Packet Pg. 732 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-40 Figure F-9 Map of Sites within High Resource Areas In terms of environmentally healthy areas, the census tracts that represent the North of Montana and Northeast neighborhoods generally have a higher (more healthy) environmental index than the remaining areas of the City. Similar to the discussion above, these areas are underrepresented in the sites inventory as they have the least housing capacity. Figure F-17 Sites Distribution by Environmental Health Index Least Healthy Most Healthy Environmental Health Index 0 1 to 4 5 to 6 7 to 8 9 to 19 Existing Citywide Households 37% 34% 10% 16% 3% SSI Lower Income Units 27% 58% 11% 4% 0% SSI Moderate Income Units 15% 70% 11% 4% 0% SSI Above Moderate Unit 49% 31% 4% 16% 0% 8.B.i Packet Pg. 733 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-41 Map F-10 Sites Capacity Increases by Environmental Health Index 8.B.i Packet Pg. 734 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-42 Attachment 1 – Approved and Pending Housing Projects The table below provides a list of approved (not yet constructed) and housing projects pending review in the City of Santa Monica. All projects are located on non-vacant sites that are developed with existing buildings or surface parking lots. All housing projects with 4 or more units are required to meet the inclusionary requirements in the City’s Affordable Housing Production Program, Santa Monica Municipal Code Chapter 9.64, providing either on-site or off-site affordable housing units. These affordable housing units (Extremely Low Income, Very Low Income, Low Income, and Moderate) are required to be deed restricted for a term of no less than 55 years. Table 1 - Approved and Pending Housing Projects as Broken Down by Affordability APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 12/7/2010 10FIM002 2 Unit Multifamily 1021 Grant Street market rate 2 Approved R2 6/1/2015 15ARB-0038 3-Unit Condos 610 California Ave market rate 3 Approved R2 5/11/2016 05TM-009 15-Unit Condominium 1211 12th St market rate 9 Approved R3 5/11/2016 05TM-009 15-Unit Condominium 1211 12th St VLI 4 Approved R3 6/1/2016 16ENT-0011 5-Unit Condos 1840 17th St LI 1 Approved R2 6/1/2016 16ENT-0011 5-Unit Condos 1840 17th St market rate 4 Approved R2 7/13/2016 16ENT-0072 3-Unit Condos 1422 20th St market rate 3 Approved R2 7/13/2016 16ENT-0071 3-Unit Condos 1420 20th St market rate 3 Approved R2 6/21/2017 16ENT-0041 3-Unit Townhomes 1121 22nd St market rate 3 Approved R2 6/21/2017 17ENT-0027 3-Unit Condos 1649 Centinela Ave market rate 3 Approved R2 10/18/2017 15ENT-0266 Mixed Use 1430-1444 Lincoln Blvd market rate 100 Approved MUB 10/18/2017 17ENT-0105 3-Unit Condos 1900 20th St market rate 3 Approved R2 11/28/2017 16ENT-0143 Mixed Use 1313-1325 6th St market rate 64 Approved NV 12/6/2017 16ENT-0098 Mixed Use (Upscale furniture building) 1437-1443 Lincoln Blvd LI 6 Approved MUB 12/6/2017 16ENT-0115 Mixed Use DRP 601-611 Wilshire Blvd market rate 37 Approved MUB 12/6/2017 16ENT-0115 Mixed Use DRP 601-611 Wilshire Blvd ELI 3 Approved MUB 8.B.i Packet Pg. 735 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-43 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 12/6/2017 16ENT-0098 Mixed Use (Upscale furniture building) 1437-1443 Lincoln Blvd market rate 34 Approved MUB 1/1/2018 17ENT-0286 3-Unit Condos 2512 7th St market rate 3 Approved OP2 2/7/2018 16ENT-0102 Mixed Use 1318 Lincoln Blvd market rate 39 Approved MUB 2/7/2018 16ENT-0102 Mixed Use 1318 Lincoln Blvd ELI 4 Approved MUB 4/4/2018 11DEV014 Mixed-Use DRP 1650-1660 Lincoln Blvd ELI 8 Approved MUB 4/4/2018 11DEV014 Mixed-Use DRP 1650-1660 Lincoln Blvd market rate 90 Approved MUB 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica Blvd VLI 5 Approved MUBL 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica Blvd LI 2 Approved MUBL 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica Blvd market rate 44 Approved MUBL 7/5/2018 18ENT-0199 Mixed Use (Fritto misto) 601-609 Colorado Ave market rate 104 Approved TA 7/5/2018 18ENT-0199 Mixed Use (Fritto misto) 601-609 Colorado Ave Moderate 36 Approved TA 7/27/2018 18ENT-0077 Condos 1443 18th St market rate 11 Approved MUBL 8/1/2018 17ARB-0043 Apartments 1754 10th St market rate 3 Approved R2 10/12/2018 18ARB-0221 100% Affordable Housing 1342 Berkeley ELI 8 Approved R2 11/7/2018 18ENT-0005 Mixed Use (bowling alley) 216-248 Pico Blvd VLI 9 Approved MUBL 11/7/2018 18ENT-0005 Mixed Use (bowling alley) 216-248 Pico Blvd market rate 93 Approved MUBL 11/7/2018 18ENT-0005 Mixed Use (bowling alley) 216-248 Pico Blvd LI 3 Approved MUBL 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St LI 7 Approved TA 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St market rate 14 Approved TA 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St SRO 38 Approved TA 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St SRO 80 Approved NV 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St market rate 20 Approved NV 8.B.i Packet Pg. 736 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-44 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St LI 14 Approved NV 1/31/2019 19ENT-0041 SRO Mixed Use Project with Commercial 1338-1342 5th St ELI 6 Approved NV 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St ELI 4 Approved TA 3/6/2019 18ENT-0182 Mixed Use 1618 Stanford market rate 43 Approved MUC 3/6/2019 18ENT-0182 Mixed Use 1618 Stanford ELI 4 Approved MUC 4/18/2019 223 Auto Dealership 1802 Santa Monica Blvd market rate 0 Approved GC 4/18/2019 17ENT-0297 Mixed Use 1707 Cloverfield market rate 58 Approved BTV 4/18/2019 17ENT-0297 Mixed Use 1707 Cloverfield ELI 5 Approved BTV 4/23/2019 15ENT-0300 Mixed Use Project 1828 Ocean Ave VLI 16 Approved OF 4/23/2019 15ENT-0297 Mixed Use Project 1921 Ocean Front Walk market rate 22 Approved OF 4/23/2019 15ENT-0300 Mixed Use Project 1828 Ocean Ave market rate 67 Approved OF 5/15/2019 15ENT-0310 21-Unit Condominium/2020 Virginia 2002-2008 21st St market rate 19 Approved R2 6/14/2019 19ENT-0054 3-Unit Condos 1802 Delaware Ave market rate 3 Approved R2 7/9/2019 19ENT-0130 3-Unit Condos 122 Strand St market rate 3 Approved OP3 9/4/2019 17ENT-0298 Mixed Use 2906-2918 Santa Monica Blvd market rate 42 Approved MUBL 9/4/2019 17ENT-0298 Mixed Use 2906-2918 Santa Monica Blvd ELI 4 Approved MUBL 9/6/2019 19ENT-0128 Addition of 4 units 1410 5th St market rate 4 Approved TA 10/2/2019 19ENT-0258 3-Unit Condos 949 10th St market rate 3 Approved R2 10/4/2019 18ENT-0129 Mixed Use 100% affordable housing 711 Colorado Ave ELI 17 Approved TA 10/4/2019 18ENT-0129 Mixed Use 100% affordable housing 711 Colorado Ave Moderate 39 Approved TA 10/21/2019 18ENT-0211 Mixed Use 1425-1427 5th St market rate 92 Approved TA 8.B.i Packet Pg. 737 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-45 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 11/7/2019 18ENT-0244 Mixed Use 3223 Wilshire Blvd market rate 49 Approved MUB 11/7/2019 18ENT-0244 Mixed Use 3223 Wilshire Blvd ELI 4 Approved MUB 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St Moderate 8 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St ELI 5 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St VLI 5 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St LI 7 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St market rate 75 Approved TA 11/14/2019 186 Commercial building 3280 Lincoln Blvd market rate 1 Approved GC 12/4/2019 16ENT-0118 Mixed Use 3030 Nebraska Ave ELI 9 Approved MUC 12/4/2019 16ENT-0118 Mixed Use 3030 Nebraska Ave market rate 174 Approved MUC 12/9/2019 19ENT-0425 3-Unit Condos 918 5th St market rate 3 Approved R2 12/19/2019 19ENT-0256 Mixed Office/SFR 1348 10th St market rate 1 Approved GC 1/15/2020 19ENT-0267 Condos 1432 17th St market rate 6 Approved R2 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St market rate 32 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St LI 14 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St SRO 79 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St ELI 9 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave SRO 35 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave market rate 14 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave LI 6 Approved TA 2/13/2020 18ENT-0206 SRO Project with Commercial 701 Colorado Ave ELI 4 Approved TA 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St market rate 8 Approved NV 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St SRO 35 Approved NV 8.B.i Packet Pg. 738 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-46 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St Moderate 3 Approved NV 3/23/2020 18ENT-0283 SRO Mixed Use Project with Commercial 1323 5th St LI 6 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St ELI 3 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St market rate 35 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St SRO 8 Approved NV 3/23/2020 19ENT-0040 SRO Mixed Use Project with Commercial 1437 6th St LI 6 Approved NV 4/4/2020 20ENT-0020 100% Affordable Housing 1819 Pico Blvd LI 47 Approved NC 4/4/2020 20ENT-0020 100% Affordable Housing 1819 Pico Blvd market rate 1 Approved NC 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St VLI 10 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St Moderate 16 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St LI 14 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St ELI 10 Approved TA 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St Moderate 13 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St LI 10 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St VLI 7 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St ELI 7 Approved NV 4/15/2020 20BLD-1044 New Duplex 2409 28th St market rate 2 Approved R2 4/22/2020 18ENT-0229 Mixed Use (Performance Bicycles) 501 Broadway market rate 75 Approved TA 4/22/2020 18ENT-0229 Mixed Use (Performance Bicycles) 501 Broadway VLI 19 Approved TA 4/30/2020 19ENT-0085 Mixed Use 1448 7th St Moderate 1 Approved NV 4/30/2020 19ENT-0085 Mixed Use 1448 7th St LI 1 Approved NV 4/30/2020 19ENT-0085 Mixed Use 1448 7th St market rate 6 Approved NV 5/20/2020 20ENT-0063 3-Unit Condos 2425 20th St market rate 3 Approved R2 8.B.i Packet Pg. 739 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-47 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 5/30/2020 20ENT-0045 5-Unit Condos 1949 17th St LI 1 Approved R2 5/30/2020 20ENT-0045 5-Unit Condos 1949 17th St market rate 4 Approved R2 6/15/2020 20ARB-0138 duplex 2714 Highland market rate 2 Approved OP2 6/17/2020 20ENT-0073 3-Unit Condos 817 16th St market rate 3 Approved R2 7/20/2020 20ENT-0019 3-Unit Condos adjacent to Landmark 2501 2nd St market rate 3 Approved OP2 8/24/2020 20ENT-0079 100% Affordable Housing 1413 Michigan Ave VLI 57 Approved NC 8/24/2020 20ENT-0079 100% Affordable Housing 1413 Michigan Ave market rate 1 Approved NC 9/13/2020 11DEV-003 Miramar Hotel Project DA 1133 Ocean Ave market rate 60 Approved OT - ELS 10/21/2020 20ENT-0164 Condos 1510 Franklin St market rate 3 Approved R2 11/16/2020 20ENT-0011 Mixed Use 1512 Euclid St market rate 8 Approved MUBL 11/16/2020 20ENT-0011 Mixed Use 1512 Euclid St LI 2 Approved MUBL 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd market rate 24 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd VLI 1 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd LI 1 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd Moderate 3 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd ELI 1 Approved LT 12/14/2020 20ENT-0280 2-Unit Condos 1514 Princeton market rate 2 Approved R2 12/14/2020 18ENT-0243 remodel to 5 of 6 live/work condo 1643 12th St market rate 0 Approved IC 12/22/2020 20ARB-0213 Triplex addition to SFR 1902 Euclid St market rate 3 Approved R2 1/19/2021 20ENT-0238 100% affordable housing for Miramar 1127-1129 2nd St VLI 21 Approved WT 1/19/2021 20ENT-0238 100% affordable housing for Miramar 1127-1129 2nd St ELI 6 Approved WT 1/19/2021 20ENT-0238 100% affordable housing for Miramar 1127-1129 2nd St LI 15 Approved WT 1/20/2021 19ENT-0235 3-Unit Condos on Landmark property 1527 17th St market rate 3 Approved R2 8.B.i Packet Pg. 740 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-48 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 2/23/2021 20ENT-0293 6 unit condos 1319 Centinela Ave market rate 6 Approved R2 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway market rate 206 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway ELI 17 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway VLI 17 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway LI 26 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway Moderate 29 Approved TA 2/28/2013 13DEV004 Hotel/Mixed Use DA (Ocean Avenue Project) 101-129 Santa Monica Blvd market rate 82 Pending OT - ELS 2/28/2013 13DEV004 Hotel/Mixed Use DA (Ocean Avenue Project) 101-129 Santa Monica Blvd VLI 18 Pending OT - ELS 2/11/2021 21ENT-0035 Mixed-Use 1101 Wilshire Blvd VLI 11 Pending MUB 2/11/2021 21ENT-0035 Mixed-Use 1101 Wilshire Blvd market rate 82 Pending MUB 1/8/2013 13DEV001 Mixed Use 1431 Colorado Ave market rate 42 Pending MUBL 1/8/2013 13DEV001 Mixed Use 1431 Colorado Ave LI 8 Pending MUBL 5/22/2018 18ENT-0136 Mixed Use 1437 7th St VLI 13 Pending NV 5/22/2018 18ENT-0136 Mixed Use 1437 7th St market rate 52 Pending NV 4/13/2021 21ENT-0091 Mixed Use 1524 7th St affordable housing** 20 Pending TA 4/13/2021 21ENT-0091 Mixed Use 1524 7th St market rate 80 Pending TA 8/6/2020 20ENT-0196 Apartments 1546 9th St market rate 9 Pending R3 8/4/2016 16ENT-0112 3-Unit Condos 1665 Appian Way market rate 3 Pending OF 3/31/2020 20BLD-1218 New addition of 2 units 1958 20th St market rate 2 Pending R2 4/13/2021 21ENT-0093 Mixed Use 3025 Olympic Blvd market rate 307 Pending MUC 4/13/2021 21ENT-0093 Mixed Use 3025 Olympic Blvd affordable housing** 38 Pending MUC 11/27/2018 18ENT-0362 Mixed Use 525 Colorado Ave market rate 30 Pending TA 11/27/2018 18ENT-0362 Mixed Use 525 Colorado Ave VLI 10 Pending TA 1/8/2013 13DEV002 Mixed Use 603 Arizona Ave market rate 39 Pending NV 1/8/2013 13DEV002 Mixed Use 603 Arizona Ave VLI 8 Pending NV 8.B.i Packet Pg. 741 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-49 APPROVAL OR APPLICATION DATE PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL* UNITS PROJECT STATUS ZONING 10/2/2020 20ENT-0234 3-Unit Condos 734 12th St market rate 3 Pending NC 9/12/2019 19ENT-0340 Mixed Use Building 825 Santa Monica Blvd market rate 41 Pending GC 9/12/2019 19ENT-0340 Mixed Use Building 825 Santa Monica Blvd VLI 7 Pending GC * Affordable units are required to be deed restricted for a term of at least 55 years. **Affordability level to be determined 8.B.i Packet Pg. 742 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-50 Table 2 - Approved and Pending Projects by Age of Building, Improvements Land Ratio (ILR), Existing Use Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR A 18ENT-0244 4266001046 MUB 6522 parking lot for Aah's 0 0.000 A 18ENT-0244 3223 WILSHIRE BLVD 4266001045 MUB 13063 one-story Aah's retail store 1955 0.108 AA 1431 LINCOLN BLVD 4282027019 LT 7512 one-story comic book store 1983 0.130 AA 20ENT-0163 1427 LINCOLN BLVD 4282027020 LT 7501 one-story comic book store 1956 0.024 AC 22ENT-0037 1527 LINCOLN BLVD 4282028019 LT 7494 former tile store; vacant retail building 1945 0.310 AC 22ENT-0037 1533 LINCOLN BLVD 4282028018 LT 7510 former tile store; vacant retail building 1952 0.429 AM 4289019022 MUBL 5601 vacant one story bowling alley 0 0.000 AM 216 PICO BLVD 4289019023 MUBL 5613 vacant one story bowling alley 1962 0.057 AM 228 PICO BLVD 4289019021 MUBL 5621 vacant one story bowling alley 0 0.000 AM 248 PICO BLVD 4289019017 MUBL 5590 vacant one story bowling alley 0 0.000 AM 254 PICO BLVD 4289019016 MUBL 5611 vacant one story bowling alley 0 0.000 AM 21ENT-0219 234 PICO BLVD 4289019019 MUBL 28008 vacant one story bowling alley 1959 0.096 AO 19ENT-0041 1342 5TH ST 4291011019 NV 7509 parking lot 0 0.000 AO 19ENT-0041 1342 5TH ST 4291011020 NV 7485 parking lot 0 0.000 AR 19ENT-0039 1445 5TH ST 4291019016 TA 7498 vacant one-story multitenant retail building 1946 0.016 AR 19ENT-0039 1445 5TH ST 4291019017 TA 7511 parking lot next to vacant retail 0 0.002 AT (blank) 4291021009 LT 3751 parking lot 0 0.000 AT 1438 LINCOLN BLVD 4291021008 LT 3752 parking lot 0 0.000 AT 1444 LINCOLN BLVD 4291021010 LT 7491 parking lot 0 0.000 AT 15ENT-0266 1430 LINCOLN BLVD 4291021006 LT 7507 parking lot 0 0.000 AT 15ENT-0266 1432 LINCOLN BLVD 4291021007 LT 7492 parking lot 0 0.000 AU 1500 LINCOLN BLVD 4291022003 LT 7500 one-story Von's with parking lot 0 0.003 AU 1500 LINCOLN BLVD 4291022025 LT 22450 one-story Von's with parking lot 0 0.003 AU 1518 LINCOLN BLVD 4291022004 LT 7500 one-story Von's with parking lot 0 0.003 AU 1526 LINCOLN BLVD 4291022005 LT 7500 one-story Von's with parking lot 0 0.003 AU 1534 LINCOLN BLVD 4291022006 LT 7500 one-story Von's with parking lot 0 0.003 AU 20ENT-0241 710 BROADWAY 4291022026 TA 52450 one-story Von's with parking lot 1995 0.179 AX 22ENT-0011 1553 4TH ST 4291025028 TA 7474 Vacant bank site across DT station 0 0.001 AX 22ENT-0011 1555 4TH ST 4291025012 TA 7497 Vacant bank site across DT station 1973 0.013 AY 20ENT-0238 1127 2ND ST 4292021010 WT 7517 parking lot 0 0.003 8.B.i Packet Pg. 743 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-51 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR AY 20ENT-0238 1129 2ND ST 4292021009 WT 7490 parking lot 0 0.003 BG 22ENT-0006 1152 21ST ST 4276007021 MUB 3491 rear parking lot for NOMA sushi and Veggie grill (2025 wilshire) 0 0.019 BG 22ENT-0006 2025 WILSHIRE BLVD 4276007027 MUB 14987 one story Veggie grill 1969 0.096 BL 1115 WILSHIRE BLVD REAR 4281020029 MUB 13949 rear parking lot 1927 0.181 BL 21ENT-0035 1101 WILSHIRE BLVD 4281020012 MUB 8559 one-story JP bar 1922 0.191 BN 1819 SANTA MONICA BLVD 4276029011 GC 14986 Honda auto inventory lot 0 0.000 BN 21ENT-0227 1350 19TH ST 4276029010 GC 7495 Honda auto inventory lot 0 0.001 BN 21ENT-0229 1342 19TH ST 4276029009 R2 8991 Honda auto inventory lot 0 0.001 BO 2911 SANTA MONICA BLVD 4267011022 MUBL 6501 one story retail building 1926 0.200 BO 16ADM-0050 1347 YALE ST 4267011021 MUBL 3266 one-story retail building 1926 0.248 BO 16ADM-0050 1349 YALE ST 4267011020 MUBL 9368 one story multitenant retail building, two story apartment building w parking lot 1923 0.111 BP 1543 LINCOLN BLVD 4282028010 LT 7497 one story vacant auto repair 1947 0.128 BP 1547 LINCOLN BLVD 4282028009 LT 7499 one story vacant auto repair 1999 0.435 BP 22ENT-0037 1537 LINCOLN BLVD 4282028011 LT 7496 one story vacant auto repair 1945 0.245 BS 15ENT-0310 2002 21ST ST 4274026001 R2 7533 one-story apartments 0 0.101 BS 15ENT-0310 2008 21ST ST 4274026003 R2 7130 one-story apartments 0 0.107 BT 19ENT-0328 1840 14TH ST 4283030018 NC 7524 100% affordable housing under construction 1962 0.258 BT 19ENT-0328 1844 14TH ST 4283030017 NC 7485 100% affordable housing under construction 1922 0.496 BT 19ENT-0328 1848 14TH ST 4283030016 NC 7525 100% affordable housing under construction 1968 0.003 BU 19ENT-0042 1415 5TH ST 4291019021 TA 7494 two story multitenant retail building 1980 0.000 BU 19ENT-0042 1423 5TH ST 4291019020 TA 7525 two story multitenant retail building 1966 0.000 BV 18ENT-0210 1543 7TH ST 4291022014 TA 7500 parking lot 1990 1.725 BV 18ENT-0210 1547 7TH ST 4291022013 TA 7500 parking lot 0 0.000 BW 1547 6TH ST 4291023011 TA 7505 one-story multi-tenant building, restaurant, office 1986 0.000 BW 18ENT-0199 609 COLORADO AVE 4291023010 TA 14982 one-story multi-tenant building, restaurant, office 1984 0.167 BX 16ENT-0115 601 WILSHIRE BLVD 4292005029 WT 10010 vacant one and two story buildings 1977 0.071 BX 16ENT-0115 611 WILSHIRE BLVD 4292005026 WT 4997 vacant one and two story buildings 1922 0.143 BY 11DEV014 1650 LINCOLN BLVD 4290002008 LT 16220 one-story retail, boxing fitness building 1954 0.000 BY 11DEV014 1660 LINCOLN BLVD 4290002006 LT 7570 one-story retail, boxing fitness building 1954 0.000 BZ 16ENT-0098 1437 LINCOLN BLVD 4282027018 LT 7485 one-story retail building 1949 0.000 BZ 16ENT-0098 1443 LINCOLN BLVD 4282027028 LT 7510 one-story retail 1959 0.000 8.B.i Packet Pg. 744 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-52 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR C 22ENT-0007 2501 WILSHIRE BLVD 4276001026 MUB 14319 one-story commercial building with multiple retailers; corner parcel; with rear residential parking lot 1951 0.138 C 22ENT-0007 2515 WILSHIRE BLVD 4276001025 MUB 6164 one-story multi-tenant commercial building 1941 0.486 C 22ENT-0007 2525 WILSHIRE BLVD 4276001027 MUB 10347 one-story commercial building, Starbucks, Urgent Care, Postal Store; common ownership; corner parcel with rear residential parking 1970 0.435 CA 16ENT-0143 1313 6TH ST 4291009021 NV 15010 parking lot 0 0.000 CA 18ENT-0283 1323 5TH ST 4291010029 NV 7512 parking lot 0 0.000 CH 22ENT-0014 1902 WILSHIRE BLVD 4276013020 MUB 4989 one story retail/restaurant building (Thai dishes, salon, medical office) 1939 0.328 CH 22ENT-0014 1908 WILSHIRE BLVD 4276013030 MUB 24993 one-story retail/restaurant building (Thai dishes, salon, medical office) 1925 0.201 CI 21ENT-0228 1921 WILSHIRE BLVD 4276008014 MUB 15015 one-story retail building (GAP) 1975 0.406 CI 21ENT-0228 1933 WILSHIRE BLVD 4276008015 MUB 10520 one-story retail building (GAP) 1958 0.333 E 20ENT-0311 2906 SANTA MONICA BLVD 4267018026 MUBL 21314 vacant two story office 1969 0.792 E 20ENT-0311 2918 SANTA MONICA BLVD 4267018003 MUBL 7021 vacant parking lot 1965 0.117 P 21ENT-0226 1347 18TH ST 4276029026 GC 7512 Honda dealership with surface inventory 1969 0.001 P 21ENT-0226 1801 SANTA MONICA BLVD 4276029048 GC 14984 Honda dealership with surface inventory 1953 0.018 S 825 SANTA MONICA BLVD 4282010012 GC 7505 Toyota dealership 0 0.000 S 21ENT-0261 825 SANTA MONICA BLVD 4282010013 GC 7491 Toyota dealership 1951 0.010 S 21ENT-0261 825 SANTA MONICA BLVD 4282010014 GC 7502 Toyota dealership 1951 0.002 05TM-009 1211 12TH ST 4282005053 R3 15008 one story apartment buildings 0 0.000 09FIM003 1434 14TH ST 4282022027 R3 7500 (blank) 1925 0.221 10FIM002 1021 GRANT ST 4284015017 R2 6491 (blank) 1928 0.421 11DEV-003 1133 OCEAN AVE 4292028001 OT 190963 Miramar Hotel 1938 0.532 13DEV001 1431 COLORADO AVE 4282034009 MUBL 22485 one-story marble store 1923 0.009 13DEV004 129 SANTA MONICA BLVD 4291014024 BC 30000 parking lot 1871 0.019 15ARB-0038 610 CALIFORNIA AVE 4292005022 R2 5002 (blank) 1912 0.209 15ENT-0297 4289025005 OF 23222 vacant parking lot next to Casa del mar hotel 0 0.000 15ENT-0300 4290020045 OF 45314 parking lot 0 0.002 16ENT-0011 1840 17TH ST 4283032008 R2 7490 (blank) 1955 0.250 16ENT-0041 1121 22ND ST 4276005022 R2 6114 (blank) 1924 0.029 16ENT-0060 (blank) 4275006026 HMU 6242 parking lot owned by Saint John's 0 0.003 16ENT-0102 1318 LINCOLN BLVD 4291008025 LT 15003 parking lot 0 0.000 8.B.i Packet Pg. 745 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-53 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR 16ENT-0112 1665 APPIAN WAY 4290018018 R3 4430 residential 1914 0.375 16ENT-0118 (blank) 4268010017 MUC 64297 one-story light industrial/creative office 0 0.002 16ENT-0205 2102 5TH ST 4289010006 OP2 5661 (blank) 1911 0.024 17ARB-0043 1754 10TH ST 4283018002 R2 7511 (blank) 1922 0.250 17ENT-0027 1649 CENTINELA AVE 4268006016 R2 6313 single family dwelling 1948 0.250 17ENT-0048 436 PIER AVE 4287027065 OP2 7480 (blank) 1911 0.250 17ENT-0105 1900 20TH ST 4274019056 R2 7575 single family dwelling 0 0.000 17ENT-0286 4287003017 OP2 7973 (blank) 0 0.000 17ENT-0297 1707 CLOVERFIELD BLVD 4268014013 BTV 76562 parking lot of Extra Space sotrage 1955 0.658 18ARB-0221 1342 BERKELEY ST 4267012009 R2 7858 Vacant lot 0 0.000 18ENT-0077 1443 18TH ST 4275010016 MUBL 7500 Vacant lot 1957 0.004 18ENT-0129 711 COLORADO AVE 4291022012 TA 7500 construction staging site 0 0.000 18ENT-0136 1437 7TH ST 4291021029 NV 14991 three story office building 1983 1.223 18ENT-0182 1618 STANFORD ST 4268002005 MUC 20016 one story office building 1950 0.201 18ENT-0200 1238 7TH ST 4291006006 NV 7500 one-story office 1912 0.001 18ENT-0206 1557 7TH ST 4291022021 TA 7500 one story brick office building 1959 0.028 18ENT-0211 1427 5TH ST 4291019019 TA 15007 one-story vacant retail building 1954 0.000 18ENT-0212 1514 7TH ST 4291023002 TA 7504 construction staging parking site 0 0.000 18ENT-0229 501 BROADWAY 4291019027 TA 15007 one-story vacant retailer (Black tux) 0 0.000 18ENT-0362 525 COLORADO AVE 4291024014 TA 7483 one-story creative office 1960 0.000 19ENT-0039 1437 5TH ST 4291019018 TA 7484 parking lot 0 0.000 19ENT-0040 1437 6TH ST 4291020016 NV 7497 one story residence 0 0.000 19ENT-0235 1527 17TH ST 4275012020 R2 7500 single dwelling unit 1923 0.053 19ENT-0258 949 10TH ST 4281025014 R2 7484 (blank) 1916 0.250 19ENT-0267 1432 17TH ST 4282019007 R2 7504 (blank) 1959 0.083 19ENT-0425 918 5TH ST 4292015004 R2 7520 (blank) 1910 0.250 20ARB-0138 2714 HIGHLAND AVE 4287019012 OP2 4708 (blank) 1912 0.273 20ARB-0213 1902 EUCLID ST 4283028010 R2 7499 (blank) 1940 0.228 20BLD-1044 2409 28TH ST 4270004017 R2 9005 (blank) 1937 0.125 20BLD-1218 1958 20TH ST 4274019001 R2 7609 (blank) 0 0.133 20ENT-0011 1512 EUCLID ST 4282032003 MUBL 7500 vacant single family home 0 0.250 8.B.i Packet Pg. 746 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-54 Consolidated Site Project ID Address AIN Zoning District Land Area Existing Use Building Age ILR 20ENT-0019 2501 2ND ST 4287010011 OP2 6478 (blank) 0 0.077 20ENT-0020 1819 PICO BLVD 4274017019 NC 13510 parking lot for religious institution 1950 0.383 20ENT-0045 1949 17TH ST 4274015020 R2 7747 Vacant lot 0 0.000 20ENT-0063 2425 20TH ST 4273019001 R2 6746 one story single family unit 1928 0.331 20ENT-0073 817 16TH ST 4281001021 R2 7481 one story single family dwelling 0 0.403 20ENT-0079 1413 MICHIGAN AVE 4283013024 NC 17992 Vacant lot 1905 0.069 20ENT-0164 1510 FRANKLIN ST 4267027057 R2 8118 two story single family unit 1924 0.310 20ENT-0234 734 12TH ST 4280025015 NC 4802 one story single family dwelling 1926 0.250 20ENT-0280 1514 PRINCETON ST 4267022010 R2 4999 one story single family dwelling 1940 0.250 20ENT-0293 1319 CENTINELA AVE 4267014026 R2 9274 two story single family unit 1929 0.488 21ENT-0027 1448 7TH ST 4291020008 NV 7498 two story apartment buildings w parking lot 1952 0.067 21ENT-0143 1546 9TH ST 4282028007 R3 7503 one story single family unit 1909 0.250 22ENT-0002 1302 6TH ST 4291010027 NV 18521 two story office 1978 0.129 22ENT-0012 2537 LINCOLN BLVD 4284008016 GC 19239 closed car wash 1965 0.167 22ENT-0013 2601 LINCOLN BLVD 4285001030 MUBL 203990 one story Gelsons shopping center; multiple tenants 1956 0.349 22ENT-0047 1333 7TH ST 4291008018 NV 7510 small site; single dental tenant; long standing owner/tenant 1978 1.333 8.B.i Packet Pg. 747 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-55 Attachment 2 - FAR and Size of Sites for Past and Current Housing Projects HCD states that a parcel smaller than 0.5 acre (21,780 sf) is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible. The City of Santa Monica is a small, compact city with parcel sizes that range across the City. Parcels in the Bergamot Plan area, Office Campus districts, and Industrial Conservation zones are generally larger (more than 30,000 sf). On the main commercial corridors, sites range between 10,000 sf to 15,000 sf. However, in the Downtown area, parcels are as small as 7,500 sf. As shown in the Table below, past and current multifamily housing projects (including 100% affordable housing projects) on mixed use and commercially zoned sites that are 15,000 sf are common. Generally, only in the Downtown have multi-unit housing projects occurred on sites less than 7,500 sf. As shown in the table, past and current housing projects in commercial and mixed use zones generally propose the maximum FAR or greater (through a development agreement). Therefore, the below development trends for housing projects demonstrate that development of housing affordable to lower income households on smaller commercial and mixed use sites within Santa Monica is typical, realistic, and feasible. PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 20ENT-0238 100% Affordable Housing 1127-1129 2nd St WT 14.984 2.75 2.75 100% 5 - 42 42 122 18ENT-0200 100% Affordable Housing 1238 7th St NV 7.486 3.50 3.50 100% 6 - 37 37 215 18ENT-0212 100% Affordable 1514 7th St TA 7.493 4.00 4.00 100% 8 - 50 50 291 18ENT-0357 100% Affordable 1445-1453 10th St MUBL 13.495 2.00 2.00 100% 4 1 39 40 129 18ENT-0105 100% Affordable 1820-1826 14th St NC 15 1.75 1.75 100% 3 - 39 39 113 19ENT-0328 100% Affordable 1834-1848 14th St NC 30.06 1.75 1.75 100% 4 1 72 73 106 12AA-002 100% Affordable Housing 520 Colorado Ave TA 6.26 1.90 2.00 95% 5 - 34 34 237 18ENT-0129 100% Affordable 711 Colorado Ave TA 7.48 4.00 4.00 100% 7 - 56 56 326 19ENT-0014 100% Affordable 2120 Lincoln Blvd GC 14.16 2.00 2.00 100% 4 1 36 37 114 07AA-007 100% Affordable 1447 Lincoln Blvd LT 23 1.8 (1.3 +0.5) 1.80 100% 5 - 97 97 188 8.B.i Packet Pg. 748 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-56 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 15ENT-0306 100% Affordable 1626 Lincoln Blvd MUB 27.808 1.78 2.75 65% 5 - 64 64 100 20ENT-0020 100% Affordable 1819 Pico Blvd NC 21.524 1.99 2.00 100% 4 1 47 48 97 09AA-007 100% Affordable 2802 Pico Blvd NC 16.2 1.50 1.5 (NC) + 3 units (R2) 100% 4 0 33 33 89 22ENT-0001 100% Affordable 1211-1215 19th St MUB 7.5 2.81 2.25 125% 6 - 34 34 197 22ENT-003 100% Affordable 1333 7th St NV 7.5 5.06 4 127% 8 - 38 38 221 21ENT-0269 100% Affordable 1634 20th IC 19.8 3.95 2.25 176% 7 - 78 78 172 12DEV001 Market Rate 1318-1324 2nd St BC 15 3.10 1.77 / 2.0 155% 4 45 10 55 160 17ENT-0275 Market Rate 1235 5th St NV 7.35 3.50 3.50 100% 5 18 5 23 136 18ENT-0283 Market Rate 1323 5th St NV 7.496 3.50 3.50 100% 6 43 9 52 302 19ENT-0041 Market Rate 1338-1342 5th St NV 14.985 3.50 3.50 100% 6 100 20 120 349 19ENT-0042 Market Rate 1415-1423 5th St TA 14.961 4.00 4.00 100% 8 111 23 134 390 18ENT-0211 Market Rate 1425-1427 5th St TA 15 4.00 4.00 100% 8 92 - 92 267 19ENT-0039 Market Rate 1437 5th St TA 7.489 4.00 4.00 100% 8 52 11 63 366 16ENT-0143 Market Rate 1313-1325 6th St NV 15 3.10 3.50 89% 6 64 - 64 186 19ENT-0040 Market Rate 1437 6th St NV 7.5 3.50 3.50 100% 6 43 9 52 302 11DEV008 Market Rate 1317 7th St NV 15 3.57 1.6 / 2.0 (3.75 DA) 179% 5 51 6 57 166 05AA-015 Market Rate 1427 7th St NV 15 1.87 2.00 94% 5 43 5 48 139 18ENT-0136 Market Rate 1437 7th St NV 14.991 NA 2.0 - 6 52 13 65 189 8.B.i Packet Pg. 749 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-57 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 21ENT-0027 Market Rate 1448 7th St NV 7.5 3.50 3.50 100% 5 15 5 20 116 18ENT-0210 Market Rate 1543-1547 7th St TA 14.962 4.00 4.00 100% 8 75 25 100 291 18ENT-0206 Market Rate 701 Colorado Ave TA 7.481 4.00 4.00 100% 8 49 10 59 344 14AA-001 Market Rate 1347 19th St GC (C4) 7.5 1.00 0.80 125% 2 3 - 3 17 11DEV007 Market Rate 702 Arizona Ave NV 15 3.00 3.0 (DA) 100% 4 40 5 45 131 13DEV-008 Market Rate 500 Broadway TA 67.5 4.00 4.00 100% 7 249 - 249 161 18ENT-0229 Market Rate 501 Broadway TA 14.975 4.00 4.00 100% 8 75 19 94 273 06DR-003 Market Rate 525 Broadway TA 37.5 1.90 2.00 95% 6 115 10 125 145 20ENT-0241 Market Rate 710 Broadway TA 108.5 2.75 / 4.0 2.75 / 4.0 (split zone) 100% 8 206 89 295 118 17ENT-0095 Market Rate 2225 Broadway MUBL 9.7 1.75 1.75 100% 3 13 2 15 67 18ENT-0362 Market Rate 525 Colorado Ave TA 7.5 5.4 4.00 137% 8 30 10 40 232 18ENT-0199 Market Rate 601-609 Colorado Ave TA 22.5 4.00 4.00 100% 8 104 36 140 271 13DEV001 Market Rate 1431 Colorado Ave TA 22.6 1.99 4.00 50% 42 8 50 96 07DEV-005 Market Rate 2930 Colorado Ave MUC 148.966 2.20 2.20 (DA) 100% 5 318 38 356 104 17ENT-0096 Market Rate 1450 Cloverfield MUBL 19.6 1.75 1.75 100% 3 32 3 35 78 17ENT-0297 Market Rate 1707 Cloverfield BTV 74.065 1.85 2.00 92% 4 58 5 63 37 20ENT-0011 Market Rate 1512 Euclid St MUBL 7.5 1.45 1.50 97% 3 8 2 10 58 16ENT-0102 Market Rate 1318 Lincoln Blvd MUB 14.982 2.25 2.75 82% 5 39 4 43 125 8.B.i Packet Pg. 750 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-58 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 20ENT-0163 Market Rate 1427-31 Lincoln Blvd LT 15 2.25 2.25 100% 5 24 6 30 87 15ENT-0266 Market Rate 1430-1444 Lincoln Blvd MUB 30 2.75 2.75 100% 5 100 - 100 145 16ENT-0098 Market Rate 1437-1443 Lincoln Blvd MUB 15.044 2.25 2.75 82% 5 34 6 40 116 12DEV017 Market Rate 1560 Lincoln Blvd MUB 37.5 2.73 2.75 (DA) 100% 5 80 20 100 116 12DEV011 Market Rate 1601 Lincoln Blvd MUB 33.154 2.34 2.25 (DA) 104% 5 71 19 90 118 16ENT-0036 Market Rate 1613-1637 Lincoln Blvd MUB 69.096 2.25 2.25 100% 5 176 15 191 120 16ENT-0058 Market Rate 1641-1645 Lincoln Blvd MUB 20.905 2.25 2.25 100% 5 61 5 66 138 11DEV014 Market Rate 1650-1660 Lincoln Blvd MUB 31.065 2.25 2.25 (DA) 100% 5 90 8 98 137 16ENT-0035 Market Rate 2903-2931 Lincoln Blvd GC 32.277 1.84 2.00 92% 4 43 4 47 63 20ENT-0079 Market Rate 1413 Michigan Ave NC 18 2.06 (w/SDB) 1.75 118% 4 1 57 58 140 16ENT-0118 Market Rate 3030 Nebraska Ave MUC 74.185 1.42 1.50 95% 4 174 9 183 107 15ENT-0300 Market Rate 1828 Ocean Ave OF 45.12 1.81 2.0 91% 4 67 16 83 80 15ENT-0297 Market Rate 1921 Ocean Front Walk OF 23.258 1.7 2.0 83% 4 22 - 22 41 18ENT-0005 Market Rate 216-234 Pico Blvd MUBL 55.689 1.75 1.75 100% 3 93 12 105 82 08AA-002 Market Rate 519 Santa Monica Blvd NV 14.9 1.90 2.00 95% 5 36 4 40 116 19ENT-0340 Market Rate 825 Santa Monica Blvd GC 22.5 1.50 1.50 125% 3 52 4 56 108 18ENT-0038 Market Rate 2822 Santa Monica Blvd MUBL 28.487 1.75 1.75 100% 3 46 4 50 76 16ADM-0050 Market Rate 2901-2907 Santa Monica Blvd MUBL 19.122 1.50 1.50 100% 3 44 7 51 116 8.B.i Packet Pg. 751 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-59 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 17ENT-0298 Market Rate 2906-2918 Santa Monica Blvd MUBL 28.309 1.68 1.75 96% 3 42 4 46 71 15ENT-0313 Market Rate 3008 Santa Monica Blvd MUBL 14.307 1.74 1.75 100% 3 22 4 26 79 18ENT-0182 Market Rate 1618 Stanford MUC 19.969 1.70 1.70 100% 5 43 4 47 103 16ENT-0115 Market Rate 601-611 Wilshire Blvd MUB 14.952 2.25 2.25 100% 4 37 3 40 117 06DR-020 Market Rate 2300 Wilshire Blvd C6 40.6 1.48 1.50 99% 3 30 - 30 32 19ENT-0028 Market Rate 2729 Wilshire Blvd MUB 7.5 1.25 1.25 100% 2 8 1 9 52 18ENT-0244 Market Rate 3223 Wilshire Blvd MUB 19.5 2.25 2.25 100% 4 49 4 53 118 21ENT-0035 Market Rate 1101 Wilshire Blvd MUB 22.489 3.03 (SDB) 2.25 135% 6 82 11 93 180 22ENT-0011 Market Rate 1553-1555 4th St TA 14.997 2.87 2.25 128% 5 54 6 60 174 22ENT-002 Market Rate 1302 6th St NV 18.4 3.50 3.5 100% 6 73 7 80 189 21ENT-0091 Market Rate 1524 7th St TA 15 4.00 2.25 178% 8 80 20 100 290 21ENT-0217 Market Rate 528 Arizona Ave NV 18.5 3.50 3.50 100% 6 73 7 80 188 22ENT-0037 Market Rate 1527-1547 Lincoln Blvd LT 37.455 2.25 2.25 100% 5 106 8 114 133 22ENT-0012 Market Rate 2537 Lincoln Blvd GC 19.2 2.25 1.50 150% 4 44 5 49 111 22ENT-0013 Market Rate 2601-2645 Lincoln Blvd MUBL 203.25 2.25 1.50 150% 5 468 53 521 112 21ENT-0226 Market Rate 1801 Santa Monica Blvd GC 22.49 1.50 1.50 100% 3 41 - 41 79 21ENT-0227 Market Rate 1819 Santa Monica Blvd GC 22.5 1.50 1.50 100% 3 41 - 41 79 22ENT-0005 Market Rate 1902 Wilshire Blvd MUB 22.5 2.25 2.25 100% 5 71 - 71 137 8.B.i Packet Pg. 752 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-60 PROJECT ID PROJECT TYPE ADDRESS STREET ZONING SITE SIZE (SF) FAR FAR (ALLOWABLE) % OF MAXIMUM FAR STORIES MARKET RATE UNITS AFFORDABLE UNITS TOTAL UNITS UNITS/ACRE BUILT/PROPOSED 21ENT-0228 Market Rate 1931 Wilshire Blvd MUB 25.5 2.25 2.25 100% 5 60 - 60 102 22ENT-0006 Market Rate 2025 Wilshire Blvd MUB 18.5 2.25 2.25 100% 4 46 - 46 108 22ENT-0007 Market Rate 2501 Wilshire Blvd MUB 30.8 2.25 2.25 100% 4 78 - 78 110 8.B.i Packet Pg. 753 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-61 Attachment 3 - Environmental and Infrastructure Constraints Government Code Section 65583.2(b)(4) requires a general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the jurisdiction. This information need not be identified on a site- specific basis. Below is a summary of the analysis of potential environmental and infrastructure constraints: 1. Environmental Constraints a. Fire The City is highly urbanized and does not include any areas designated as a High or Very High Fire Hazard Severity Zone (FHSZ). The nearest wildfire zones are to the north of the City associated with the Santa Monica Mountains and as such, wildfire risk is very limited within City boundaries. The primary fire hazard risks are man-made and are most likely to occur in commercial and industrial areas where industrial chemicals are used, stored, or transported. These potential fire risks, however, are mitigated by stringent enforcement of State and Federal regulations related to hazardous materials storage and transport. Fire risks are not considered constraints to housing development since there are existing regulations and plans in place to address such risk. b. Flooding FEMA recently updated the City’s flood maps to account for flooding due to climate change and rising ocean levels. Based on the new maps, 85 beach front properties along Pacific Coast Highway in the City are now within a FEMA defined Special Flood Hazard Area (SFHA), which is an area subject to a one percent or greater chance of flooding in any given year. To ensure compliance with FEMA, the City amended Santa Monica Municipal Code Chapter 7.68 (Floodplain Management Regulations) on March 3, 2021. The amended regulations require new construction in the special flood zones to obtain a floodplain development permit and implement safety requirements addressing flood risks. Inundation by tsunami can also affect the low-lying beach front properties of the City. In the event of a tsunami, the City has designated tsunami evacuation routes and has also adopted a Multi Hazard Functional Emergency Plan to reduce risk and prevent loss from large scale emergencies, including tsunamis. Location in a flood zone or tsunami zone are not considered constraints to housing development since there are existing regulations and plans in place to address such risk. c. Fault Rupture and Seismic Hazards The City of Santa Monica is located in a seismically active area. The closest known fault in the City is the Santa Monica Fault, which is comprised of various segments with several strands that cross through the northeastern portion of the City. The Santa Monica Fault zone was designated in 2018 as an active fault by the California Geological Survey (CGS). A number of SSI sites identified on the eastern end of Wilshire Boulevard and Santa Monica Boulevard are located within this fault zone. The State does not prohibit housing in an active fault zone, but instead 8.B.i Packet Pg. 754 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-62 requires that structures built for human occupancy be assessed for potential fault rupture risks. Consistent with State requirements, the City’s Building and Safety Division requires the submittal of a Fault Rupture Study to assess potential fault rupture risks and implement measures as necessary to mitigate such risks. Additionally, the design and construction of new buildings are required to be engineered to withstand the seismic ground acceleration that may occur during an earthquake, pursuant to the Santa Monica Building Code which incorporates applicable provisions of the California Building Code (CBC). The City also requires new buildings to submit a Design-Level Geotechnical Report prior to building permit issuance in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design to minimize seismic hazards. Fault rupture risks and seismic hazards are not considered constraints to housing development since there are existing regulations and plans in place to address such risks. d. Liquefaction Liquefaction occurs when ground shaking transforms granular material from a solid state to a liquefied state due to earthquake. These soils may acquire a high degree of mobility and lead to structurally damaging deformations. Liquefaction begins below the water table, but after liquefaction has developed, the groundwater table will rise and cause the overlying soil to mobilize. Liquefaction typically occurs in areas where the groundwater is less than 30 feet from the surface and where the soils are composed of poorly consolidated fine to medium sand. The CGS Seismic Hazard Zone Map that covers the City of Santa Monica identifies the beach front areas and a small eastern portion of the City between Olympic Boulevard and Pearl Street as having liquefaction risk. However, according to the City’s Safety Element Geologic Hazards map, the City has varying potential for liquefaction: • Along the beach • From the beach, inland to the southwest corner of the city to Marine Park following the lowlands along Lincoln Boulevard • In the northern industrial corridor Liquefaction risks are addressed through the City’s building permit process. The design and construction of new buildings are required to be engineered to address potential liquefaction risks, pursuant to the Santa Monica Building Code which incorporates applicable provisions of the California Building Code (CBC). Additionally, the City requires developers of new buildings to submit a Design-Level Geotechnical Report in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. The Geotechnical Report is required to include a site- specific soils investigation to determine liquefaction potential on the site. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design prior to building permit issuance to minimize liquefaction risks. As such, liquefaction is not considered to be a constraint to housing development since there are existing regulations and plans in place to address this environmental concern. 8.B.i Packet Pg. 755 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-63 e. Landslides The main areas of landslide concern within the City are confined to the areas along Highway 1/Pacific Coast Highway (Hwy 1) below the Palisades bluffs, at the southwestern edge of the City. The City has implemented a number of projects in the past decade to reduce landslide risks and soil instability at the bluffs including the California Incline Bridge Replacement Project and the Santa Monica Palisades Bluff Stabilization Project. The geotechnical reports for these two projects were submitted to the California Coastal Commission, Caltrans, and the City of Santa Monica and each agency concluded that the planned construction improvements on the bluff would be safe and not cause or contribute to erosion or degradation of geologic stability. In addition, several slope stabilization and dewatering measures have been implemented by the City which has decreased rate of erosion and improved the stability of the bluffs. As a result of these measures, landslide risks below the bluffs are considered low. The properties in the northern portion of the City (near the Santa Monica Mountains) and in the Bryn Mawr Avenue residential area near Marine Park are characterized by steeper slopes. The design and construction of new buildings are required to be engineered to minimize landslide risks and soil instability, pursuant to the Santa Monica Building Code which incorporates the applicable provisions of the California Building Code (CBC). The City also requires new buildings to submit a Design-Level Geotechnical Report prior to building permit issuance in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design to minimize landslide and soil collapse hazards. Landslide risks are not considered to be constraints to housing development since there are existing regulations and plans in place to address such concerns. f. Former Claypit/Landfill Areas Beginning in the early 1900s, clay mining operations took place in the east central portion of the City (near the City Yards and the Bergamot Plan area). After clay quarries were depleted, some clay pit areas were used as municipal landfills by the City from the mid-1940s until December 1970. After the landfills closed, structures were built over the landfills and remediation efforts have taken place including the installation of methane probes at the City Yards. Future housing projects occurring in these former claypit/landfill areas would require detailed Phase I environmental Site Assessments and subsurface investigations (Phase II) as necessary to address human health hazards. Any clean up recommendations and remediation measures in Phase I and Phase II site assessments are required to be implemented under the oversight of the appropriate clean up agency (Department of Toxic Substances Control, State Water Resources Control Board, Santa Monica Fire Department, etc.). The former claypit/landfill areas are not considered to be constraints to housing development since there are existing regulations and plans in place to address such concerns on a case-by-case basis. g. Santa Monica Airport The Santa Monica Municipal Airport, located in the southeastern area of the City, covers approximately 215 acres of land generally bounded by Bundy Drive to the east, Santa Monica Business Park and Ocean Park Boulevard to the north, 23rd Street to the west, and Dewey Street 8.B.i Packet Pg. 756 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-64 in the City of Los Angeles to the south. The Santa Monica Municipal Airport is a general aviation airport that primarily caters to personal aircraft and flight schools and contains a number of non-aviation uses primarily located in the area south of the runways, including the Santa Monica College Bundy Campus. This airport is currently subject to a settlement agreement with the FAA and Consent Decree that require the City to maintain airport operations through December 31, 2028, and to also Santa Monica Measure LC, which governs use of the entire airport site should the City elect to close its airport at any time after December 31, 2028, as authorized by the Consent Decree. The Los Angeles County Airport Land Use Commission (ALUC) is responsible for airport land use compatibility planning for Los Angeles County. Local actions, including rezoning and new housing projects located within an Airport Influence Areas (AIA) must be submitted to the ALUC for review. None of the sites identified in the SSI are located in Santa Monica’s AIA. The other potential environmental issue associated with the airport relates to operational noise. In general, residential uses should be sited outside of an airport’s 65 dBA CNEL (decibels, Community Noise Equivalent Level) noise contour. None of the sites identified in the SSI are located within the Santa Monica Airport’s 60, 65, and 70 CNEL noise contours. Therefore, the presence of the Santa Monica Airport is not considered to be a constraint to housing development. h. Biological Resources The City is mostly urbanized, with few areas of native wildlife habitat occurring within the City limits. The nearest wildlife habitat occurs along the coast at Santa Monica State Beach. Substantial forested open space occurs in the Santa Monica Mountains, located approximately 3.5 miles to the north. The majority of the City of Santa Monica has been developed, paved, or landscaped, and is generally devoid of large expanses of habitat that support sensitive species. No major regional wildlife migration corridors are known to exist within the City limits. No native riparian habitat, blueline streams, wetlands, or sensitive natural communities are located in the City limits. The beach areas of the City do provide foraging and roosting opportunities for several special status species (e.g., least terns. Snowy plovers). The City is not recognized as an existing or proposed Significant Ecological Area (SEA) that links wildlife populations. Biological resources are not considered to be constraints to housing development. 2. Infrastructure Constraints As an urbanized community with well established residential neighborhoods and commercial districts, Santa Monica has a comprehensive backbone infrastructure which includes existing sewer and water lines, and storm drains. Based on existing and planned capacity, the City has sufficient infrastructure (water, sewer, and storm drain) capacity to accommodate the RHNA at all income levels. a. Sewer System 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. Sewer pipes have a flow capacity based on the diameter of the pipe 8.B.i Packet Pg. 757 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-65 and the slope of the pipeline. Increased wastewater flows from construction of up to 8,895 units in the next 8 years under the RHNA is projected to result in impacts to existing sewer pipes, incrementally triggering the need for expansion or replacement of individual sewer line segments. The City’s Public Works Department anticipates that an increase in the Capital Facilities Fee would be necessary to finance the capital improvements necessary to accommodate the increase in housing. While an increase in sewage capacity will be required to serve future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The City does not budget or pay for improvements that are necessary to support individual private development projects, which includes affordable housing projects. If it is shown that infrastructure capacity will be exceeded by a project, private developers are generally responsible for the cost of upsizing the mains needed to support the demand generated by the project. Housing projects would not be constrained by sewer capacity issues. b. Water System The City of Santa Monica Water Resources Division is a retail water agency providing water service throughout the City, including single- and multi-unit residential, commercial, and industrial customers, and landscape and fire protection supply. 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). Nevertheless, water demand from construction of new housing is expected to increase, which could trigger the need for additional water distribution pumps if there is insufficient water pressure. While an increase in water system capacity will be required to serve future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The City does not budget or pay for improvements that are necessary to support individual private development projects, which includes affordable housing projects. If it is shown that infrastructure capacity will be exceeded by a project, private developers are generally responsible for the cost of upsizing the mains needed to support the demand generated by the project. Housing projects would not be constrained by water system capacity issues. c. Water Supply The City water supply consists of local groundwater, imported water from Metropolitan Water District of Southern California (MWD), and urban treated runoff water from the Santa Monica Urban Runoff Recycling Facility (SMURRF). 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. 8.B.i Packet Pg. 758 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-66 d. Storm Drains The overall drainage pattern of the City of Santa Monica is to the southwest. An underground storm drain system intercepts surface runoff through a series of catch basins, connector pipes and mainlines and carries the majority of the storm water to the Santa Monica Bay portion of the Pacific Ocean. The storm drain system is comprised principally of pipes and channels owned by two separate entities: the City of Santa Monica and the County of Los Angeles. Additionally, a few drainage facilities within the right-of-way of Interstate 10 are under Caltrans jurisdiction. The storm drain pipes/channels in the city range from 16 inches to 11 feet in diameter. The conduits are mainly constructed of reinforced concrete pipe (RCP) or reinforced concrete (RC). A few of the structures are brick arch drains, or corrugated metal pipes (CMP). 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, about 1,050 are owned and maintained by the County; 70 by the City of Santa Monica, and 100 by Caltrans. The City has constructed an Urban Runoff Recycling Facility (SMURRF) to treat the dry weather storm drain discharges from excess irrigation, spills, construction sites, pool draining, car washing and other activities that would otherwise drain into the Santa Monica Bay and recycle it for irrigation and dual plumbed building purposes. All projects on sites over 15,000 sf would be subject to the City’s Runoff Conservation and Sustainable Management Ordinance requirements. This would include preparation and implementation of a Runoff Mitigation Plan to minimize polluted runoff in accordance with the City’s Ordinance. In addition, the projects would be required to store and use (for non-potable purposes), infiltrate, or evapotranspire project-generated runoff during a 0.75-inch storm event, or alternatively, pay the City an urban runoff-reduction fee. Therefore, storm drains do not pose a constraint to housing development. 8.B.i Packet Pg. 759 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-67 Attachment 4 – Letter of Intent from SMMUSD 8.B.i Packet Pg. 760 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis B-68 Attachment 5 – Suitable Sites Inventory Table 8.B.i Packet Pg. 761 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in City of Santa Monica 2021-2029 Housing Element F-61 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 A 3223 WILSHIRE BLVD 4266001046 MUB 6,522 parking lot for Aah's 0.00 approved project - part of 3223 wilshire 1 A 3223 WILSHIRE BLVD 4266001045 MUB 13,063 one-story Aah's retail store 1955 0.11 approved 54 unit project 1 AA 1431 LINCOLN BLVD 4282027019 LT 7,512 one-story comic book store 1983 0.13 approved 100 unit project (1427-1431 Lincoln) 1 AA 1427 LINCOLN BLVD 4282027020 LT 7,501 one-story comic book store 1956 0.02 approved 100 unit project (1427-1431 Lincoln) 1 AC 1527 LINCOLN BLVD 4282028019 LT 7,494 former tile store; vacant retail building 1945 0.31 common ownership; in Downtown; single tenant building 1 AC 1533 LINCOLN BLVD 4282028018 LT 7,510 former tile store; vacant retail building 1952 0.43 common ownership; in Downtown; single tenant building 1 AM 3RD STREET/PICO BLVD 4289019022 MUBL 5,601 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 216 PICO BLVD 4289019023 MUBL 5,613 vacant one story bowling alley 1962 0.06 SB330 application; 199 units/ 19 affordable 1 AM 228 PICO BLVD 4289019021 MUBL 5,621 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 248 PICO BLVD 4289019017 MUBL 5,590 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 254 PICO BLVD 4289019016 MUBL 5,611 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 234 PICO BLVD 4289019019 MUBL 28,008 vacant one story bowling alley 1959 0.10 SB330 application; 199 units/ 19 affordable 1 AO 1342 5TH ST 4291011019 NV 7,509 parking lot 0.00 approved 120 unit w SRO project (1338-1342 5th St) 1 AO 1342 5TH ST 4291011020 NV 7,485 parking lot 0.00 approved 120 unit w SRO project (1338-1342 5th St) 1 AR 1445 5TH ST 4291019016 TA 7,498 vacant one-story multitenant retail building 1946 0.02 approved project w SRO 1437-1445 project (63 units) 1 AR 1445 5TH ST 4291019017 TA 7,511 parking lot next to vacant retail 0.00 approved project w SRO 1437-1445 project (63 units) 1 AT LINCOLN BLVD/SANTA MONICA BLVD 4291021009 LT 3,751 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1438 LINCOLN BLVD 4291021008 LT 3,752 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1444 LINCOLN BLVD 4291021010 LT 7,491 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1430 LINCOLN BLVD 4291021006 LT 7,507 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1432 LINCOLN BLVD 4291021007 LT 7,492 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AU 1500 LINCOLN BLVD 4291022003 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1500 LINCOLN BLVD 4291022025 LT 22,450 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1518 LINCOLN BLVD 4291022004 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1526 LINCOLN BLVD 4291022005 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1534 LINCOLN BLVD 4291022006 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 710 BROADWAY 4291022026 TA 52,450 one-story Von's with parking lot 1995 0.18 approved 300 unit project (710 Broadway) 1 AX 1553 4TH ST 4291025028 TA 7,474 Vacant bank site across DT station 0.00 common ownership; vacant building in DT 1 AX 1555 4TH ST 4291025012 TA 7,497 Vacant bank site across DT station 1973 0.01 common ownership; vacant building in DT 1 AY 1127 2ND ST 4292021010 WT 7,517 parking lot 0.00 approved 100% affordable housing - 42 units 1 AY 1129 2ND ST 4292021009 WT 7,490 parking lot 0.00 approved 100% affordable housing - 42 units 1 BG 1152 21ST ST 4276007021 MUB 3,491 rear parking lot for NOMA sushi and Veggie grill (2025 wilshire) 0.02 SB330 application; 46 units w/ offsite affordable at 1211-1215 19th 1 BG 2025 WILSHIRE BLVD 4276007027 MUB 14,987 one story Veggie grill 1969 0.10 SB330 application; 46 units w/ offsite affordable at 1211-1215 19th 1 BL 1115 WILSHIRE BLVD REAR 4281020029 MUB 13,949 rear parking lot 1927 0.18 (blank) 1 BL 1101 WILSHIRE BLVD 4281020012 MUB 8,559 one-story JP bar 1922 0.19 SB330 application; pending project (93 units) 1 BN 1819 SANTA MONICA BLVD 4276029011 GC 14,986 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BN 1350 19TH ST 4276029010 GC 7,495 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BN 1342 19TH ST 4276029009 R2 8,991 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BO 2911 SANTA MONICA BLVD 4267011022 MUBL 6,501 one story retail building 1926 0.20 approved 53 unit project (2901-2907 Santa Monica project) 1 BO 1347 YALE ST 4267011021 MUBL 3,266 one-story retail building 1926 0.25 approved 53 unit project (2901-2907 Santa Monica project) 8.B.j Packet Pg. 762 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-62 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 BO 1349 YALE ST 4267011020 MUBL 9,368 one story multitenant retail building, two story apartment building w parking lot 1923 0.11 approved 53 unit project ( 2901-2907 Santa Monica project) 1 BP 1543 LINCOLN BLVD 4282028010 LT 7,497 one story vacant auto repair 1947 0.13 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BP 1547 LINCOLN BLVD 4282028009 LT 7,499 one story vacant auto repair 1999 0.43 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BP 1537 LINCOLN BLVD 4282028011 LT 7,496 one story vacant auto repair 1945 0.25 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BS 2002 21ST ST 4274026001 R2 7,533 one-story apartments 1949 0.10 approved Park Virginia Townhomes 19 units 1 BS 2008 21ST ST 4274026003 R2 7,130 one-story apartments 1953 0.11 approved Park Virginia Townhomes 19 units 1 BT 1840 14TH ST 4283030018 NC 7,524 100% affordable housing under construction 1962 0.26 approved affordable housing project 73 units 1 BT 1844 14TH ST 4283030017 NC 7,485 100% affordable housing under construction 1922 0.50 approved affordable housing project 73 units 1 BT 1848 14TH ST 4283030016 NC 7,525 100% affordable housing under construction 1968 0.00 approved affordable housing project 73 units 1 BU 1415 5TH ST 4291019021 TA 7,494 two story multitenant retail building 1980 0.00 approved 111 unit project (1415-1423 5th St) 1 BU 1423 5TH ST 4291019020 TA 7,525 two story multitenant retail building 1966 0.00 approved 111 unit project (1415-1423 5th St) 1 BV 1543 7TH ST 4291022014 TA 7,500 parking lot 1990 1.73 approved 100 unit project (1543-1547 7th St) 1 BV 1547 7TH ST 4291022013 TA 7,500 parking lot 0.00 approved 100 unit project (1543-1547 7th St) 1 BW 1547 6TH ST 4291023011 TA 7,505 one-story multi-tenant building, restaurant, office 1986 0.00 approved 140 unit project (part of 609 Colorado project) 1 BW 609 COLORADO AVE 4291023010 TA 14,982 one-story multi-tenant building, restaurant, office 1984 0.17 approved 140 unit project (part of 609 Colorado project) 1 BX 601 WILSHIRE BLVD 4292005029 WT 10,010 vacant one and two story buildings 1977 0.07 approved 40 units w/ 3 affordable (601-611 Wilshire) 1 BX 611 WILSHIRE BLVD 4292005026 WT 4,997 vacant one and two story buildings 1922 0.14 approved 40 units w/ 3 affordable (601-611 Wilshire) 1 BY 1650 LINCOLN BLVD 4290002008 LT 16,220 one-story retail, boxing fitness building 1954 0.00 approved 98 Units (1650-1660 Lincoln) 1 BY 1660 LINCOLN BLVD 4290002006 LT 7,570 one-story retail, boxing fitness building 1954 0.00 approved 98 Units (1650-1660 Lincoln) 1 BZ 1437 LINCOLN BLVD 4282027018 LT 7,485 one-story retail building 1949 0.00 approved 40 unit project (1437-1443 Lincoln) 1 BZ 1443 LINCOLN BLVD 4282027028 LT 7,510 one-story retail 1959 0.00 approved 40 unit project (1437-1443 Lincoln) 1 C 2501 WILSHIRE BLVD 4276001026 MUB 14,319 one-story commercial building with multiple retailers; corner parcel; with rear residential parking lot 1951 0.14 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 C 2515 WILSHIRE BLVD 4276001025 MUB 6,164 one-story multi-tenant commercial building 1941 0.49 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 C 2525 WILSHIRE BLVD 4276001027 MUB 10,347 one-story commercial building, Starbucks, Urgent Care, Postal Store; common ownership; corner parcel with rear residential parking 1970 0.44 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 CA 1313 6TH ST 4291009021 NV 15,010 parking lot 0.00 approved 64 unit project (1313-1325 6th St) 1 CA 1323 5TH ST 4291010029 NV 7,512 parking lot 0.00 approved 43 unit project 1 CH 1902 WILSHIRE BLVD 4276013020 MUB 4,989 one story retail/restaurant building (Thai dishes, salon, medical office) 1939 0.33 SB330 application; 71 units w/ offsite affordable in rear 1 CH 1908 WILSHIRE BLVD 4276013030 MUB 24,993 one-story retail/restaurant building (Thai dishes, salon, medical office) 1925 0.20 SB330 application; 34 affordable units; lot has been split with 100% affordable in rear 1 CI 1921 WILSHIRE BLVD 4276008014 MUB 15,015 one-story retail building (GAP) 1975 0.41 SB330 application; 60 units w/ 9 affordable 1 CI 1933 WILSHIRE BLVD 4276008015 MUB 10,520 one-story retail building (GAP) 1958 0.33 SB330 application; 60 units w/ 9 affordable 1 E 2906 SANTA MONICA BLVD 4267018026 MUBL 21,314 vacant two story office 1969 0.79 approved 46 unit project (2906-2918 Santa Monica Blvd) 1 E 2918 SANTA MONICA BLVD 4267018003 MUBL 7,021 vacant parking lot 1965 0.12 approved 46 unit project (2906-2918 Santa Monica Blvd) 1 P 1347 18TH ST 4276029026 GC 7,512 Honda dealership with surface inventory 1969 0.00 SB330 application; 41 units w/ 7 affordable 1 P 1801 SANTA MONICA BLVD 4276029048 GC 14,984 Honda dealership with surface inventory 1953 0.02 SB330 application; 41 units w/ 7 affordable 1 S 825 SANTA MONICA BLVD 4282010012 GC 7,505 Toyota dealership 0.00 pending project 48 units (825 Santa Monica) 8.B.j Packet Pg. 763 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-63 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 S 825 SANTA MONICA BLVD 4282010013 GC 7,491 Toyota dealership 1951 0.01 pending project 48 units (825 Santa Monica) 1 S 825 SANTA MONICA BLVD 4282010014 GC 7,502 Toyota dealership 1951 0.00 pending project 48 units (825 Santa Monica) 1 1211 12TH ST 4282005053 R3 15,008 one story apartment buildings 0.00 approved 13 units 1 1434 14TH ST 4282022027 R3 7,500 1925 0.22 approved 6 unit condos 1 1021 GRANT ST 4284015017 R2 6,491 1928 0.42 approved 2 units 1 1133 OCEAN AVE 4292028001 OT 190,963 Miramar Hotel 1938 0.53 approved Miramar Project - 60 condo units 1 1431 COLORADO AVE 4282034009 MUBL 22,485 one-story marble store 1923 0.01 pending 50 unit project 1 129 SANTA MONICA BLVD 4291014024 BC 30,000 parking lot 1871 0.02 pending Ocean Avenue project - 100 units 1 610 CALIFORNIA AVE 4292005022 R2 5,002 1912 0.21 approved 3 condo units 1 OCEAN FRONT WALK/BAY STREET 4289025005 OF 23,222 vacant parking lot next to Casa del mar hotel 0.00 approved with 1828 ocean ave; formerly 1921 OFW (22 units) 1 OCEAN FRONT WALK/PICO BLVD 4290020045 OF 45,314 parking lot 0.00 approved 83 unit project 1 1840 17TH ST 4283032008 R2 7,490 1955 0.25 5 unit condos 1 1121 22ND ST 4276005022 R2 6,114 1924 0.03 approved 3 townhomes 1 SANTA MONICA BLVD/23RD STREET 4275006026 HMU 6,242 parking lot owned by Saint John's 0.00 pending Providence Saint John's Master Plan - 10 Units 1 1318 LINCOLN BLVD 4291008025 LT 15,003 parking lot 0.00 approved 43 unit project 1 1665 APPIAN WAY 4290018018 R3 4,430 residential 1914 0.37 pending 3 Unit townhome project 1 4268010017 MUC 64,297 one-story light industrial/creative office 0.00 approved 183 unit project - WS project 1 2102 5TH ST 4289010006 OP2 5,661 1911 0.02 3 unit condos 1 1754 10TH ST 4283018002 R2 7,511 1922 0.25 approved 3 apartment units 1 1649 CENTINELA AVE 4268006016 R2 6,313 single family dwelling 1948 0.25 approved 3 condo units 1 436 PIER AVE 4287027065 OP2 7,480 1911 0.25 3 unit condos 1 1900 20TH ST 4274019056 R2 7,575 single family dwelling 0.00 approved 3 condo units 1 4287003017 OP2 7,973 0.00 3 unit condos 1 1707 CLOVERFIELD BLVD 4268014013 BTV 76,562 parking lot of Extra Space sotrage 1955 0.66 approved 63 units w/ 5 affordable 1 1342 BERKELEY ST 4267012009 R2 7,858 Vacant lot 0.00 100% affordable housing project w/ 8 units 1 1443 18TH ST 4275010016 MUBL 7,500 Vacant lot 1957 0.00 approved 11 condo units 1 711 COLORADO AVE 4291022012 TA 7,500 construction staging site 0.00 approved 100% affordable housing 1 1437 7TH ST 4291021029 NV 14,991 three story office building 1983 1.22 approved 65 unit project 1 1618 STANFORD ST 4268002005 MUC 20,016 one story office building 1950 0.20 approved 47 unit project 1 1238 7TH ST 4291006006 NV 7,500 one-story office 1912 0.00 approved 37 unit project 1 1557 7TH ST 4291022021 TA 7,500 one story brick office building 1959 0.03 approved AA project for 59 unit project 1 1427 5TH ST 4291019019 TA 15,007 one-story vacant retail building 1954 0.00 approved 92 unit project 1 1514 7TH ST 4291023002 TA 7,504 construction staging parking site 0.00 approved 100% affordable housing - 50 units 1 501 BROADWAY 4291019027 TA 15,007 one-story vacant retailer (Black tux) 0.00 approved 94 unit project 1 525 COLORADO AVE 4291024014 TA 7,483 one-story creative office 1960 0.00 approved 40 unit project 1 1437 5TH ST 4291019018 TA 7,484 parking lot 0.00 approved 52 unit project 1 1437 6TH ST 4291020016 NV 7,497 one story residence 0.00 approved 51 unit project 1 1527 17TH ST 4275012020 R2 7,500 single dwelling unit 1923 0.05 approved 3 condo units addition 1 949 10TH ST 4281025014 R2 7,484 1916 0.25 approved 3 condo units 8.B.j Packet Pg. 764 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-64 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 1 1432 17TH ST 4282019007 R2 7,504 1959 0.08 approved 6 unit condos 1 918 5TH ST 4292015004 R2 7,520 1910 0.25 approved 3 condo units 1 2714 HIGHLAND AVE 4287019012 OP2 4,708 1912 0.27 approved duplex 1 1902 EUCLID ST 4283028010 R2 7,499 1940 0.23 approved triplex addition 1 2409 28TH ST 4270004017 R2 9,005 1937 0.13 approved duplex 1 1958 20TH ST 4274019001 R2 7,609 0.13 approved addition of 2 units 1 1512 EUCLID ST 4282032003 MUBL 7,500 vacant single family home 0.25 pending 10 unit project 1 2501 2ND ST 4287010011 OP2 6,478 0.08 approved 3 unit condos addition 1 1819 PICO BLVD 4274017019 NC 13,510 parking lot for religious institution 1950 0.38 approved 100% affordable housing 48 units 1 1949 17TH ST 4274015020 R2 7,747 Vacant lot 0.00 approved 5 condo units 1 2425 20TH ST 4273019001 R2 6,746 one story single family unit 1928 0.33 approved 3 condo units 1 817 16TH ST 4281001021 R2 7,481 one story single family dwelling 0.40 approved 3 condo units 1 1413 MICHIGAN AVE 4283013024 NC 17,992 Vacant lot 1905 0.07 approved 100% affordable housing (58 units) 1 1510 FRANKLIN ST 4267027057 R2 8,118 two story single family unit 1924 0.31 approved 3 unit condos 1 734 12TH ST 4280025015 NC 4,802 one story single family dwelling 1926 0.25 approved 3 condo units 1 1514 PRINCETON ST 4267022010 R2 4,999 one story single family dwelling 1940 0.25 approved 2 condo units 1 1319 CENTINELA AVE 4267014026 R2 9,274 two story single family unit 1929 0.49 approved 6 unit condos 1 1448 7TH ST 4291020008 NV 7,498 two story apartment buildings w parking lot 1952 0.07 approved 8 unit project 1 1546 9TH ST 4282028007 R3 7,503 one story single family unit 1909 0.25 pending 9 unit apartments 1 1302 6TH ST 4291010027 NV 18,521 two story office 1978 0.13 SB330 application; 80 units w/ offsite at 1333 7th 1 2537 LINCOLN BLVD 4284008016 GC 19,239 closed car wash 1965 0.17 SB330 application; 49 units w/ 5 affordable 1 2601 LINCOLN BLVD 4285001030 MUBL 203,990 one story Gelsons shopping center; multiple tenants 1956 0.35 SB330 application; 521 units w/ 53 affordable 1 1333 7TH ST 4291008018 NV 7,510 small site; single dental tenant; long standing owner/tenant 1978 1.33 SB330 application; 100% affordable receiver site of 38 units 2 AH 1353 OLYMPIC BLVD 4283008001 MUBL 10,144 Synder Diamond parking lot 0.02 expressed past interest; prominent corner 2 AH 1654 14TH ST 4283008004 MUBL 15,011 Synder Diamond 1975 0.31 expressed past interest; prominent corner 2 AH 1660 14TH ST 4283008018 MUBL 21,369 Synder Diamond 1925 1.17 expressed past interest; prominent corner 2 AN 1311 5TH ST 4291010019 NV 7,498 parking lot for retail building 1939 0.68 low scale old building Downtown; common ownership 2 AN 1313 5TH ST 4291010020 NV 7,510 one-story retail building 0.02 low scale old building Downtown; common ownership 2 BI 1519 COLORADO AVE 4282035010 MUBL 22,498 one-story creative office 1957 0.48 high potential with across st access to expo; adjacent parcel at 1544 16th St is parking lot with common ownership 2 CC 1317 WILSHIRE BLVD 4281012025 MUB 22,535 Rite Aid 1940 0.15 high potential with parking lot; underutilized site; single tenant 2 G 2848 COLORADO AVE 4268002012 MUC 11,927 one-story light industrial 1952 0.13 prior residential project withdrawn due to DA process 2 G 2878 COLORADO AVE 4268002011 MUC 18,020 one-story light industrial 1959 0.24 prior residential project withdrawn due to DA process 2 G 2902 COLORADO AVE 4268002013 MUC 82,310 one-story light industrial 1938 0.23 prior residential project withdrawn due to DA process 2 G 2912 COLORADO AVE 4268002003 MUC 9,597 one-story light industrial 1963 0.86 prior residential project withdrawn due to DA process 2 H 3025 OLYMPIC BLVD 4268010018 MUC 54,556 one-story creative office/light industrial building 0.00 large parcel; adjacent to approved development; owned by known residential developer; prior application for residential 2 1244 7TH ST 4291006007 NV 7,500 Office building with dental tenants 0.83 low scale office Downtown with parking in rear; adjacent to approved residential project on same size lot 2 1301 WILSHIRE BLVD 4281012022 MUB 60,051 Von's 1966 0.15 high potential parking; has expressed interest in past; single tenant 2 1327 5TH ST 4291010017 NV 7,497 one-story retail building 1930 0.62 low scale retail Downtown across 4th/5th Arizona; owned by housing provider; adjacent to approved residential project on same size lot 2 1401 WILSHIRE BLVD 4281011028 MUB 21,271 one-story US Bank Building with rear parking lot 1931 0.45 adjacent parking lot; not on HRI; one story single tenant bank with high potential 8.B.j Packet Pg. 765 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-65 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 2 1501 WILSHIRE BLVD 4281005026 MUB 32,561 One story vacant retail formerly Santa Monica Town Car with large rear parking lot 1932 0.35 underutilized parking lot; fronting Wilshire Blvd with access; vacant building 2 2723 LINCOLN BLVD 4285001032 MUBL 20,599 34 Degrees North Fitness and one-story auto repair 1955 0.41 lots of parking; single story 2 625 ARIZONA AVE 4291006027 NV 22,500 one-story office building 1938 0.54 low scale office Downtown; corner lot; prior development inquiry 2 626 WILSHIRE BLVD 4291006001 NV 15,000 711 strip mall 1959 0.09 High; location on corner; with parking lot 2 2225 COLORADO AVE 4275016021 MUBL 35,990 one-story R&D (Kite Pharma) building with parking lot 1972 1.02 one-story R&D underdeveloped; kitepharma looking for new space 2 1407 7TH ST 4291021027 NV 14,993 one-story retail building 1923 0.13 low scale retail strip; multiple tenants; alley access; corner parcel 3 AS 1410 LINCOLN BLVD 4291021002 LT 7,508 parking lot 0.01 common ownership to 720 Santa Monica Blvd; owned by commercial investment company 3 AS 718 SANTA MONICA BLVD 4291021001 LT 7,497 commercial building; balloon place and common ownership 1924 0.52 low scale building at edge of DT; in proximity to other residential development; common ownership; owned by commercial investment firm 3 R 1237 LINCOLN BLVD 4282009027 LT 7,514 Motel 1907 0.13 old motel; tenant does not appear to have longetivity 3 R 1243 LINCOLN BLVD 4282009014 LT 7,502 Motel 1949 0.48 old motel; tenant does not appear to have longetivity 3 718 COLORADO AVE 4290001023 LT 21,881 former Fisher lumber site vacant 1965 0.08 vacant building; site for sale 3 603 ARIZONA AVE 4291006029 NV 7,506 one-story office building 1963 0.00 low scale office - one story; AA for residential applied for back in 2014; owned by housing developr 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288009900 R4 12,477 City parking lot on main south of Ashland 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288010900 R4 16,469 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288011900 R3 23,118 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288012902 R3 26,951 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288013905 R3 26,348 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288014901 R3 40,256 City parking lot on main (approximately 11.8 Ksf) rest is affordable housing 1947 0.00 city owned parking lot - no leases with outside parties 4 AL MAIN STREET B/T OCEAN PARK BLVD AND ASHLAND AVE 4288015901 R3 50,158 City parking lot on main 0.00 city owned parking lot - no leases with outside parties 4 AP 1301 4TH ST 4291011909 BC 32,245 Bank of America; Chase bank; parking lot 1959 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011900 NV 8,977 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011901 NV 5,989 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011902 NV 7,520 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011903 NV 7,480 Bank of America; Chase bank; parking lot 1980 0.00 4th/Arizona withdrawn project 4 AP 1324 5TH ST 4291011904 NV 7,520 Bank of America; Chase bank; parking lot 2013 0.00 4th/Arizona withdrawn project 4 AP 1326 5TH ST 4291011905 NV 7,481 Bank of America; Chase bank; parking lot 2013 0.00 4th/Arizona withdrawn project 4 AP 1333 4TH ST 4291011910 BC 20,244 Bank of America; Chase bank; parking lot 1961 0.00 4th/Arizona withdrawn project 4 AP 1334 5TH ST 4291011908 NV 7,508 Bank of America; Chase bank; parking lot 2013 0.00 4th/Arizona withdrawn project 4 AQ 1318 4TH ST 4291012900 BC 22,484 Parking Structure 3 0.00 RFP for affordable housing issued 8.B.j Packet Pg. 766 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-66 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 4 AQ 1320 4TH STREET 4291012901 BC 7,504 Parking Structure 3 0.00 RFP for affordable housing issued 4 BQ 1217 14TH ST 4282003901 R3 7,510 public parking lot 12 behind petco 0.00 city owned parking lot - no leases with outside parties 4 BQ 1217 14TH ST 4282003900 R3 7,497 public parking lot 12 behind petco 0.00 city owned parking lot - no leases with outside parties 4 I 26TH STREET/OLYMPIC BLVD 4268014900 CAC 540 Bergamot Arts Center 0.00 existing Bergamot Arts Center; lease agreement with arts uses; must replace groundfloor arts uses 4 I 26TH STREET/OLYMPIC BLVD 4268013919 CAC 409,713 Bergamot Arts Center 0.00 existing Bergamot Arts Center; lease agreement with arts uses; must replace groundfloor arts uses 4 1146 16TH STREET 4281005900 R2 7,499 public parking lot 8 behind Café Zella (city owned) 0.00 city owned parking lot - no leases with outside parties 4 1217 EUCLID STREET 4282004900 R3 14,994 public parking lot 7 behind LaMonarca Bakery 0.00 city owned parking lot - no leases with outside parties 5 AB 1421 LINCOLN BLVD 4282027021 LT 7,516 parking lot for CVS pharmacy 0.00 common ownership to adjacent parcel 5 AG 4282035002 MUBL 7,482 parking lot for automotive service center building 1522-1530 Broadway 0.02 common ownership with adjacent parcel 5 AJ 3101 LINCOLN BLVD 4285036002 GC 4,820 parking lot for georges burgers 0.00 single tenant; underutilized parcel with common ownership 5 B 4267007003 MUB 4,394 New Balance store parking lot 0.00 past interest in development; common ownership with adjacent parcels 5 B 2616 WILSHIRE BLVD 4267007002 MUB 4,393 New Balance store parking lot 0.00 past interest in development; common ownership with adjacent parcels 5 BR 907 SANTA MONICA BLVD 4282011033 GC 2,494 small private parking lot for auto repair and Tuesday morning 0.00 common ownership- could be developed with Tuesday Morning site 5 CJ 1453 25TH ST 4275001013 MUBL 7,002 parking lot for Helen's cycles 0.00 common ownership see 1457 25th 5 F 1547 26TH ST 4267022018 OC 8,107 parking lot for one story vacant commercial office building 0.00 common ownership - see 2601 Colorado 5 F 2615 COLORADO AVE 4267022015 OC 5,966 parking lot for one story vacant commercial office building 0.02 common ownership to 3 other parcels - see 2601 Colorado 5 K 3125 PICO BLVD 4274034023 NC 5,005 parking for closed Valentinos restaurant 0.00 common ownership with adjacent parcel; vacant building 5 M 2306 SANTA MONICA BLVD 4275005002 MUBL 7,002 parking lot for 2300 santa monica (cynergy) 0.00 common ownership with adjacent parcel; single tenant 5 N 4275009012 MUBL 7,500 parking lot for one-story to two story building with iron gym and creative office tenants 0.01 recently sold building; location on Broadway near other residential uses make it likely it will turn over; common ownership (see 1457 19th street) 5 O 4276022001 MUBL 5,229 parking lot for laundromat 0.01 common ownership with 3 adjacent parcels; corner lot 5 O 4276022004 MUBL 5,196 parking lot for auto repair 0.09 common ownership with 3 adjacent parcels; corner lot 5 U 1348 14TH ST 4282015011 GC 7,515 parking lot for Truxtons restaurant and Bar 0.01 common ownership w/ adjacent parcels (1327-1333 Santa Monica Blvd) 5 Y 1214 SANTA MONICA BLVD 4282023022 GC 2,509 parking lot with vacant auto repair 1975 0.05 common ownership w/ adjacent parcel; underutilized; one story autorepair 5 Y 1218 SANTA MONICA BLVD 4282023021 GC 7,504 parking lot with vacant auto repair 1925 0.11 common ownership w/ adjacent parcel; underutilized; one story autorepair 5 4268001038 BTV 38,548 Lionsgate parking lot 0.00 SCAG Helpr tool classifies this as a vacant site; owned by separate owner than Lionsgate parcel; used as Lionsgate parking 5 4283010001 MUBL 7,495 parking lot for one story vacant office building 0.00 could be developed with adjacent vacant parcel on corner 5 1541 15TH ST 4282035014 MUBL 7,510 parking lot for SM Conservatory 0.00 property owner expressed interest in 100% affordable 5 1716 BERKELEY ST 4268009019 CCS 11,703 parking lot serving underparked industrial uses 0.05 underutilized lot; medium size could be developed for affordable housing; owned by housing provider 6 AD 12TH STREET AND BROADWAY 4282032002 MUBL 7,487 Ford auto storage parking lot 0.00 common ownership with adjacent parcel; southwest corner 6 AD 1222 BROADWAY 4282032001 MUBL 7,487 Ford auto storage parking lot 1956 0.02 common ownership with adjacent parcel; southwest corner 6 AE 1544 14TH ST 4282033010 MUBL 7,484 Paint and body shop auto storage (see 1538 14th st) 1957 0.04 common ownership with adjacent parcel used as parking lot; one story service bays 6 AF 12TH STREET AND BROADWAY 4282033018 MUBL 4,986 Ford auto storage parking lot 0.08 common ownership with adjacent parcel; southeast corner 6 AF 12TH STREET AND BROADWAY 4282033020 MUBL 4,992 Ford auto storage parking lot 0.06 common ownership with adjacent parcel; southeast corner 6 AF 1310 BROADWAY 4282033019 MUBL 4,987 Ford auto storage parking lot 0.07 common ownership with adjacent parcel; southeast corner 8.B.j Packet Pg. 767 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-67 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 6 AK 2700 LINCOLN BLVD 4287017043 GC 5,609 parking lot for Big Q's auto repair - common ownership to 3 adjacent parcels 1946 0.00 for sale property; advertised for redevelopment potential; common ownership to adjacent parcel 6 AZ 3204 LINCOLN BLVD 4287032015 GC 2,014 auto repair shop parking lot 0.00 adjacent common ownership (see 3204 lincoln); one story auto with parking lot 6 AZ 3204 LINCOLN BLVD 4287032016 GC 1,521 auto repair shop parking lot 1973 0.00 adjacent common ownership (see 3204 lincoln); one story auto with parking lot 6 BB 1348 18TH ST 4276030010 GC 7,506 Honda auto storage 1977 0.00 common ownership with adjacent 2 parcels used also as parking; comprises one of many surface lots for Honda 6 BF 832 SANTA MONICA BLVD 4282027003 GC 7,493 Toyota auto storage 1958 0.02 common ownership with adjacent 888 SM Blvd and R2 parcels (1418-1424 9th); offsite lot - main dealership across the street on Lincoln 6 BK 1411 17TH ST 4275011023 GC 7,500 off-site parking lot for auto storage 1921 0.25 for sale property; no common ownership but adjacent to vacant two story auto showroom building at 1710 Santa Monica 6 CB 1447 18TH ST 4275010015 MUBL 7,500 parking lot for Herman's auto repair 0.26 large site; auto storage; 3 adjacent parcels with common ownership (see 1449 18th) 6 CB 1807 BROADWAY 4275010013 MUBL 7,500 parking lot for Herman's auto repair 0.01 large site; auto storage; 3 adjacent parcels with common ownership (see 1449 18th) 6 T 1201 SANTA MONICA BLVD 4282014026 GC 22,473 BMW auto storage 1969 0.08 common ownership with adjacent parcel - large separte inventory lot; main dealership is across alley at 1187 Santa Monica Blvd 6 T 1337 12TH ST 4282014016 GC 14,994 BMW auto storage 1964 0.02 common ownership with adjacent parcel - large separte inventory lot; main dealership is across alley at 1187 Santa Monica Blvd 6 W 1418 16TH ST 4282020004 GC 7,494 Lexus parking lot - used car lot/service lot 1964 0.00 lot is used to sell used cars; Main Lexus dealership is at 1501 Santa Monica Blvd; dealership may consolidate its operations 6 W 1530 SANTA MONICA BLVD 4282020001 GC 7,510 Lexus parking lot - used car lot/service lot 1952 0.00 lot is used to sell used cars; Main Lexus dealership is at 1501 Santa Monica Blvd; dealership may consolidate its operations 6 W 1530 SANTA MONICA BLVD 4282020002 GC 7,497 Lexus parking lot - used car lot/service lot 1952 0.00 lot is used to sell used cars; Main Lexus dealership is at 1501 Santa Monica Blvd; dealership may consolidate its operations 6 X 1308 SANTA MONICA BLVD 4282022024 GC 9,711 offsite auto storage lot for Suburu 1924 0.02 in 2020 was used for Mercedes Benz; currently used for Suburu; main dealership is at 1229 Santa Monica 6 X 1415 EUCLID ST 4282022023 GC 7,499 offsite auto storage lot for Suburu 1921 0.00 in 2020 was used for Mercedes Benz; currently used for Suburu; main dealership is at 1309 Santa Monica 6 Z 1335 LINCOLN BLVD 4282010019 LT 7,482 Toyota service repair lot 0.02 common ownership with adjacent parcel 6 Z 1339 LINCOLN BLVD 4282010018 LT 7,509 Toyota auto storage - service center lot 1913 0.03 common ownership with adjacent parcel 6 1415 12TH ST 4282023025 GC 37,478 offsite overflow Ford service & repair auto storage lot 1965 0.13 off-site overflow service and lot for Ford; large parcel; mostly surface parking with service bays; owned by Real estate developer 7 AI 1901 WILSHIRE BLVD 4276008010 MUB 10,498 one-story vacant House of Billiards building 1938 0.33 vacant space; corner parcel; for sale with 1141 19th St 7 AK 2720 LINCOLN BLVD 4287017044 GC 8,022 one story Big Q's auto repair 1969 0.21 active sales; advertised for redevelopment; Common ownership to 3 adjacent parcels - see 2700 lincoln 7 BC 3307 PICO BLVD 4274036002 NC 5,015 one story retail building 1938 0.48 5000 sf small parcel size; adjacent properties 3311, 3317 Pico also being sold concurrently 7 BC 3311 PICO BLVD 4274036003 NC 2,502 one story retail building 1948 0.58 small parcel size; adjacent sites 3307, 3317 Pico being sold concurrently 7 BC 3317 PICO BLVD 4274036027 NC 6,777 one-story auto repair shop 1974 0.16 small parcel size; adjacent parcels 3307, 3311 Pico being sold concurrently 7 BD 3018 PICO BLVD 4270006041 NC 5,958 one-story retail building 1950 0.68 all 3 adjacent parcels for sale (3018-3030 Pico) 7 BD 3024 PICO BLVD 4270006042 NC 5,775 two-story apartment building 1957 0.89 all 3 adjacent parcels for sale (3018-3030 Pico) 7 BD 3026 PICO BLVD 4270006043 NC 5,579 two story commercial retail building 1955 0.88 all 3 adjacent parcels for sale (3018-3030 Pico) 7 BE 1450 20TH ST 4275009009 MUBL 22,500 Part of Big Jos burgers 0.54 for sale property; with adjacent parcels; large underutilized site 7 BE 1925 BROADWAY 4275009010 MUBL 7,500 parking lot for Big Jos burger 1957 0.42 for sale property; very undertilized site with single story tenant and large lot; advertised for redevleopment opportunity 7 N 1457 19TH ST 4275009011 MUBL 15,000 one story iron gym and creative office with parking lot (common ownership) 1948 0.28 recently sold building; location on Broadway near other residential uses make it likely it will turn over; common ownership (see 1457 19th street) 7 V 1619 1/2 SANTA MONICA BLVD 4282018010 GC 3,212 vacant car sales lot; recently sold 1960 0.26 common ownership with adjacent parcel; recently sold 7 V 1619 SANTA MONICA BLVD 4282018012 GC 4,282 vacant car sales lot; recently sold 1977 0.26 common ownership with adjacent parcel; recently sold 8.B.j Packet Pg. 768 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-68 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 7 1634 20TH ST 4275025002 IC 19,662 two-story office building 1925 0.05 older building; In IC north of Olympic Boulevard adjacent to bike path; proximity to existing residential; for sale; with preassessment for affordable housing already done 7 1703 OCEAN PARK BLVD 4273023032 NC 14,021 one-story Burger restaurant and laundrymat 1974 0.85 one-story multitenant retail building with large parking; corner large parcel; recently sold 7 2316 LINCOLN BLVD 4289001007 GC 14,104 one-story retail (recliner sales) building 1953 0.14 on Lincoln Boulevard with high development potential; larger parcel on corner 7 2510 PICO BLVD 4270001023 NC 18,171 car wash 1960 0.28 large parcel with access from side street; new owner indicate future residential development interest 8 AB 1411 LINCOLN BLVD 4282027029 LT 14,994 CVS pharmacy 1948 0.34 in DT; adajcent parcel is parking lot 8 AE 1323 COLORADO AVE 4282033011 MUBL 22,495 Paint and body shop 1952 0.09 location is ideal as it is located across from park; common ownership with adjacent parcels; one story service bays 8 AV 1719 WILSHIRE BLVD 4276010037 MUB 18,769 one story Enterprise car rental 0.13 one story with parking lot; common ownership with adjacent parcel at 1723 wilshire; large site 8 AW 2202 BROADWAY 4275016007 MUBL 35,989 one-story Ferguson plumbing and lighting 1950 0.28 one story single tenant light industrial; common ownership with adjacent parcel 8 AW 2218 BROADWAY 4275016005 MUBL 19,800 one-story Ferguson plumbing and lighting 1947 0.54 proximity to redeveloping residential parcels across; large sized lot 8 BF 888 SANTA MONICA BLVD 4282027032 GC 15,005 Toyota auto storage 0.57 common ownership with adjacent parcel 8 CD 2711 WILSHIRE BLVD 4266016100 MUB 28,663 Chase bank building with rear parking 1977 0.32 sheer size of lot may make this property desirable for redevelopment; adjacent rear parking lot see 1135 Princeton 8 L 2601 WILSHIRE BLVD 4266016054 MUB 15,365 76 gas station 0.00 large size parcel; corner; access to alley; gas station may make it undesirable to sell; common ownership with Sonny Mclean 8 1020 WILSHIRE BLVD 4282007025 MUB 17,502 one-story Belcampo restaurant building 1960 0.46 single tenant; low scale; next to Apartments.com; large parcel; could be developed with 1018 Wilshire but no common ownership 8 1025 WILSHIRE BLVD 4281027033 MUB 22,517 one-story El Cholo restaurant 1932 0.15 large parcel small restaurant; lots of parking 8 1100 SANTA MONICA BLVD 4282024026 GC 14,992 Toyota preowned center 1942 0.26 large parcel; corner 8 1102 BROADWAY 4282031032 MUBL 22,486 small one story office tenants; appears mostly vacant 1975 0.45 large parcel on corner; includes parking 8 1224 5TH ST 4291004016 NV 14,986 one story office building 1962 0.20 doublewide lot 8 1234 WILSHIRE BLVD 4282005001 MUB 14,993 one-story Ulta building 1946 0.37 large lot; low scale; single tenant; corner parcel 8 1420 WILSHIRE BLVD 4282003001 MUB 29,976 one-story Audio and Video center and Bank of America 1953 0.67 corner parcel; two tenants; rear adjacent parking parcel owned by Bank of America 8 1453 14TH ST 4282021013 MUBL 22,518 one-story building with 3 tenants, Paint lab and small creative office 1925 0.43 low scale building; new development adjacent to north 8 1624 LINCOLN BLVD 4290001012 LT 22,288 car wash 1972 0.09 next to affordable housing; part of development trends occuring on Lincoln 8 1701 WILSHIRE BLVD 4276010035 MUB 13,497 one-story vacant Mens Warehouse 1961 0.49 single tenant is bankrupt; vacant building; alley access; corner 8 1907 WILSHIRE BLVD 4276008023 MUB 15,009 one-story restaurant (Chandi) 1966 0.31 prospective owners with interest to redevelop; single tenant; one story 8 2020 WILSHIRE BLVD 4276014025 MUB 19,574 one-story restaurant and nightclub (Opaque Restaurant and Senator Jones club) 1955 0.10 rear parcel is R2 parking lot; low scale; few tenants; could be developed in conjunction with 2030 Wilshire but no common ownership 8 2230 BROADWAY 4275016024 MUBL 21,600 one story creative office building 1948 0.41 vacant space; large parcel; single story 8 2308 BROADWAY 4275016028 MUBL 27,773 one story creative office building 1948 0.35 large lot; proximity to redeveloping residentail across 8 2411 PICO BLVD 4274006023 MUBL 17,664 one story auto repair shop 1966 0.14 large one story auto repair with parking; adjacent to residential; large parcel; single tenant 8 2520 SANTA MONICA BLVD 4275001024 MUBL 20,962 one-story Goodwill building 1962 1.17 large parcel on corner; single tenant 8 2730 SANTA MONICA BLVD 4267020026 MUBL 28,573 one-story AAA building 1965 0.33 access to side street; large parcel; underutilized with access to transit 8 2802 SANTA MONICA BLVD 4267019028 MUBL 14,451 one-story office (roque and mark) building 1965 0.43 two frontages with rear parking; doublelot on corner; access to alley; single tenant 8.B.j Packet Pg. 769 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City of Santa Monica 2021-2029 Housing Element F-69 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 8 2828 WILSHIRE BLVD 4267005009 MUB 29,264 one-story commercial building, Vitamin Store and vacant restaurant space 1949 0.25 big parcel; two frontages 8 2914 WILSHIRE BLVD 4267004015 MUB 25,528 two-story LA mattress store with office 1949 0.66 one story retail with office above; multiple tenants; rear parking; larger parcel 8 2933 SANTA MONICA BLVD 4267011025 MUBL 19,147 one story Wine Expo 1948 0.18 two frontages; single tenant 8 1651 16TH ST 4283010900 MUBL 161,263 vacant SMMUSD headquarters building 1976 0.00 SMMUSD indicated interest in redeveloping for worker housing 9 BA 2800 LINCOLN BLVD 4287017045 GC 21,519 one story car wash 1961 0.19 large parcel decent size; single tenant; common ownership with parcel 4287017018 9 BR 901 SANTA MONICA BLVD 4282011034 GC 15,006 one-story Tuesday Morning store 1976 0.17 large parcel; corner parcel; single tenant 9 CX 1832 FRANKLIN ST 4268011006 MUC 17,921 one story creative office 1951 0.12 owner inquiry on site history; demolition of existing building applied for recently; new ownership in LLC 9 CX 3122 NEBRASKA AVE 4268011004 MUC 20,010 one story light industrial 1950 0.32 large parcel; recently acquired with adjacent parcels with LLC 9 1724 STANFORD ST 4268003003 MUC 31,503 one story light industrial 1927 0.01 appears to be Volkswagen off site storage lot and service bays 9 1740 STANFORD ST 4268003002 MUC 29,308 one story creative office 1957 0.22 large parcel; acquired into LLC; ownership by developer 10 AE 1538 14TH ST 4282033009 MUBL 7,485 Paint and body shop 1955 0.00 common ownership with adjacent parcel; one story service bays 10 AG 1520 BROADWAY 4282035001 MUBL 7,510 one-story auto parts building 1976 0.49 common ownership with adjacent parking lot parcel; building seems to be used only for storage; corner parcel with alley access 10 AJ 3101 LINCOLN BLVD 4285036001 GC 4,749 one-story Georges burgers restaurant 1968 0.49 large parcel on corner; single tenant; common ownership with parking lot parcel 10 AV 1723 WILSHIRE BLVD 4276010025 MUB 7,500 parking lot for Enterprise Rental 1976 0.06 recently sold with 1719 Wilshire; enterprise rental 10 AZ 3204 LINCOLN BLVD 4287032014 GC 1,988 one story auto repair shops 1960 0.15 adjacent common ownership (see 3204 lincoln); one story auto with parking lot 10 BB 1719 SANTA MONICA BLVD 4276030011 GC 14,986 Honda dealership with surface inventory 1977 0.07 common ownership with adjacent 2 parcels (1344-1348 18th St); main dealership at 1337 Euclid/1301 Santa Monica Blvd 10 BJ 2624 WILSHIRE BLVD 4267007004 MUB 4,405 one-story restaurant 1932 0.15 common ownership to adjacent 2 parcels 10 BJ 2628 WILSHIRE BLVD 4267007005 MUB 4,404 one-story mathnasium and salon 1959 0.29 common ownership to adjacent 2 parcels 10 BJ 2636 WILSHIRE BLVD 4267007006 MUB 5,481 one-story mathnasium and salon 1949 0.28 common ownership to adjacent 2 parcels 10 BK 1710 SANTA MONICA BLVD 4275011025 GC 10,000 two-story vacant building 1946 0.49 vacant auto showroom with parking lot; recently sold 10 BR 911 SANTA MONICA BLVD 4282011015 GC 5,004 part of Tuesday morning site 1963 0.25 common ownership to Tuesday morning parking lot site 10 CB 1449 18TH ST 4275010014 MUBL 7,500 parking lot for Herman's auto repair 0.00 large site; auto storage; 3 adjacent parcels with common ownership (see 1449 18th) 10 CJ 1457 25TH ST 4275001012 MUBL 7,002 one-story Helen's cycle 1963 0.40 one story; single tenant; with rear parking lot 10 D 3011 SANTA MONICA BLVD 4267012003 MUBL 7,187 small one story dentist 1953 0.16 common ownership with adjacent parcel developed with old office 10 D 3017 SANTA MONICA BLVD 4267012004 MUBL 7,214 two story office 1969 0.15 common ownership with adjacent parcel 10 F 2601 COLORADO AVE 4267022017 OC 6,066 one story vacant commercial building 1946 0.33 currently vacant; common ownership to 3 other adjacent parcels (see 2601 Colorado) 10 F 2615 COLORADO AVE 4267022016 OC 5,977 one-story vacant commercial building 0.35 vacant building, for lease; common ownership to 3 other parcels (see 2601 Colorado) 10 J 2008 PICO BLVD 4273003002 NC 2,497 one-story campos taco with lot 0.00 large lot with parking; common ownership; single tenant 10 J 2008 PICO BLVD 4273003001 NC 4,722 one-story campos taco with lot 1948 0.15 large lot with parking; common ownership; single tenant 10 J 2010 PICO BLVD 4273003003 NC 6,491 one-story campos taco with lot 1949 0.13 large lot with parking; common ownership; single tenant 10 K 3115 PICO BLVD 4274034031 NC 7,502 closed Valentino's restaurant 1945 0.32 common ownership with adjacent parcel; vacant building 10 L 2615 WILSHIRE BLVD 4266016055 MUB 5,508 one story bar Sonny Mcleans 1940 0.30 sonny mcleans; common ownership with adjacent 76 station 10 M 2312 SANTA MONICA BLVD 4275005020 MUBL 5,553 one-story retail store - cynergy cycle 1940 0.40 common ownership with adjacent parcel; single tenant 8.B.j Packet Pg. 770 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-70 Category Consolidated Site Address Parcel No. Zoning District Land Area Existing Use Building Age ILR Optional Information 10 O 2439 SANTA MONICA BLVD 4276022002 MUBL 5,195 one story laundromat 1948 0.32 common ownership with 3 adjacent parcels; corner lot 10 O 2445 SANTA MONICA BLVD 4276022003 MUBL 5,207 one story auto repair 1946 0.28 common ownership with 3 adjacent parcels; corner lot 10 Q 1414 18TH ST 4275011002 GC 7,500 parking for vacant Honda service repair 0.27 formerly the Honda service center at 1726 Santa Monica Blvd which has since left; large site in combination with adjacent parcel 10 Q 1726 SANTA MONICA BLVD 4275011001 GC 15,000 two-story vacant Honda service center 1976 0.28 vacant; common ownership with 3 adjacent parcels 10 U 1323 SANTA MONICA BLVD 4282015013 GC 4,998 one-story Truxton restaurant and Bar 1923 0.10 common ownership with rear and adjacent parking parcel; two tenants on-site; corner parcel 10 W 1530 SANTA MONICA BLVD 4282020003 GC 7,509 Lexus auto storage 1952 0.00 auto storage for service center 10 Y 1200 SANTA MONICA BLVD 4282023023 GC 4,978 parking lot with vacant auto repair 1962 0.03 common ownership w/ adjacent parcel; underutilized; one story autorepair 10 3232 SANTA MONICA BLVD 4267015027 MUBL 13,878 one story retail building (keyboard store) 1968 0.42 single tenant; large parcel; corner lot; 11 1140 7TH ST 4292005007 R2 7,497 St Monica Church parking lot DA indicates that affordable housing shall be constructed as priority 11 1257 CENTINELA AVE 4267001016 R2 42,631 Church of Jesus Christ parking lot 1948 large parking lot 11 1343 OCEAN PARK BLVD 4284025028 R3 25,777 Mt Olive Church with large parking 1962 has express interest; half of site is parking lot 11 3114 3RD ST 4287038027 OP2 22,603 St Clement Church parking 1956 large separate parking 11 801 WASHINGTON AVE 4281033024 R2 15,012 parking lot for Saint Pauls Lutheran Church (blank) 11 BH 925 CALIFORNIA AVE 4281029012 R2 4,993 Vintage Church trinity house parking lot 1967 double lot 11 BH 929 CALIFORNIA AVE 4281029011 R2 5,017 Vintage Church trinity house parking lot 1967 double lot 12 CN 4276012027 R2 22,500 large parking lot for Rite Aid off Pico existing parking lot in rear of retail diagonal across from Rite Aid; large size lot 12 S 4282010011 R3 7,493 parking lot for Toyota A-Lot; parking in rear of 825 SMB project 12 BA 4287017018 OP2 5,659 parking lot for car wash on lincoln 1961 common ownership to vacant car wash fronting Lincoln but zoned OP2 12 CC 1122 14TH ST 4281012024 R2 37,532 Rite aid parking lot off Wilshire common ownership to Rite Aid fronting Wilshire 12 CD 1135 PRINCETON ST 4266016045 R2 21,913 Chase Bank parking lot common ownership to Chase bank; large parcel 12 AI 1143 19TH ST 4276008009 R2 7,192 parking lot for sale; with 1901 Wilshire; common ownership 12 B 1215 26TH ST 4267007030 R2 6,377 parking lot for New balance store A-Lot; parking lot for New balance; common ownership 12 CM 1219 PRINCETON ST 4267006012 R2 6,983 parking lot for multi tenant retail A-Lot; common ownership to front wilshire parcel; Pacific Dining Car vacant restaurant 12 CN 1223 18TH ST 4276012018 R2 7,486 large parking lot for Rite Aid off Pico existing parking in rear of retail; large adjacent common ownership in front but riteaid may not leave 12 Q 1418 18TH ST 4275011003 R2 7,500 parking structure for former Honda service center service center appears to have moved; common ownership with adjacent two parcel 12 BF 1418 9TH ST 4282027004 R3 7,492 Toyota parking lot 1925 A-Lot; common ownership to 2 other parcels 12 1424 9TH ST 4282027005 R3 7,503 CVS parking lot A-Lot 12 1847 16TH ST 4283032024 R2 6,040 vacant lot undeveloped; no structures 12 528 SAN VICENTE BLVD 4293004010 R2 11,074 vacant lot undeveloped; no structures 12 621 PACIFIC ST 4289005013 OP2 5,865 vacant lot undeveloped; no structures 8.B.j Packet Pg. 771 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 1 Vernice Hankins From:Clerk Mailbox Sent:Thursday, June 16, 2022 11:26 PM To:councilmtgitems Subject:FW: Housing Commission Recommendations to City Council regarding Draft Redline Revisions to the Adopted 6th Cycle Housing Element Update From: Leonora <leonorasc@gmail.com> Sent: Thursday, June 16, 2022 9:07 PM To: Theresa Marasco <Theresa.Marasco@santamonica.gov>; leslielambert92 <leslielambert92@gmail.com>; Council Mailbox <Council.Mailbox@santamonica.gov>; Clerk Mailbox <Clerk.Mailbox@santamonica.gov>; Planning Commission Comments <planningcomment@santamonica.gov> Subject: Housing Commission Recommendations to City Council regarding Draft Redline Revisions to the Adopted 6th Cycle Housing Element Update EXTERNAL Below please find the recommendations passed by the Housing Commission on 6/16/22. - Ensure affordable housing is not just a paper exercise and obtain revenue sources to make affordable housing a reality, inclusive of increased efficiency in the current budgetary process, and more robust resources for affordable housing. - Prioritize affordable housing in historically blue and green lined neighborhoods. - Inaction has contributed to the segregation that exists and the City should take meaningful action to physically redistribute affordable housing equitably across the city. Steps are long overdue. There are no neutral actions and the City cannot fail to act. Leonora Camner Housing Commissioner On Behalf of Santa Monica Housing Commission Item 8.B 06/21/22 1 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 772 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 2 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 773 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 3 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 774 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 4 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 775 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 5 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 776 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 6 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 777 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 7 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 778 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 8 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 779 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 9 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 780 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 10 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 781 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 11 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 782 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Item 8.B 06/21/22 12 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 783 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) REPEAL ARTICLE 34 in the CA state constitution; USE public land for PUBLIC GOOD, end systematic housing violence & displacement. Article 34 of the CA constitution reads; “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 qualied electors of the city, town or county, as the case may be..” Localities that have been abusing their positions and segregating cities by race & class should not decide what happens to public land. Workers that commute into cities also have the right to decide what happens to public land, retirees, college students, and many others also have that right! “Heidi Marston resigns from LASHA,citing dicultiesin fullling LAHSA's mission without "fundamental shifts". In her resignationletter, Marston elaborates: "Power and funding alone control homelessness. But in our current system, organizations like the one I lead, the Los Angeles Homeless Services Authority (LAHSA), are not given control over regulatory or policy decisions, service providers remain underfunded, and dedicated front-line employees of non-prot organizations and government entities are hamstrung by rules, red tape, and bureaucracy. Marston also points to low wages, high rents, restrictive zoning laws, and other "shadow monsters'' we must tackle in order to end homelessness." https://medium.com/@hmarston2/the-homelessness-crisis-a-monster-of-our-own-maki ng-be5975399ce1 1 Item 8.B 06/21/22 13 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 784 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Structural Governance of the Social Housing Authority The State Housing Authority -HCD will oversee The Social Housing Authority; Community-led development of PS, aordable, & market-rate housing: Social Housing Agencies in each county in CA (ONE SOCIAL HOUSING AGENCY with selected progressive civil peers (community advocates) assigned to oces in each part of the county (likely NSEW & Mid-City, TBD);a group of progressive housing civilpeers that implements & develops new community-owned aordable, market-rate, and PS rental housing on publicly owned land throughout LA County. Communities are well put together, mostly in walkable, pedestrian/bike-friendly built communities. The agency as a collective whole will capture vacancy numbers (parking lots, buildings (privately & publicly owned), to determine ownership/best use for vacant spaces. The Social Housing Authority will override city councils in localities to partner directly with County BOS, and HCD to collect funding meant for homeless/housing 2 Item 8.B 06/21/22 14 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 785 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) spending, money goes into ONE TRUST account that must provide RECEIPTS of where/how much money is spent on specic projects. Agency works with HUD to implement new guidelines for aordable homeownership for the blue-collar working class. Agency maintains ONE website/database that has a list of AVAILABLE community-owned aordable, market-rate, and PS rental housing. List of AVAILABLE aordable & market-rate homeownership opportunities. Aordable housing waitlist for rental housing should be no longer than 6 months, 6 months is actually too long but should not exceed that. The social housing agency is focused on public safety, public safety means safety from heavy trac violence and climate arson. This means the social housing team works to build communities that are walkable, bike, and pedestrian-friendly. Communities that have access to green space. Communities that aren’t being heavily polluted by LAPD helicopter pilots (noise & fuel pollution linked to dementia, linked to cancer). Cars belong on the outside of multi-family communities, not within. Cars are occupying too much land space! Humans need land to live on, we shouldn’t NEED to drive everywhere. Create when possible 15-20 minute cities/small communities. 3 Item 8.B 06/21/22 15 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 786 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Social Agency is primarily focused on the development of community-owned housing. However, the agency will be divided into 3 primary teams; PSH, aordable & market-rate rentals, aordable & market-rate homeownership; Permanent Supportive Housing- PSH for residents in need of wraparound services. Services could be needed short or long-term depending on the person. This team is focused on securing housing for residents with low-to-no income, chronically homeless, FOSTER youth (up to age 24), disabilities etc. This team doesn’t provide the services it connects other agencies & non-prots to PS housing. This team maintains a database of PSH units that are available and works to revamp/remodel the broken shelter housing system to turn them into PSH. Again, ONE social service housing website for residents with varying needs. Foster Youth: safe and clean group homes that provide guidance & structure to youth/young adults up to the age of 24. REVAMP the broken Foster System; guidance comes from social workers that are based out of the revamped DPSS, non-prots, grassroots teams, etc.). PSH shouldn’t feel carceral (jail-prison like). 4 Item 8.B 06/21/22 16 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 787 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Supportive services are wraparound services in QUALITY family planning, STI/STD prevention/protection, mental, behavioral, & rehabilitation healthcare, etc, etc. Introduce UBI, money that should come from another trust account will not come from the housing trust fund. UBI for foster youth, and adult residents not working or below the poverty line. UBI up to $1000 a month for completed work/ treatment assignments. For displaced youth; completed schooling/work/etc. Standard UBI (no work /treatment assignments required) $300-$500. Repeating; services are provided by A REVAMPED DPSS, by grassroots and non-prot teams, etc. Agency will provide a civil peer court system; will also be for any potential cases of alleged abuse happening from workers but all workers must have ongoing training, schooling, and teachings in proper behavior when interacting with residents in PSH communities, especially foster youth! Service teams should meet every few months to go over what is and what is not working, the social housing agency does not provide the service, they are simply making available the housing needed for the residents in need of PSH, possibly in need of long term care, healing, community. The PSH Social Housing Team works with the DPSS to secure safe parking/dwelling zones within the county until PSH becomes available. All non-prot groups/service teams need to be an extension of this department (LASHA, DPSS, Grassroot teams, etc., etc.) Service teams should be able to contact PSH social agency team to nd PSH, Safe parking/dwelling, and/or to receive money for temporary hotel/room stays (FEMA MONEY should be used as the ONE trust account is mostly for development/maintenance/admin of community-owned housing. ONE TRUST per county social agency/authority). 5 Item 8.B 06/21/22 17 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 788 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-Owned aordable & market-rate Housing; residents are self-sucient, can pass a criminal background check likely just need assistance securing an aordable or market-rate unit. Will work with residents with a prior eviction.Community-owned aordable & market-raterental housing that is always aordable. Rent shouldn’t take more than 20-30% of a resident's total income after taxes. Establish an aordable rental market-rate price for the blue-collar working class. The aordable price should not be averaged with working-class/high income earners included in the calculation. Most workers, most jobs in LA County pay about $40,000. What is the average wage for the blue-collar worker??? Community-owned, market-rate units will likely be much cheaper than privately owned market-rate. All local city aordable housing authorities would be moved into the social agency/demolished.There are too many moving parts of the housing programs/processes. We need ONE coordinated system with FUNCTIONING non-prots, social service teams an extension of the one agency. Social workers, eld workers, and rehousing specialists should be able to utilize the agency/website to secure at a minimum safe parking/safe dwelling. Should be able to give food vouchers/stamps, etc. to those that need them. Again, the housing team is likely divided by local cities in the county, likely by NSEW & mid-city, TBD. Each of those divided teams will be divided into the 3 groups of; PSH, aordable & market-rate rentals, aordable & market-rate homeownership) Public Safety-A civil peer board of housing (court)will be established to hear cases about any potential threats to public safety happening in Socially owned housing. The court will also hear about allegations of any abuse happening within the system and 6 Item 8.B 06/21/22 18 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 789 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) correct the action. PSA on appropriate behavior will be provided to all residents/sta that are part of the social housing community. The goal of the Social Housing agency is to prevent displacement but they will support “JUST-CAUSE” eviction for tenants posing a risk/threat to other tenants. No gang activity or violence WILL be tolerated, the community has a right to safety, if that safety is ever threatened, residents in the community have the right to evict! Some PSH will be for residents in transition from jail/prison back into community living. Prevent ROOT CAUSE of problems that we areseeing in our community.Also, consider communities for disabled residents/ residents with special needs that may need long-term wraparound services. Consider partnership with community colleges for aordable housing for students/young adults up to age 24-25. Consider committed behavioral, mental, and rehabilitation health programs for residents with outstanding issues in above mentioned. Any committed programs should still be a place of healing, not further violence and trauma. Dismantle and rebuild existing programs in that area. Fix the problems at the ROOT, save the next generation and again, ongoing training, and schooling, for workers in this eld.HIGHER payfor workers in these elds! 7 Item 8.B 06/21/22 19 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 790 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) The private housing market can always exist if it likes but residents shouldn't be forced to rely on it. There are residents whose families have been dealing with generational housing violence as it relates to race & class, they cannot rely on a privately owned market that has no accountability! Rent has gone up by over 65% within the last 10 years in LA County with no rebuttal for the blue-collar working class, retirees, residents of generational housing violence and displacement, college students, foster youth, and many many others. 8 Item 8.B 06/21/22 20 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 791 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) 9 Item 8.B 06/21/22 21 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 792 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) This social agency will have nothing to do with private housing developments but it can purchase private housing and it can assist with securing housing for residents in privately owned housing. The Social Agency will maintain a website of AVAILABLE community-owned aordable, market-rate, and PS rental housing units. Privately owned units can also be listed. <<<WATCH CYBER FRAUD/SCAMS which is rampant on apartment rental websites. The social agency is being created to develop and implement new housing developments on vacant publicly owned land and remodels for publicly owned vacant buildings.The agency cannot deny community-owned housing developments in any neighborhood in LA County, they are a county-wide team that implements new developments of community-owned PS, aordable, and market-rate housing in ALL CITIES in the county, this includes SANTA MONICA, BEVERLY HILLS, WEST HOLLYWOOD, MARINA DEL REY, PASADENA, DOWNEY, LONG BEACH, etc., etc., etc., ALL CITIES IN LA COUNTY! The intentional segregation as it relates to race & class MUST end, THE NIMBY violence MUST END! For community-owned aordable & market-rate housing, long-term residents of LA County should get priority with housing placements,focusing on getting workers closer to their jobs. It is imperative for the health of humans, the health of the Earth, and other species that we reduce drive times, and reduce pollution. Preventing displacement is IMPERATIVE. The team can prevent displacement by subsidizing rent for tenants in privately owned units and/or helping move them to community-owned aordable housing. 10 Item 8.B 06/21/22 22 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 793 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Aordable homeownership-full proposal coming soon,introduce co-ops, CLT’s, and resell requirements. The primary focus is blue-collar workers (aordable with resell requirements) and market-rate housing. Use money from market-rate sales to place into the ONE trust account. Insert grassroots team to help with restorative justice aspects of homeownership for residents impacted by systematic racial violence. How do you think this story is going to end????????? Short-term rentals-introduce tourism short-term stays,money goes into the ONE trust account. Trust Account-One trust account that will be auditedby city/state controllers. Money comes from HUD, Feds, State, Donations, & HHH. The annual state surplus budget must donate a portion into trust every year. The tourism industry should be donating a portion of total earnings into the trust. The cannabis industry should be donating a portion of money into the trust, should be redirecting money to communities impacted by the “pretend war on drugs” created by the U.S Gov’t. A small portion is for admin/resident manager fees (try to avoid outsourcing resident management to other companies, which could run up costs). The largest portion of the trust is for housing development/property maintenance.)How much are CAtaxpayers giving in federal dollars to other states using the money for social services (TBD). 11 Item 8.B 06/21/22 23 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 794 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-owned housing cannot be sold to corporations.If TOPA is introduced, keep under CLT (land lease) to allow tenants to purchase their units but prevent corporations from being able to purchase***??? (verify).Also, any money given to nonprots to build aordable housing should mean that that housing cannot be sold to a corporation. How and why are some non-prots that received Gov’t/Taxpayer money able to sell aordable buildings after a set number of years to private corporations? Housing would go back to the social agency OR TOPA if the non-prot wanted to be released from oversight/responsibility. The Social Agency can buy privately owned property and resell it to private owners/corporations but NOT publicly owned land/housing, not rent nor ownership. Again, community-owned developments are going to be built with the community in mind, with green space, stores, hospitals, etc., sometimes worked/developed within the communities. Social Housing Plans ready for implementation; https://htwws.org/santamonicaairport/ (Author notes, not part of the proposal) -Examine the years that ADOS (American descendants of Survivors paid federal taxes but were not able to utilize public service. Examine displacement and communities that were intentionally burned t the ground by supremacists. Request reimbursement/hold percent of federal/state taxes to heal communities. -Tenancy in commonis a form of co-ownership of propertyin which each party owns an undivided interest that passes to his or her heirs at death. The interest is undivided 12 Item 8.B 06/21/22 24 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 795 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) because each tenant has rights in the whole property. Although ownership is in common, tenants may have equal or unequal shares. -Joint tenancyis the joint ownership of propertyby two or more co-owners in which each co-owner owns an undivided portion of the property. On the death of one of the joint tenants, their interest is automatically passed to surviving tenants. -Real property- immovable property, a building, land,plants etc, (though buildings can actually be moved depending on). -Just cause eviction in CLT -Community members causingviolence when corrective action cannot be taken, not working. Racial violence & other forms of discrimination. Peer court will recommend rehabilitation programs when permitted to do so, severe cases could result in immediate evictions. -Land on Earth belongs to all of humanity. -Land has not been fairly distributed to residents impacted by systematic housing violence as it relates to race & class. -The aim of the Surplus Land Act (the "Act"); is to increase the availability of real property in California for aordable housing development by requiring the prioritization of aordable housing when selling or leasing public lands no longer necessary for agency use. -"Feb. 5, 1866: Thaddeus Stevens Proposes Land DistributionAmendment" https://www.zinnedproject.org/news/tdih/thaddeus-stevens-freedmens-bill/ 13 Item 8.B 06/21/22 25 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 796 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -Foster City- examine the broken foster system, keeping families together whenever possible, family planning services, safe housing & family for youth that are not able to stay with their biological families. To do; -Write the state bar and include them on your housing emails. REQUIRE that the state bar authorize civil peers to oversee legal issues related to housing (LLP’s). -BLM the org must redirect funding into one trust that is overseen by a group of Black civil peers. Push money back into Black communities as direct UBI payment, as housing payments, treatment payments, crime & gang prevention, etc., etc. -Email OMBW/Watch for grants (GS) -Civilian Eminent Domain of Public Land; communities protected from Climate arson; Free market exists for those that want to be part of it. -Establish Public Bank -A PORTION of public land MUST remain PUBLICLY owned for use by the community. -Agency divided into NSEW & Mid-City?!?! Civil Peer teams in NSEW & Mid-City ?? -If the BOS goes ROUGE, the social agency will partner with the state housing authority directly and override county BOS should they become non-compliant. 14 Item 8.B 06/21/22 26 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 797 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) The Social Housing Authority (created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -representcal.org, why a constitutional conventionis necessary, and how the CA constitution allows localities to abuse their position, allows illegal segregation as it relates to race & class. -Examine pre-built tiny home/ADU placements in well put together communities that are aordable & supportive. Sheds are not tiny homes. Some residents already own tiny homes or they want to, can support themselves but need land. Communities likely could be supported in the valley. 15 Item 8.B 06/21/22 27 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 798 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 1 Vernice Hankins From:HowTheWest Was Saved <howthewestws@gmail.com> Sent:Monday, June 20, 2022 3:43 PM To:councilmtgitems Subject:06/21/22 Santa Monica City council meeting; Comment on item 8B, Housing Element Attachments:SocialHousingAuthority.TieiraRyder.4-25-22.pdf EXTERNAL Hello, We are asking HCD to support a county-led social housing team that is overseen by actual progressive housing advocates. Not much has changed in Santa Monica City's housing element and as a collective, we will NEVER get out of the housing crisis if we do not begin implementing a solid social housing policy across the entire U.S. Build more privately owned market-rate housing but residents cannot rely on a market that has proven unreliable! The source has already granted us all permission to live on Earth. Residents of varying "racial" & class backgrounds do not require the permission of another human to live anywhere on Earth. We must build housing in well-built communities that are walkable, bike- friendly, and affordable! The incorrectly zoned Santa Monica airport & penmar golf course MUST close in this housing cycle so that we can begin building housing surrounded by a large park! HCD, local residents are asking for your support in capturing PUBLIC land to be used for PUBLIC good. Localities that have been intentionally segregated by race & class cannot be expected to do the right thing. https://htwws.org/social-housing-ca/ ‐‐ Best, Item 8.B 06/21/22 28 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 799 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 2 Tieira https://htwws.org/santamonicaairport/ https://youtu.be/WSFf00y-0uA To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away. Item 8.B 06/21/22 29 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 800 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 2021-2022 EXECUTIVE COMMITTEE Julie Rusk, chair John Maceri, past chair Karen Gunn, vice chair Jody Priselac, vice chair Natalya Zernitskaya, secretary Perry Roshan-Zamir, treasurer BOARD OF DIRECTORS Gary Avrech Sheila Banani Tara Baraukas Claudia Bautista-Nichols Lindsay Call Stephanie Cohen Timothy Conley Donna Gentry Ana Maria Jara Shawn Landres Ashley London Janet Gollery McKeithen Thomas McLaughlin Jessy Morales Tara Pomposini Cynthia Rose Laura Rosenbaum Eric Shafer Cecilia Tovar Nat Trives Angel Villaseñor Michele Wittig Leila Youssefi Donald Zelaya EMERITUS BOARD MEMBERS Debra Farmer Misti Kerns The Human Relations Council of Santa Monica Bay Area is a non-profit organization that promotes a culture of fair treatment, inclusion and equal access to opportunities. P.O. Box 1307 • Santa Monica, CA 90406 -1307 :hrcsantamonica.org :humanrelationscouncilsantamonicabay June 8, 2022 Re: June 28, 2022 Council Adoption of FY 2022/23 City of Santa Monica Budget Dear Mayor, City Council and City Staff: The Human Relations Council (HRC) of Santa Monica Bay Area is a nonprofit organization that promotes a culture of fair treatment, inclusion, and equal access to opportunities. As such, we are deeply committed to equitable, sustained, creative and user-friendly community engagement and public participation. •We appreciate the City Council and staff commitment to greater access for public participation in Council and Board/Commission meetings through your support for “hybrid” meetings and provision of language access services. This includes call-in and virtual options for public comment and readily available translation and interpretation services, particularly in Spanish and Amharic. We strongly believe that enabling greater public access in these ways is one required step to further the City’s goals of becoming a more equitable and inclusive community. •We further encourage the City Council to provide the resources needed to support the City staff-created Equity Action Plan designed to ensure increased awareness, action and improved equity outcomes across all City departments. In summary, we eagerly anticipate implementation progress across all departments on the City’s Equity Action Plan. Genuine and sustained progress on this Plan along with support for those who may not be able to attend in-person meetings and those who may need language support are foundational for a more diverse, equitable, and inclusive Santa Monica for all. When you adopt the FY 2022/23 City budget and department priorities, please adequately fund and restate your priority for this necessary and essential work. Thank you for your service to the people who live, work and visit Santa Monica. On Behalf of HRC Board With Kind Regards, Julie Rusk Item 8.B 06/21/22 30 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 801 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 1 Vernice Hankins From:Debra Shepherd <daysonthespectrum@gmail.com> Sent:Tuesday, June 21, 2022 11:28 AM To:councilmtgitems Subject:Item 8B EXTERNAL Good day Councilmembers: I'm writing to you as a 20 plus year resident of the city of Santa Monica. I am also a person with lived experience of homelessness. I am currently a participant in the housing voucher program. I know that you have a lot of input about housing, but I don't know how much of it actually comes from people like me. I watch your meetings regularly. Most feedback comes from people, who are insulated by their privilege. They have no lived experience of struggling for basic necessities. When a person is struggling to pay rent, or they are unhoused, it's like drowning. It's a crisis that requires extraordinary measures. For the last 20 years, I have watched people kill projects with their privilege, that would have provided hundreds of units of affordable housing. The number of required units from the state is the result of that. It's not the state of California unfairly singling out the city of Santa Monica. We earned this number. It's time for us to accept the requirement, and do whatever is necessary to meet it. Best Regards, Debra Shepherd Santa Monica resident Item 8.B 06/21/22 31 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 802 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 2 Vernice Hankins From:ml.verville@verizon.net Sent:Tuesday, June 21, 2022 11:06 AM To:Sue Himmelrich; Kristin McCowan; Phil Brock; Gleam Davis; Lana Negrete; Christine Parra; Oscar de la Torre Cc:councilmtgitems Subject:Agenda Item 8.B: Housing Element Draft Redline Revisions EXTERNAL Dear Santa Monica City Council, As these Staff‐recommended revisions are reviewed, it should be noted that the Council’s actions in complying with the over‐reaching and counter‐productive state legislation will only serve to further undermine any future challenge the City may decide to undertake. Agenda Item 8.B Housing Element Draft Redline Revisions is simply the City’s latest action of acquiescence, dating back to 2019. This sets the stage to further undermine the community wellbeing, further ration fixed amenities such as parks, and compromise the City’s already challenged long term financial situation. To be specific, the financial downside is amplified by the simultaneous increase in (unfunded) service and infrastructure requirements and the initiative to convert destination retail space to residential, eliminating city sales tax revenues in the process. This strategy leaves significant tax increases on existing residents as the only option. The reality of Santa Monica’s housing capacity and history of addition Santa Monica’s has added so much housing that its current stock translated into 1.78 residents per housing unit according to the 2020 census. To place this into context, the City of Los Angeles is 46% higher at 2.61 residents per housing unit. The Statewide average of 2.75 residents per housing unit is 54% higher than Santa Monica. Santa Monica has one of the lowest levels of any city in the state. How did Santa Monica achieve such housing abundance? Since 1960, Santa Monica has added a net 1.5 housing units for each new resident, children included. This translates into 14,795 net new housing units servicing a net population increase of 9,794. Item 8.B 06/21/22 32 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 803 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 3 In fact, Santa Monica kept building new housing units even in decades that experienced net declines in city population! During the 1980s and 1990s, Santa Monica had a 4,230 net decline in population. Despite that decline, the city built 1,445 net new housing units during that same period. To be clear, that 60‐year building trend was not in response any historical overcrowding. In 1960, the average number of people per housing unit in Santa Monica was 2.23. The 2.65 in the City of Los Angeles was 19% higher than Santa Monica. The average over the entire State in 1960 was 2.88, 29% higher than Santa Monica. Moreover, since 1980s, Santa Monica has added 4,000 affordable housing units, representing about 70% of the housing stock added since 1980 and 10% of the City’s entire current multi‐ family housing stock. Despite this housing abundance reality, the Council has yet to seriously challenge the arbitrary and onerous state allocations. The state‐defined shortage in Santa Monica relates to residents, NOT housing. To be clear, Santa Monica does not have a shortage of housing. According to the arbitrary RHNA process that this item relates to, the State has actually deemed that Santa Monica has a shortage of new residents. By definition, any “solution” to this misdirected state‐defined “problem” provides no benefit to current residents and will – in fact – be to their detriment. If the Council continues to service this unsupported and unjustified RHNA process, it will be decreasing its ability to defend its residents, which is one of the City Council’s core responsibilities. How does the State justify the need for increasing residents in Santa Monica? Out of the 8,895 units of housing being required by the State, 1,156 units (13%) are acknowledged as the true future organic growth requirement of the City in the next eight years. The other 7,739 units (87%) are related to hypothetical concepts of “existing need” which are defined as 4,300 units that should be built due to the existence of “high quality Item 8.B 06/21/22 33 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 804 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 4 transit areas” (HQTA) – bus stops – and 2,749 units due to proximity to places of employment. Then there is a catchall of around 690 more units just for good measure. How relevant is this “existing need”? The state’s definition of HQTA has been defined as basic bus service. Yet, the BBB’s (and LA Metro) actual transit utility is so low that ridership is at an all‐time low, and remains in a decline that predated the pandemic. The jobs requirement is related to “workforce” housing. But, as cities such as Santa Monica are within larger metropolitan areas, the traditional (and only logical) concept has been to look at jobs and housing on a broader regional scale to account for the fact that as people change jobs, they do not need to change living location. Under the new state models, it appears that workers are conveniently assumed not to change jobs. But when they actually do, and they no longer work in Santa Monica, will they consequently lose their housing to make way for others who take their place in those Santa Monica jobs? Of course not. This is an opportunity for Council action to defend the residents The prior City Council failed the residents in pushing back against this nonsensical State overreach at its inception. Each iteration of staff compliance with State demands reduces the City’s ability to defend its residents. Does the Council want to continue on this path? Many residents feel that there needs to be a significant policy course correction. Thank you, Marc L. Verville Sunset Park Santa Monica Item 8.B 06/21/22 34 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 805 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 5 Vernice Hankins From:zinajosephs@aol.com Sent:Tuesday, June 21, 2022 10:33 AM To:councilmtgitems Cc:zinajosephs@aol.com; Phil Brock; Gleam Davis; Oscar de la Torre; Sue Himmelrich; Kristin McCowan; Lana Negrete; Christine Parra; Jing Yeo; David Martin; David White Subject:City Council 6/21 agenda item 8-B -- Revised Husing Element EXTERNAL Dear City Council members, Agenda item 8-B staff report: http://www.acgov.org/board/bos_calendar/documents/DocsAgendaReg_11_18_21/GENERAL%20ADMINISTRATION/Re gular%20Calendar/Housing_Element_RHNA_11_18_21.pdf 1) On page 3 of 8 of the staff report for item 8-A on the City Council's 6/21 agenda, it says that overall housing capacity was increased to over 13,000 units. Does that mean that Planning staff will then propose zoning changes to accommodate 13,000 additional housing units? Why do this when we're only required to zone for 9,000? 2) This plan includes allowing 300+ housing units at 4th/5th & Arizona, leaving no room for a park. 3) This plan includes allowing 700+ housing units at the Bergamot Arts Center. What will happen to the art galleries? 4) Up zoning even more of the city city than necessary for 9,000 housing units (which was a ridiculous number to begin with) will allow investors from near and far to buy up property for speculation. This will not benefit residents and, if that much housing is actually built, it will create enormous stress on city infrastructure, especially water. 5) Will outdoor watering restrictions eventually move from 2x per week to 2x per month? Why not just cut down all the trees in the city and be done with it, rather than watch them sicken and die from lack of water? 6) We can also go ahead and replace all the remaining grass with decomposed granite, asphalt, and cement, thus creating a gigantic heat island in Santa Monica. 7) In addition, legislation currently moving through the state legislature will remove all parking requirements for new construction, so imagine thousands of new daily car trips as residents drive around looking for street parking. What a great way to make a city unlivable. Zina Josephs (Santa Monica resident since 1970) Item 8.B 06/21/22 35 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 806 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 6 Vernice Hankins From:Daniel Galamba <galambadb@hotmail.com> Sent:Tuesday, June 21, 2022 9:38 AM To:councilmtgitems; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Sue Himmelrich; Kristin McCowan; Oscar de la Torre; Daniel Galamba Subject:June 21, 2022 City Council Meeting: Please Oppose Item 8.B. Housing Element Draft Redline Revisions EXTERNAL Dear City Council, I request that you oppose the draft Housing Element Redline Revisions. These revisions are based on a ridiculous RHNA assessment of 9,000 units that will result in Santa Monica's population increasing by 20% over 8 years with all the resulting traffic, congestion, gridlock, public services and infrastructure that go along with it. All not paid by the State. California's and Los Angeles County's population has increased by about 2% over the past 10 years. Santa Monica's population has increased by only about 3% over this same 10 year period. Therefore requiring a 20% increase in Santa Monica's population over 8 years is just simply up zoning so developers can make more money at our expense. These 9,000 units include 6,000 affordable units that will cost about $3 billion. Again, not paid by the State. We don't have $440 million to pay our unfunded pension obligations let alone $3 billion for 6,000 affordable units. Therefore, over time the requirement that these units be affordable will be dropped and market rate units will then go in there because there will be the money for that. This is just a two‐step process so developers can make more money at our expense. This will destroy our City as developers did in Westwood and West Los Angeles in the 1980's. Now people don't want to live in West Los Angeles anymore or come to Westwood Village or West Los Angeles anymore and both Westwood Village and West Los Angeles are going down hill and I don't want the same thing to happen to us in Santa Monica and it will. I therefore request that you suspend working with the State on these Housing Element Revisions and join other cities (e.g. Pasadena) in legal action against the State until the State accepts a RHNA that reflects a realistic 2‐3% population growth in Santa Monica over 8 years. Please don't let our City of Santa Monica be looted by greedy developers as they did in Westwood and West Los Angeles in the 1980's. Thank you. Sincerely, Dr Daniel Galamba Item 8.B 06/21/22 36 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 807 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 1 Vernice Hankins From:Nancy Coleman <n.coleman1@verizon.net> Sent:Tuesday, June 21, 2022 3:01 PM To:councilmtgitems; Sue Himmelrich; Gleam Davis; kristin.mckown@santamonica.gov; Christine Parra; Phil Brock; Oscar de la Torre; Lana Negrete; Jing Yeo; David Martin Subject:Item 8B EXTERNAL To: Mayor Himmelrich and Council Members From: Nancy Coleman Date: June 21, 2022 Re Item 8 B, Housing Element 8 B Housing Element While I understand that the goal of tonight’s effort is to approve a state acceptable Housing Element there are a number of questions still outstanding. The Council needs to think about where parks will be when all city‐owned property is designated for affordable housing. Santa Monica is already a park pour community. The increased height and FAR for Neighborhood Commercial streets is not acceptable. 55 feet is too high. If state bonuses are applied it will be even higher. 1) On page 3 of 8 of the staff report for item 8-A on the City Council's 6/21 agenda, it says that overall housing capacity was increased to over 13,000 units. Does that mean that Planning staff will then propose zoning changes to accommodate 13,000 additional housing units? Why do this when we're only required to zone for 9,000 and this is too many for the city. 2) This plan includes allowing 300+ housing units at 4th/5th & Arizona, leaving no room for a park. 3) This plan includes allowing 700+ housing units at the Bergamot Arts Center. What will happen to the art galleries? 4) Up zoning even more of the city, including the increased heights of up to 84 feet in a portion of the DCP and Bergamot plus state bonuses will make the City of Santa Monica have the look of downtown Miami. is the than necessary for 9,000 housing units? Item 8.B 06/21/22 37 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 808 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) 2 This will not benefit residents and, if that much housing is actually built, it will create enormous stress on city infrastructure, especially water. Nancy Coleman Item 8.B 06/21/22 38 of 38 Item 8.B 06/21/22 8.B.p Packet Pg. 809 Attachment: Written Comments [Revision 1] (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) City CouncilHousing Element Draft Redline Revisions June 21, 2022 8.B.q Packet Pg. 810 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Purpose •Review and Direct staff to transmit Housing Element draft redline revisions to HCD comments on adopted Housing Element •Redlines focus on changes necessary to get to compliant Housing Element •Does not revisit policy decisions previously approved by City Council that were not subject of HCD comments •General Categories of Comments & Responses to HCD Comments 1.Technical Revisions –Suitable Sites Inventory, Constraints Analysis, ADUs 2.AFFH –Santa Monica’s Fair Housing Approach •Rezoning -Height/FAR adjustments for housing projects and distribution across the city based on Planning Commission prior direction and AFFH requirements 3.City-owned sites 8.B.q Packet Pg. 811 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Mandated by State Housing Element Law •Encourage Housing Production •Government Code 65583.2(c)(3) -zoning must be appropriate to accommodate the RHNA (8,895 units) of which 69% must be for lower income housing •Demonstrate through Suitable Sites Inventory •Account for financial feasibility Income Category RHNA Allocation Very Low Income (0-50% AMI)2794 Low Income (51-80% AMI)1672 Moderate Income(81-120% AMI)1702 Above Moderate (>120% AMI)2727 8.B.q Packet Pg. 812 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Key Housing Element Deadlines •October 15, 2021 –Adopt a compliantHousing Element •February 12, 2022 –extra 120 days to adopt a compliant Housing Element in order to avoid updating Housing Element every 4 years •AB1398 took effect on January 1, 2022 replacing this provision with a requirement to rezone for the RHNA by October 15, 2022 HCD’s position is that HCD had to certify the Housing Element before Council adoption 8.B.q Packet Pg. 813 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Out of Compliance -Consequences Immediate short-term consequences •Approvals •Must approve any project with 20% on-site units affordable to lower- income households or 100% moderate units even if the project exceeds zoning or LUCE maximums •Conditions cannot render the project infeasible •Loss of funding for affordable housing •Rezoning for RHNA complete by 10/15/22 •If rezoning not completed •Must approve any project with at least 49% of housing units affordable to very low, low and moderate income households on SSI that meets the standards listed in the housing programs for rezoning •State can start enforcement proceedings against City 8.B.q Packet Pg. 814 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Out of Compliance -Consequences Long-term consequences •SB35 determination based on building permits issued relative to pro-rated RHNA •If Above Moderate RHNA not met –streamlined process for projects with at 10% affordability •If Lower Income RHNA not met –streamlined process for projects with at least 50% affordability •Requires ministerial approval process for housing projects that include State can also seek judicial relief and impose penalties and fines 8.B.q Packet Pg. 815 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Background •October 12, 2021 –Housing Element adopted •February 2, 2022 –Planning Commission comments on height/FAR for housing projects to achieve sufficient capacity for 6th Cycle RHNA •February 8, 2022 –HCD letter received •April 26, 2022 –progress update on HCD consultations •June 1 & 15, 2022 –Planning Commission direction on key factors that affect overall capacity + draft redline revisions 8.B.q Packet Pg. 816 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Next Steps •Focus on completing Housing Element policy document •June 15 –Planning Commission •Draft redline revisions to Housing Element •June 21 –City Council •Draft redline revisions to Housing Element •July –Submit draft redline revisions to HCD for 60 day review •If “draft in compliance” letter received will work on zoning through September •September –adoption of the EIR, adoption of draft redlines We are here 8.B.q Packet Pg. 817 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Technical Revisions •Suitable Sites Inventory –Appendix F •Added maps, tables, explanation of how SSI sites improve or exacerbate fair housing conditions •Reduced the realistic capacity of sites, taking into account 15% commercial probability factor •Added evidence to justify use of factors, such as improvements to land ratio, age of buildings, vacancy, and tenancy •Provided evidence that presumed densities have occurred on small sites 8.B.q Packet Pg. 818 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Technical Revisions •Constraints Analysis •Emergency Shelters –Revised analysis demonstrating sufficient capacity; revised Program 2.I to include compliance with AB 139 •Permanent Supportive Housing –Clarification added to ensure no discretionary action is required for supportive housing •Employee Housing –Compliant with State law, no revisions necessary •Land Use Controls –Language added to Programs 1.F and 1.J to clarify intent to modify standards and regulations that are found to be constraints; FAR and Building Height tables added to both programs •Fees & Exactions –Clarification provided the typical residential project do NOT require a CUP; Clarification regarding how entitlement fees are determined •Local Processing & Permit Procedure –Demonstrate that design approval findings still create predictable process •Program 2.1 –Revisions provided to include known amendments needed for State law consistency 8.B.q Packet Pg. 819 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Technical Revisions •ADUs •Updated number of ADU permits issued per year and included 2021, with assumptions based on these numbers revised throughout the Housing Element •Projected 47 building permits/year on average •Difference between Housing Element and Annual Progress Report will be reconciled 8.B.q Packet Pg. 820 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Affirmatively Furthering Fair Housing •Santa Monica’s Fair Housing Strategy leads with housing preservation –added geographic targeting & metrics •Program 2F •Program 2G •Program 2I •Goal 3 Programs –reflection of all Santa Monica’s actions on anti- displacement and housing preservation •Goal 4 Programs –increase equitable housing access •*NEW* 4E and 4F •Goal 6 Program –housing assistance •Goal 7 Programs –fair housing enforcement 8.B.q Packet Pg. 821 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Adding Housing as Permitted Use in Areas where it has been prohibited •Office Campus (OC) •Industrial Conservation (IC) •Conservation: Creative Sector (CCS) Upzone for Housing Potential in Areas that Have Not Accommodated Housing in the Past •Main Street •Montana Ave •Ocean Park Boulevard AFFH: Permit Housing Where Housing Has not Occurred 8.B.q Packet Pg. 822 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Housing Preservation: Location of Rent Control Units Zoning Parcels with Rent Control Units % Parcels with Rent Control Units Total Rent Control Units % of all Rent Control Units R1 60 0.9%60 1.5% R2 2261 53.3%2463 63.0% R3 510 66.5%644 16.5% R4 16 44.4%17 0.4% OPD 10 40.0%10 0.3% OP1 13 8.4%13 0.3% OP2 480 38.9%554 14.2% OP3 13 35.1%46 1.2% OP4 10 13.0%10 0.3% MUBL 41 9.7%43 1.1% MUB 1 0.6%1 0.0% GC 12 5.1%12 0.3% HMU 11 15.5%11 0.3% OF 2 5.0%2 0.1% CCS 1 3.8%1 0.0% DCP 22 4.5%22 0.6% •25.7% of all residentially zoned parcels contain rent control units •97.6% of all rent control units are in residential zones 8.B.q Packet Pg. 823 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Affirmatively Furthering Fair Housing •Influenced distribution of housing capacity (FAR/height) throughout the city •Informed programs for R1 Zones 8.B.q Packet Pg. 824 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Basis for Height/FAR Recommendation FAR Used for Calculation Overall Unit Capacity SSI capacity -adopted Housing Element (Oct ’21)11,070 SSI capacity –current recommendation (June’22)~est. 13,000 •Basis for Suitable Sites Inventory •Demonstrate overall housing capacity for purposes of EIR project description •15% inclusionary requirement •Minimum parking requirement •Ground floor flexibility •Distribution based on spreading housing throughout city •More intensive housing potential north of I-10 •Less intensive housing potential for Main, Pico, Montana, Ocean Park Factor #1 Feasibility Factor #2 AFFH Calculate Capacity 8.B.q Packet Pg. 825 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Evolution of Height/FAR Mixed Use/Commercial Zones –No Tiers •Overall Capacity •~13,600 units •Need to ensure buffer at each income level to account for future pending projects •Overall buffer –53% •Lower Income –60% buffer •Moderate Income -12% buffer Zone Council Approved 10/12/21 Current Recommendation 6/21/22 MUBL –N I-10 2.25/50’3.25/70’ MUBL –Pico 2.25/50’2.00/45’ MUBL –Pico (West of Lincoln)2.25/50’2.50/55’ MUBL –Main St 2.25/50’2.50/55’ MUBL –Lincoln 2.25/50’2.50/55’ MUB 2.75/60’3.25/70’ GC (SMB)2.75/60’3.25/70’ GC (Lincoln)2.25/50’2.50/55’ 8.B.q Packet Pg. 826 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Evolution of Height/FAR Mixed Use/Commercial Zones –No Tiers Zone Council Approved 10/12/21 Current Recommendation 6/21/22 GC (Pico)2.75/60’2.00/45’ NC 2.75/60’2.25/50’ NC (Main)3.00/65’2.50/55’ NC (Ocean Park)2.75/60’2.50/55’ NC (Montana)2.25/50’2.50/55’ IC 3.25/70’3.00/65’ OC 2.75/60’2.75/60’ HMU 2.75/60’2.50/55’ •Overall Capacity •~13,600 units •Need to ensure buffer at each income level to account for future pending projects •Overall buffer –53% •Lower Income –60% buffer •Moderate Income -12% buffer 8.B.q Packet Pg. 827 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in HMU 2.5 55’ Equitable Distribution of Housing Capacity across Santa Monica 2.5 55’ 2.5 55’ 2.5 55’ 2.045’ 2.7560’ 3.0 65’ 2.75 60’ 2.5 55’ 2.5 55’ 2.2550’ 2.2550’ 2.5 55’ 3.2570’ 2.5 55’ 2.5 55’ 2.5 55’ 2.0 45’ 2.75 60’ 3.065’ 2.7560’ 2.555’ 2.555’ 2.2550’ 2.25 50’ 2.5 55’ 3.25 70’ HMU 2.555’ Map of Recommended FAR/Height 8.B.q Packet Pg. 828 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Evolution of Height/FAR Bergamot Area Plan –No Tiers Zone Council Approved 10/12/21 Current Recommendation 6/21/22 BTV 2.50/55’4.00/84’ MUC - North of Penn. and South of Expo Bike Path 2.50/55’3.25/70’ MUC –South of Nebraska & North of Expo Bike Path 2.50/55’4.00/84’ CCS 2.50/55’2.50/55’ CAC 2.50/55’2.50/55’ 4.0 84’ 2.5055’ 2.50 55’ 4.0 84’ 4.0 84’ 2.50 55’ 2.5055’ 4.0 84’ 3.25 70’ 3.2570’ 8.B.q Packet Pg. 829 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Evolution of Height/FAR Downtown Community Plan Scenario 1 (High Range) Scenario 1 (Low Range) Scenario 2 (AFFH) Scenarios 3, 4, 5 New PC & Staff Recommended 6/15/22 Zone Council Endorsed 10/12/21 Updated Feasibility Feb 2022 Staff Recommend Feb 2022 Tier 1 Tier 2 Tier 3 LT (East)2.75 2.75 2.75 2.75/60’3.0/65’- LT (West)2.75 2.75 2.75 2.75/60’3.0/65’- NV 2.75 2.75 2.75 2.75/60’3.50/70’4.0/84’ BC (Promenade)2.75 2.75 2.75 2.75/60’3.0/65’- BC (2nd/4th)2.75 2.75 2.75 2.75/60’3.50/70’- TA 2.75 2.75 2.75 2.75/60’3.50/70’4.0/84’ OT 2.75 2.75 2.75 2.75/60’3.0/65’- WT 2.75 2.75 2.75 2.75/60’3.0/65’- 8.B.q Packet Pg. 830 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Map of Recommended FAR/Height -Downtown NV Zone Tier 3 4.0 84’ All DCP Tier 1: 2.75 FAR, 60’ Tier 2 3.570’ Tier 2 3.0 65’ Tier 23.0 65’ NV Zone Tier 3 4.0 84’ Tier 2 3.5 70’ Tier 2 3.0 65’ Tier 23.0 65’ 8.B.q Packet Pg. 831 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in AFFH in R1 Zones •Discussions with HCD clarified that requirements of demonstrating commitment for additional units in R1 (does not need to be deed restricted) •NEW Programs 4E & 4F •PROGRAM 4.E: PROVIDE NEW HOUSING CHOICES AND AFFORDABILITY IN HIGH OPPORTUNITY AREAS THROUGH INCENTIVES FOR SB9 UNITS IN R1-ZONE NEIGHBORHOODS The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. This will open up the possibility for property owners to construct up to 6 units through a multi-step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F. •PROGRAM 4F: ESTABLISH TARGET TO INCREASE HOUSING PRODUCTION IN R1 ZONES AND INCLUDE MID-CYCLE MONITORING The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Reviewprogress towards targets by December 31, 2025,and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. 8.B.q Packet Pg. 832 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in City Owned Sites •HCD requires commitment that City-owned sites can accommodate the 1,880 affordable housing units Sites Unit Capacity Constraints Parking Structure 3 (pending project)104 None Wilshire Parking Lots (3)130 None 4th Street and Arizona 362 Bank leases don’t terminate until 2026 Bergamot Arts Center 707 Property management agreement until April 2027. Annual leases with 30 businesses that renew each calendar year until redevelopment Main Street Parking Lots 577 None but replacement parking will be necessary (Coastal Zone) Total 1,880 8.B.q Packet Pg. 833 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in City Owned Sites & Lower Income Shortfall •Government Code section 65583.2, subdivisions (h) and (i) states that candidate sites must be rezoned to address the shortfall in lower income units •Under existing zoning, the lower income shortfall is approximately 1,100 units •City-owned sites have lower income capacity of 1,880 units to accommodate the shortfall. •Per State law, these sites must allow 100 percent residential use and require residential use to occupy at least 50 percent of the floor area •Loss of a City-owned site means that there will be a shortfall in lower income capacity = must identify alternate site to make up for the loss 8.B.q Packet Pg. 834 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in City-Owned Sites –Draft Revision Program 2E The City shall plan for a minimum of 1,884 1,880 affordable housing units across available City-owned sites, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,884 affordable units. The first An RFP for at least one a city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, . Future RFPs shall be staggered based on availability of resources.the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months. As has been done in the past, the City will use a variety of tools Tto facilitate 100% affordable housing development including but not limited to: •Facilitate appropriate zoning and process to support 100% affordable housing •Substantially reduced or free ground rent, the City will •Providing funding through local housing trust fund •Support applications for other funding sources for affordable housing (e.g. low-income-housing tax credits, grants, State funding, Federal funding) Further, 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.” 8.B.q Packet Pg. 835 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Additional Redlines (Inadvertent Omissions) •Program 1D •Timeframe: by June 30, 2023 October 15, 2022 •Programs 1F and 1J •“Any changes will promote housing and ensure that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR and height shown in the table below.” •Program 1F •“In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees, unit mix, and design standards…” •Program 1J •The off-site affordability requirement will shall be greater than the on-site requirement 8.B.q Packet Pg. 836 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Additional Redlines (Inadvertent Omissions) •Program 4E •Delete “In addition, these SB9 units shall be required to be rented or sold.” •Program 6A –Program Background •Add voucher distribution in 90405 •Chapter 1, Section H –Summary of Housing Programs •Program 4A •Timeframe: by October 15, 2022 •Minor numerical adjustments in Chapter 4 due to calculations from approved/pending projects in SSI •Approved/Pending Projects (Page 110) •Capacity to Accommodate RHNA by Income Levels (Page 112) •Figure 4-4 (Page 113) 8.B.q Packet Pg. 837 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Recommendation •Review and Direct staff to transmit draft redline revisions to HCD 8.B.q Packet Pg. 838 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Why Has Overall Capacity Increased? Addressing HCD Comments means the need to study an increase in overall number of potential housing units based on two main factors Overall Number of Units (RHNA + Buffer ~13,000 units) Reduced number of parcels 1)Re-categorizing sites on the SSI from future projects to pending projects due to applications received for housing projects since September 2021 2)15% reduction in zoned capacity to account for possibility that sites develop into 100% commercial instead of housing 8.B.q Packet Pg. 839 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in Example Housing Potential by Census Tract 8.B.q Packet Pg. 840 Attachment: PowerPoint Presentation (4856 : Housing Element Draft Revisions in