the Housing
Plan, Imp. 9.7
Replacement requirements
The land inventory includes sites in the mixed
use overlay zone that include existing
residential uses. As such, the element must
include a policy that requires the replacement
of these residential units affordable to the same
or lower-income level as a condition of
development on such site.
The land inventory includes a handful of parcels that are residentially zoned, but do not have existing residential development, and some commercially zoned sites with
existing residential development (some are currently vacant).
However, the City actively enforces the provisions of SB 330 and Density Bonus replacement requirements, and ensures that any proposed development complies with these
regulations. SB 330 is a recently adopted state law that requires any new housing development to replace existing housing units in the development, if any housing units were demolished previously to allow such project to be
constructed. This provision is known as the “no net loss” provision because it intends to ensure that new housing developments do not result in an overall loss of housing units, including affordable housing units.
A program commitment stating that the City enforces and complies with the provisions of SB 330 and Density Bonus law (if applicable) has been added to Imp. 9.7. In addition, this program includes a commitment for the City to start an
affordable housing working group that will meet on a quarterly September 14, 2022 -10-
basis to discuss potential affordable housing projects and initiatives, starting in 2023.
A. Housing
Needs,
Resources and
Constraints
A.2 Land
Inventory to
Accommodate
the RHNA
Page C-8 in
Appendix C
(Accessory
Dwelling Units
Section)
Accessory Dwelling Units (ADUs)
The analysis in the element related to expected
ADU production must be based on past
records of permitted ADUs. However, the
element does not address discrepancies
between the City and HCD’s records on the
number of ADUs permitted in 2018, 2019, and
2020. The City must reconcile ADU figures with
HCD records and rescale assumptions based
on permitted ADUs.
Additional information has been included in the ‘Accessory Dwelling Units’ section of Appendix C, which describes the steps that the City has taken with regards to updating the City’s ADU regulations. Given that the Housing Element is being revised at this time, the City also has more information available regarding the number of ADU permits that were issued in 2021(a total of 19), and has updated Appendix C with this information. Regarding the inconsistencies between the City’s records and HCD’s records, the City has previously noted this discrepancy when submitting the General Plan Annual Progress Reports to HCD for the years noted in the comment (2018, 2019, and 2020), and provided information each year as to how the discrepancy should be fixed. Staff has followed up with HCD about correcting this issue, and HCD staff has provided direction at this time regarding how to address these discrepancies (by submitting revised Annual Progress Reports into their system). Staff will ensure that updated reports are submitted to match the City’s records.
A. Housing
Needs,
Resources and
Constraints
A.3
Governmental
Constraints
of the Housing
Plan, Imp. 12.1
Land use controls
The revisions added to Program 12.1
(Development Standards) to “study” and
“consider” do not result in meaningful actions
to address potential constraints on multifamily
housing and this analysis. Stronger language
and a timeline for these actions must be added
to these programs.
Imp 11.1 has been revised to include the following action:
• Perform outreach to property owners of parcels located in the mixed use overlay zone to notify them of the ability to redevelop properties with or convert existing buildings to mixed use developments. The housing created in this
zone will result in new units in high opportunity areas that does not displace existing tenants. This outreach will
include a mailed notice and advertising on the City’s
social media accounts and website, and will be
performed by 2023.
Imp 12.1 has been revised to include stronger commitments with specified timelines and the following additional actions:
• Simplify modulation requirements for multi-family housing projects by 2025
• Create an adaptive reuse program by 2028 to more easily allow the conversion of existing commercial structures to September 14, 2022 -11-
residential uses, including existing legally nonconforming hotels in residential areas.
• Adopt objective design standards for multi-family housing projects and create materials for multi-family applicants that clearly state design standards by 2026
• Consider an ordinance to streamline the approval process to allow Director-level approvals for Architectural Review of multi-family housing projects with affordable housing; bring this topic forward for discussion by the Planning Commission by 2026.
• Review the mixed use overlay zone regulations by 2026 to assess how these regulations have been utilized by
projects, and to determine whether further code
changes are necessary to encourage housing and
meeting housing production targets.
A. Housing
Needs,
Resources and
Constraints
A.3
Governmental
Constraints
the Housing
Plan, Imp. 12.2;
Page B-29 of
Appendix B
Fees
The element includes a statement indicating
that Program 12.2 (Reduced Fees for
Affordable Housing) commits the City to
conducting a fee study to assess whether
additional waivers can be granted for
affordable housing projects. However, there
are no revisions found in Program 12.2. This
comment appears to be addressing an
inconsistency in the Housing Plan document.
Appendix B (starting on page B-29) contains a discussion of current fees that are charged for multi-family and single-family residential development projects, which uses actual fee amounts from projects that have been recently submitted to the City. While the previous version of the Housing Element concluded that fees do not impose an undue constraint on the production of new housing, the revisions acknowledge that such fees are not an insignificant amount, and since the City wishes to incentivize the production of affordable housing units, it will commit to undertaking a fee study to assess all permit fees for housing projects. In addition, the Housing Element contains a commitment to adopt modified
development fees for projects that contain a certain
percentage of affordable (based on the results of the study).
Policy H 4.3 has been updated to state: “Conduct a housing development fee study to provide fee waivers for entitlement and permitting costs, to facilitate the production of
affordable, senior, and workforce housing.”
Imp. 12.2 has been updated to reflect a timeline for a housing development fee study, and the adoption of modified
development fees for projects that include a certain
September 14, 2022 -12-
percentage of affordable housing (to be determined by the study). These activities shall be undertaken by 2026.
The language in Appendix B referring to Imp 12.2 has also been updated to be consistent with Imp. 12.2.
A. Housing
Needs,
Resources and
Constraints
A.3
Governmental
Constraints
Page B-25 of
Appendix B Processing and permit procedures
The element must analyze the impact of permit
and processing procedures for impacts on
cost, supply, and built density.
A more detailed explanation regarding Architectural Review processes has been added to Appendix B, to clarify how the procedures are applied and the objectives they intend to accomplish. This information also clarifies that the
Architectural Review criteria are applied and cited evenly in the approval resolution, which follows a regularized template for all projects, and the average processing time for
Architectural Commission-level architectural review projects is 3 weeks from the date of receipt of a formal application to the date a project is agendized and heard by the Architectural Commission. In addition, this section clarifies that nearly all minor (staff-level review) Architectural Review applications are approved at the staff level or over-the-counter on the day of application. As such, the existing Architectural Review process for multi-family residential projects in Beverly Hills is a streamlined, standardized procedure that does not appear to be a barrier to the approval of housing projects.
Imp 12.1 has been revised to include stronger commitments with specified timelines and the following additional actions that are meant to ensure that housing projects can be
reviewed and permitted quickly:
• Simplify modulation requirements for multi-family
developments by 2025
• Create an adaptive reuse program by 2028 to more easily allow the conversion of existing commercial structures to residential uses, especially existing legally nonconforming hotels in residential areas
• Adopt objective design standards for multi-family housing projects and create materials for multi-family applicants that clearly state design standards by 2026
September 14, 2022 -13-
• Consider an ordinance to streamline the approval process to allow Director-level approvals for Architectural Review of multi-family housing projects with affordable housing; bring this topic forward for discussion by the Planning Commission by 2026
• Review the mixed use overlay zone regulations by 2026 to assess how these regulations have been utilized by
projects, and to determine whether further code
changes are necessary to encourage housing and
meeting housing production targets
In its assessment of whether or not Design Review procedures have a significant impact on development, City staff has reviewed the number of Track 1 and Track 2 Design Review approvals from 2013 to 2021, and has found a strong trend towards more Track 1 approvals (approved by the Director of Community Development) and fewer Track 2 approvals
(approved by the Design Review Commission). Since Track 1 approvals are reviewed at the Director level, these are often processed more quickly than Track 2 approvals, and therefore, do not add as much time to process the required Design
Review approval. Therefore, City staff has concluded that the Design Review approval process does not create
unreasonable processing delays for projects.
A. Housing
Needs,
Resources and
Constraints
A.3
Governmental
Constraints
N/A Constraints on persons with disabilities
Family Definition: In response to HCD’s prior
review, which found that the City’s definition of
family acts as a constraint on persons with
disabilities and is discriminatory, the City
responded to HCD by noting that “the City
believes that the current definition complies
with State law and that no revisions are
necessary or appropriate at this time. It is
important to recognize that the existing
definition is part of an integrated set of land use
regulations that has been carefully crafted to
protect the integrity of existing single-andmulti-family neighborhoods...” (Exhibit 1, The City has reviewed the definitions of ‘family’ and
regulations related to group homes in residential zones in the zoning codes of other cities that have received certified Housing Elements, and believes that these are consistent with the City’s current definitions. In addition, the City would like to note that the zoning code currently allows transitional and supportive housing in all single-family residential zones and all multi-family residential zones in the City, subject to the same standards as similar residential uses. If such housing is configured as a single-family residence, it is regulated as such and is subject to all regulations applied to residences in the single-family residential zone where it is located. Please refer to Beverly Hills Municipal Code Section 10-3-302. The City’s definitions and regulations are in compliance with state law.
September 14, 2022 -14-
Housing Element Comments and Responses).
Based upon the City’s refusal to address these
constraints, the adopted element still does not
address this finding.
Group Homes: Similarly, HCD’s prior review
found that group homes for seven or more
persons are excluded from most residential
zones and did not evaluate approval
requirements for impacts on objectivity and
approval certainty. The City responded to HCD
by noting that “the City believes the
regulations for group homes for 7+ persons
complies with State law” Based upon the City’s
response, the adopted element still does not
address this finding.
A. Housing
Needs,
Resources and
Constraints
A.4 NonGovernmental
Constraints
the Housing
Plan, Imp. 12.3
Densities and approval times
The element must address requests to develop
housing at densities below those anticipated in
the sites inventory and the length of time
between receiving approval for housing
development and submittal of application for
building permits. The element was not revised
to address this requirement.
In order to address the comment related to the densities of proposed projects, staff compiled a list of recent multi-family housing projects that were recently approved:
• 425-429 N. Palm Drive – 25 units allowed, 20 units
proposed
• 340 S. Rexford Drive – 3 units allowed, 3 units proposed • 250 N. Crescent Drive – 7 units allowed, 8 proposed
(approved through density bonus)
• 9265 Burton Way – 17 units allowed, 23 units proposed (approved through density bonus)
• 457 Oakhurst Drive – 8 units allowed, 6 proposed
City staff has reviewed recent multi-family projects that have been processed (see above list), and have found that while most projects have maximized the allowed density (and many that were approved or are currently proposed exceed the maximum density through the density bonus program), there are some projects that have been submitted and approved with lower densities of housing units than what would otherwise be allowed under the zoning code. In order to address the potential for housing projects to be submitted and built at lower densities, Imp. 12.3 has been updated to include an S
eptember14, 2022-15-
action that requires the City to meet with project applicants to review zoning regulations in the event that a housing project is submitted with proposed densities below the permitted
density in the zone. The City has also hired additional Planning staff members to help expedite the review and processing of projects, and to help distribute information to the public more efficiently. Additional information has been included in this program to discuss the steps the City has already taken to ensure more efficient development reviews and reduce
delays with processing.
Furthermore, Imp. 9.6 has been updated with the following implementation action: • Ensure compliance with residential unit replacement state law (SB 330 and Density Bonus law, if applicable) whenever redevelopment of existing residential properties occurs in the multi-family residential areas or mixed use overlay zone The City’s commitment to compliance with the regulations of SB 330 means that even if housing projects are proposed with a lower density than what is allowed per the zoning code, they will never be approved with a number of housing units lower than what currently exists on the site.
The City also reviewed permit processing timelines for
entitlement projects within the last two years, and found that the average processing time for a variety of types of projects was approximately 11 months. The majority of these projects included review by the Planning Commission and/or City
Council at a public hearing for final approval. However, City staff also found that many delays were related to the
applicant’s resubmittal of corrected materials and information responsive to correction letter, as City staff’s turnaround of corrections to applicants were all within 30 days or less of submittal of information. For example, a recent Central R-1 Permit request to allow a 2-story accessory structure (guest house, not ADU), had a total processing time of 9 months.
However, the time between the date the application was
September 14, 2022 -16-
deemed complete and the public hearing before the
Planning Commission was only 1 month. Another example of a Central R-1 and ADU Use Permit request had a total
processing time of 6 months, and the time between the date the application was deemed complete and the public
hearing before the Planning Commission was 1.5 months. Thus, the City often finds that processing delays for entitlement requests most often related to the time between City staff providing a correction letter to the applicant, and the time taken by the applicant to resubmit materials in response to such letter. Furthermore, the City currently offers concurrent entitlement processing and plan check reviews, as long as the applicant acknowledges that such plan check results are at risk of changing as a result of the entitlement approval.
A. Housing
Needs,
Resources and
Constraints
A.5 Lowincome units at
risk of
conversion
the Housing
Plan, Imp. 9.7;
Page A-22 of
Appendix A in
Assisted
Housing at Risk
of Conversion
Units at risk of conversion
The element must estimate the total costs of
preserving at-risk units that are in danger of
converting to market-rate during the next ten
years. The element presents confounding
information that the earliest date of conversion
for the Beverly Hills Senior Housing project is
2028 and is “technically classified as being atrisk of conversion...”; however, the “City has the right to purchase the upper floor for one dollar
in 2041; therefore, this project is not at risk of
conversion to market rate.
Clarifying information has been added into Imp. 9.7 and Appendix A that discusses the existence of a recorded
covenant on the Menorah Housing Foundation property
(referred to by the state as the Beverly Hills Senior Housing Project). This covenant ensures that the residential portions of the property shall only be used for senior and disabled housing, and if such uses are discontinued, the City shall approve the use of the property. In addition, this covenant states that if the rental rates are not set by a Federal, State, or other public agency, the Planning Commission shall be able to set such rental rates. Since this covenant is recorded on the property and runs with the land, it ensures that these units are not at risk for conversion, even if the affordability covenant is set to expire within the current planning period. Additionally, policy H1.5 was amended to add monitoring of the potential loss of existing residential units that are removed as part of a new multi-family residential or mixed-use development. (Imp. 9.5).
B. Housing
Programs
B.1 Timeframe
for
implementatio
n actions
the Housing
Plan, Imp. 10.4;
Page C-8 in
Appendix C
(Accessory
Timeframes for programs
Programs 9.3 (Home Repair and Improvement)
and 10.3 (Housing Trust Fund) must be revised
to address timeframes for completion of these
implementation programs. In addition,
Program 10,4 (Accessory Dwelling Units) still
Imp. 9.3 and 11.1 have been revised to encourage the
Handyworker program to be re-established by 2025.
Imp. 10.3 has been revised to state that the City will establish an affordable housing working group that will meet on a quarterly basis, and to state that the City will enter into an agreement with a developer to develop an affordable
September 14, 2022 -17-
Dwelling Units
Section) requires timeframes for creating pre-approved
ADU plans and for outreach materials,
including an ADU webpage.
housing project on City-owned land by 2023. The City has already released a Request for Proposals (RFP) for developers who are interested in proposing an affordable housing
development project on several different City-owned sites.
The City is currently reviewing these proposals, as a first step towards developing an affordable housing project.
Imp. 10.4 has been revised to include specific timeframes for amending the City’s regulations related to ADUs. In particular, this program states that the City shall adopt an ordinance to update the ADU regulations to ensure they are consistent with State law by 2023, and consider including changes to these regulations that will incentivize the construction of ADUs. In addition, the program states that the City will provide prechecked ADU plans for use by the public by 2025, and will revisit the ADU regulations in 2025 if ADU production falls below the target set in the sites inventory analysis (in Appendix C).
Additional information has been included in the ‘Accessory Dwelling Units’ section of Appendix C, which describes the steps that the City has already taken with regards to updating the City’s ADU regulations.
B. Housing
Programs
B.2 Housing
Programs –
Sites Inventory
the Housing
Plan, Imp. 10.4;
page 487,
Imp. 12.1
Based on the results of the land inventory
analysis (see comment A.2), the element may
need to include additional or revised programs
that address a shortfall of sites or zoning that
satisfactorily encourages a variety of housing
types.
In the previous version of the Housing Element, the sites inventory included an adequate number of sites that
accommodated the RHNA for the City. Moreover, the
previous version included a large buffer of the number of units that could be built per the zoning (based on the density calculation of the mixed use overlay zone), beyond the 3,104 housing units required by the RHNA. The sites inventory has been revised by applying a more specific set of criteria to evaluate whether a site should be included in the inventory or not, and is still able to accommodate the required number of housing units to satisfy the RHNA and an additional buffer of housing units.
Since HCD has not yet approved the land inventory and
accompanying analysis, it is not possible to assess whether additional policies and implementation programs are needed at this time to address a shortage of sites and zoning
regulations to satisfy the RHNA. This comment may be
September 14, 2022 -18-
addressed with further guidance from HCD once a review of the revisions to the adopted Housing Element takes place.
However, the City has added the following programs that can help to address potential shortfalls of housing production during the next planning period.
Imp 10.4 states:
• Revisit ADU regulations in 2025 to allow great flexibility if ADU production falls below targets outlined in sites
inventory analysis.
Imp 12.1 states:
• Review the mixed use overlay zone regulations by 2026 to assess how these regulations have been utilized by
projects, and to determine whether further code changes are necessary to encourage housing and meeting housing
production targets.
B. Housing
Programs
B.3 Housing
programs to
assist in the
development
of adequate
housing to
meet the
needs of
extremely low-,
very low-, lowand moderateincome
households.
the Housing
Plan, Imp. 9.7
The element now includes revisions that identify
additional actions to assist low-, very low-, lowand moderate-income households in Program
10.6 (Partnerships with Affordable Housing
Developers). However, none of these actions
have corresponding timeframe commitments
for implementation that will result in beneficial
impacts during the planning period.
Imp. 9.7 includes a commitment for the City to start an affordable housing working group that will meet on a quarterly basis to discuss potential affordable housing projects and initiatives, starting in 2023. This group will also explore the possibility of any partnerships with developers or non-profit organizations to construct City-funded affordable housing projects.
Imp 10.6 also states that the City will enter into an agreement with affordable housing developer in 2023 to develop an affordable housing project on city owned land. The City has already released a Request for Proposals (RFP) for developers who are interested in proposing an affordable housing
development project on several different City-owned sites.
The City is currently reviewing these proposals, as a first step towards developing an affordable housing project.
B. Housing
Programs
B.4 Housing
programs to
of the Housing
Plan, Imp. 12.1
Programs to remove constraints
The element now includes revisions to Program
12.1 (Development Standards) that commit the
City to amendments by 2024, it still contains
Imp 12.1 has been revised to include stronger commitments with specified timelines and the following additional actions:
• Simplify modulation requirements for multi-family projects by 2025
September 14, 2022 -19-
remove
constraints terms including “studying” and “evaluating” that do not result in beneficial impacts during
the planning period.
In addition, depending on the results of the
analysis of potential governmental and
nongovernmental constraints, additional
programs and policies may need to be added
to address such constraints.
• Create an adaptive reuse program by 2028 to more easily allow the conversion of existing commercial structures to residential uses, including existing legally nonconforming hotels in residential areas.
• Adopt objective design standards for multi-family housing projects and create materials for multi-family applicants that clearly state design standards by 2026
• Consider an ordinance to streamline the approval process to allow Director-level approvals for Architectural Review of multi-family housing projects with affordable housing; bring this topic forward for discussion by the Planning Commission by 2026.
• Review the mixed use overlay zone regulations by 2026 to assess how these regulations have been utilized by
projects, and to determine whether further code
changes are necessary to encourage housing and
meeting housing production targets.
B. Housing
Programs
B.5 Housing
programs to
affirmatively
further fair
housing
Appendix A,
Page A-44 Affirmatively Furthering Fair Housing
The element must include a complete analysis
of affirmatively furthering fair housing.
Depending on the results of this analysis,
additional programs and policies may need to
be added to address the issues identified in the
analysis.
The Fair Housing section in Appendix A has been revised extensively and the following policies and programs are included in order to Affirmatively Further Fair Housing:
• Ensure that all development applications are considered, reviewed, and approved without prejudice to the
proposed residents, contingent on the development
application’s compliance with all entitlement
requirements.
• Accommodate persons with disabilities who seek
reasonable waiver or modification of land use controls
and/or development standards pursuant to procedures
and criteria set forth in the applicable development
regulations.
• Work with the County to implement the regional Analysis of Impediments to Fair Housing Choice and HUD
Consolidated Plan.
• Facilitate public education and outreach by posting
informational flyers on fair housing at public counters, libraries, and on the City’s website.
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• Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources will be invested to provide interpretation and translation services when requested at public meetings when
feasible.
• As feasible and legal per state law, provide a virtual option for public meetings to increase ability of all
members of the public to participate.
• Continue to facilitate the placement of qualified
households into affordable housing units constructed in the City. Advertise the units on affordable housing
websites with a regional reach. Notify adjacent
jurisdiction housing departments when affordable units
are available.
• Maintain the affordable housing webpage on the City
website with information on applying for available units. • Encourage community and stakeholder engagement
during development decisions.
• Process a Municipal Code amendment clarifying that
agricultural employee housing for six or fewer employees is treated as a single-family structure permitted in the same manner as other dwellings of the same type in the
same zone.
• Perform outreach to property owners of parcels located in the mixed use overlay zone to notify them of the ability to redevelop properties with, or convert existing buildings to, mixed use developments. The housing created in this zone will result in new units in high opportunity areas that does not displace existing tenants. This outreach will
include a mailed notice and advertising on the City’s
social media accounts and website, and will be
performed by 2023.
• City staff will provide fee-free consultation for property owners exploring housing development in order to discuss the provision of affordable units in housing developments, and provide information on fair housing as it relates to housing development.
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• By end of 2023, City will work with a consultant to develop fair housing action plan that includes, but is not limited to the programs outlined below.
• The City will provide annual fair housing training for staff. that are involved directly or indirectly in housing, the capital improvement plan, code enforcement, rent
stabilization, and the development of planning and
zoning documents.
• The City will provide an update to the Planning
Commission on fair housing issues annually
• The City will develop a website that provides fair housing resources
• The City will provide brochures and information regarding fair housing, tenant rights, rent stabilization, available grants and loans, first-time homebuyer programs, and
Section 8 programs on the city website.
• Build upon the existing rent stabilization and tenant’s right protections by creating brochures that will be placed on the website and provided at key community sites (such
as City Hall, the library, and community centers).
• Review and discuss developments in fair housing related legislation and litigation and consider code amendments to maintain compliance with applicable law.
• Study and amend Municipal code sections 10-3-12.5 and 10-3-12.8 related to incentives for construction multiple- family housing for the elderly and disabled and multiple- family congregate housing for elderly and disabled
persons to address identified outdated language and
ensure code provisions are not inhibiting such
development.
• As feasible and legal per state law, provide a virtual option for public meetings to increase ability of all
members of the public to participate.
• Continue to facilitate the placement of qualified
households into affordable housing units constructed in the City. Advertise the units on affordable housing
websites with a regional reach. Notify adjacent
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jurisdiction housing departments when affordable units
are available.
• Maintain the affordable housing webpage on the City
website with information on applying for available units.
New and/or Revised Fair Housing Policies
Based on the Analysis of Fair Housing, the following policies have been added or revised in the adopted Housing
Element, incorporated to the Housing Plan (Implementation Measure 11.1), and referenced here, in order to Affirmatively Further Fair Housing.
1. Housing Mobility Strategies consist of removing
barriers to housing in areas of opportunity and
strategically enhancing access.
• Provide annual education to landlords and tenants
regarding applicable laws and protections
• Continue to refer tenants for Fair Housing Counseling through the Housing Rights Center (for civil rights claims) • Continue to refer tenants and landlords to the Loyola Center for Conflict Resolution (for conflicts not related to protected status)
• Continue to host annual housing rights trainings for
landlords and tenants, including presentation on
discrimination by Housing Rights Center
• Continue hosting in a hybrid format (in person and online) through 2024 in order to provide wider accessibility to the meetings.
• Advertise via newspaper and social media platforms • Conduct four housing trainings annually, tailored to: 1) landlords, 2) tenants, 3) joint landlords and tenants, and 4) rent registration to keep landlords and tenants
apprised of fair housing laws and incentives.
• Cover topics such as property maintenance, housing
services, registration, mediation, and evictions.
• Develop a component of the training to address state
and federal mandates regarding anti-discrimination.
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• Send periodic email blasts to landlords (to all with known email addresses) to disseminate updates regarding
updates in Federal, State, and local landlord-related
legislation and resources programs as updates become
available.
• Send mailed notices to tenants regarding updates in
Federal, State, and local tenant-related legislation and resources programs, such as Housing is Key
• Continue to provide referral to the Housing Rights Center, State Fair Employment and Housing, HUD Fair Housing
and Equal Opportunity division, and other legal services as appropriate.
• Explore funding options to incentivize the repair and maintenance of aging rent stabilized-apartments
buildings.
• Continue to provide referral to the Housing Rights Center, State Fair Employment and Housing, HUD Fair Housing
and Equal Opportunity division, and other legal services as appropriate.
• Form an internal Housing Element Implementation
working group of applicable City divisions to monitor the ongoing implementation of the Housing Element
programs.
2. New Housing Choices and Affordability in Areas of
Opportunity means promoting housing supply,
choices and affordability in areas of high opportunity
and outside of areas of concentrated poverty.
• Forge partnerships with non-profit or community groups serving under-represented ethnic and racial minorities to promote greater access to housing opportunities in
Beverly Hills.
• Provide all known affordable housing available units to the Housing Rights Center of Los Angeles for listing in the "Project Place" monthly rental listing.
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• Connect with leadership from SAGE, Advocacy and
Services for LGBTQ+ Elders, to explore how the City can serve this population’s housing needs.
• City staff will continue to provide fee-free consultation for property owners exploring housing development in order
to discuss the provision of affordable units in housing developments, and provide information on fair housing as it relates to housing development.
• Continue a program to provide low cost conceptual
review to provide preliminary comments on housing
development projects prior to formal submittal to the
City, within a 60-day turnaround.
• Study and create additional incentives to promote the mixed use program, including promoting the ability to
adaptively reuse existing commercial buildings, to
facilitate the creation of new units in high opportunity areas.
• Continue to implement reasonable accommodation
ordinance and provide accessible information/
application and guidance for reasonable
accommodation applicants.
• Continue to explore opportunities for the City to purchase or support the purchase of underutilized land for potential future affordable housing projects.
• Consider amendments to existing Inclusionary Housing
Ordinance beyond state law requirements that will
enhance and incentivize the City’s affordable housing
program.
• Study a way to encourage new middle
income/workforce housing through incentives and
possible amendment of the density bonuses ordinance.
3. Place-based Strategies to Encourage Community
Conservation and Revitalization Involves 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
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affordable housing, improving infrastructure, schools,
employment, parks, transportation and other
community amenities.
• As part of the annual General Plan report, report on the interest from developers in the mixed-use overlay zone. • Continue to dedicate one full-time code enforcement
officer to the Rent Stabilization Division to investigate and respond to housing complaints, including investigating
habitability violations, issuing citations, and ensuring compliance with all habitability standards.
• Encourage reinstating a residential repair program
through the Handyworker Program” by studying options
for administering the program.
• Develop information and outreach for property owners
regarding rehabilitation and maintenance of housing
units.
• Continue to provide adequately zoned sites for multi-unit housing in infill areas or commercial corridors in closer proximity to major transportation hubs for diverse housing types that include both rental and ownership
opportunities through the implementation of the Mixed-
Use Overlay Zone.
• Review with the applicable Commissions and revise local regulations to include objective design standards to be applied to single-family and multi-family residential
housing development applications.
• Begin to implement the streetscape design standards
applicable to the Mixed-Use Overlay Zone to enhance
the livability along the mixed-use corridor and extend the City’s “garden-like quality” character to the new housing corridors created in the Mixed Use Overlay Zone.
4. Protecting Existing Residents from Displacement
comprises strategies that protects residents in areas of lower or moderate opportunity and concentrated
poverty and preserves housing choices and
affordability.
September 14, 2022 -26-
• Maintain and continue to implement the Rent
Stabilization Ordinance adopted in 2018.
• Study through 2023 how the Rent Stabilization Ordinance can be strengthened to protect housing affordability.
• Conduct annual staff trainings with the City Attorney’s Office for staff members to understand new legislation
and fair housing requirements as applicable to local
requirements and housing project applications.
• Maintain and continue to implement the mandatory
Seismic Retrofit Program for multi-family properties.
• Study the use of incentives to expand of the voluntary seismic retrofit program applicable to single-family
residential and commercial properties.
• Continue to convene the Aging in Place Group (staff
committee) created in 2019 that coordinates the nurse
practitioner program, Bet Tzedek, JFS, RSO, and Code
Enforcement to review cases of vulnerable households
seeking assistance and coordinate all available city and non-profit services with the goal of prevent eviction.
• Continue to prevent unlawful eviction and fund legal aid organizations such as Bet Tzedek that provide tenant
education and representation regarding landlord/tenant
disputes.
B. Housing
Programs
B.6 Housing
programs to
preserve
assisted
housing
developments
the Housing
Plan, Imp. 9.7;
Page A-22 of
Appendix A in
Assisted
Housing at Risk
of Conversion
The element must complete an analysis of units
at risk of conversion to market rate, and based
on the results of this analysis, must add or
modify programs and policies to address the
results.
This topic has been previously addressed in the response to Comment A5 (see above). Clarifying information has been added into Imp. 9.7 and Appendix A that discusses the
existence of a recorded covenant on the Menorah Housing Foundation property. This covenant ensures that the
residential portions of the property shall only be used for senior and disabled housing, and if such uses are discontinued, the City shall approve the use of the property. In addition, this covenant states that if the rental rates are not set by a Federal, State, or other public agency, the Planning Commission shall be able to set such rental rates. Since this covenant is recorded on the property and runs with the land, it ensures that these units are not at risk for conversion, even if the September 14, 2022 -27-
affordability covenant is set to expire within the current planning period.
In addition, as stated in Imp. 9.7, the City actively enforces the no net loss provisions of SB 330 and Density Bonus, and reviews all projects for compliance with SB 330 and Density Bonus replacement requirements (if applicable).
B. Housing
Programs
B.7 Programs to
promote ADUs
the Housing
Plan, Imp. 10.4;
Page C-8 in
Appendix C
(Accessory
Dwelling Units
Section)
The element now includes revisions that
address some timeframes to actions identified
in Program 10.4 (Accessory Dwelling Units).
However, other actions still lack specified
timeframes other than indicating “throughout
the planning period,” including amending the
zoning code to remove barriers regarding
ADUs in multi-family zones, pre-plan checks
and pre-approved ADU plans, and creating an
ADU webpage.
Imp. 10.4 has been revised to include specific timeframes for amending the City’s regulations related to ADUs. In particular, this program states that the City shall update the ADU
regulations to ensure they are consistent with State law by 2023, and consider including changes to these regulations that will incentivize the construction of ADUs. In addition, the program states that the City will provide pre-checked ADU plans for use by the public by 2025, and will revisit the ADU regulations in 2025 if production falls below the target set in the sites inventory analysis (in Appendix C). Additional information has been included in the ‘Accessory Dwelling Units’ section of Appendix C, which describes the steps that the City has taken with regards to updating the City’s ADU regulations.
C. Public
Participation
Appendix A,
Page A-26
and Appendix
E , Page E-9
The comment states that the element must
demonstrate that all economic segments of
the community, particularly low- and
moderate-income households and
organizations that represent them, were
involved in the development of the housing
element.
Throughout the update process, the Housing Element team consulted internally with other City staff who can be
considered local experts in housing and social services through their official City roles:
• Helen Morales - Deputy Director of Rent Stabilization, City of Beverly Hills
• Rachel Evans – Human Services Administrator, City of
Beverly Hills
Both Ms. Morales and Ms. Evans provided information about the existing services provided by the City, assisted in the fair housing analysis, and provided connections to external
contacts/organizations to gather deeper local knowledge and data. Their expertise was relied upon in the creation of the fair housing policies.
The City performed additional outreach to organizations and community members to learn more about fair housing issues in September 14, 2022 -28-
the City, and ensure that all economic segments of the
community have been engaged in the Housing Element
update process. The City conducted interviews with
representatives from Jewish Family Services, Bet Tzedek, and Beverly Hills Renters Alliance. These interviews took a representative approach, as each organization represents and targets different segments of the community, including senior households, and renter households. These interviews helped to inform the City of the fair housing issues facing the community, and helped craft the policies in the Affirmatively Furthering Fair Housing (AFFH) analysis section (in Appendix A).
The following additional external stakeholder groups were contacted for this process, but were not available to be interviewed:
• Beverly Hills Unified School District (BHUSD)
• Menorah Housing Foundation
• Housing Rights Center
• Sage - LGBTQ Seniors
The City has also agendized a review of the revised Housing Element document (in response to HCD’s comments) at an
upcoming Planning Commission meeting on August 25, 2022.
Notice of this meeting was published in two local newspapers, 20 days in advance of the meeting date, and notice was also emailed to the City’s interested parties list for the Housing Element and affordable housing program. Information about these additional outreach activities has been included in both Appendix A and E.
Attachment 4
HCD Comment Letter – 1-14-2022
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
January 14, 2022
Ryan Gohlich, Director
Community Development Department
City of Beverly Hills
455 North Rexford Drive, First Floor
Beverly Hills, CA, 90210
Dear Ryan Gohlich:
RE: City of Beverly Hills’ 6th Cycle (2021-2029) Adopted Housing Element Thank you for submitting the City of Beverly Hills’ (City) housing element adopted October 12, 2021 and received for review on October 18, 2021. Pursuant to Government Code section 65585, subdivision (h), the California Department of Housing and Community Development (HCD) is reporting the results of its review.
The adopted housing element addresses most statutory requirements described in HCD’s July 30, 2021 review; however, additional revisions are necessary to fully 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.
As a reminder, the City’s 6th cycle housing element was due October 15, 2021. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (October 15, 2021), then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).
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 note, upon adoption of the housing element, the City must submit an electronic Ryan Gohlich, Director
version of the sites inventory with its adopted housing element to [email protected]. 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.
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 meets housing element requirements for these and other funding sources.
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 Chelsea Lee, of our staff, at [email protected].
Sincerely,
Senior Program Manager
Paul McDougall
City of Beverly Hills’ 6th Cycle Adopted Housing Element Page 1 January 14, 2022
APPENDIX
CITY OF BEVERLY HILLS
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).) The element now includes additional information on outreach conducted, a few maps, and marginal sites analysis for some of the fair housing areas but generally does not address this requirement. Please see HCD’s prior review for additional information and HCD’s data viewer and guidance at https://www.hcd.ca.gov/communitydevelopment/affh/index.shtml.
2. 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).)
Parcel Listing: The element now identifies the anticipated affordability levels of units on identified sites, but still does not include revisions to clarify generic descriptions of existing uses of sites identified in the inventory. Please see HCD’s prior review for additional information.
Realistic Capacity: The element now includes minimal discussion that indicates allowable densities in the Mixed-Use Overlay Zone are higher than the default density for the City and lists recently approved projects in the R-4 zone that achieved densities between 30-59 units per acre. However, the element provides no analysis based on land-use controls, environmental constraints, infrastructure, and site improvements to demonstrate the calculation of residential capacity on identified sites. Please see HCD’s prior review for additional information.
Suitability of Nonvacant Sites: HCD’s prior review found the element must include analysis that demonstrates the potential for additional development of nonvacant sites.
City of Beverly Hills’ 6th Cycle Adopted Housing Element Page 2 January 14, 2022
In response, the element adds some information on ILV ratios and market conditions of sites in the Mixed-Use Overlay zone. However, the element does not provide sufficient analysis to demonstrate existing uses will discontinue in the planning period, analyze existing leases or contracts that would prevent redevelopment of sites, or provide evidence of the City’s past experience with converting existing uses to higher density residential development. Please see HCD’s prior review for additional information.
Environmental Constraints: HCD’s prior review found the element must describe any known environmental constraints or other conditions on identified sites that could impact housing development in the planning period. In response, the element now states, “while environmental constraints will require development to incorporate measures to mitigate potential hazards, these constraints are not expected to preclude housing development consistent with the regional housing needs allocation (RHNA),” (p. B-56).
This statement indicates the presence of constraints on sites identified; therefore, the element did not address this finding.
Replacement Requirements: HCD’s prior review found the element includes sites in the Mixed-Use Overlay Zone with existing residential uses. The element was not revised to address this requirement. Please see HCD’s prior review.
Accessory Dwelling Units (ADUs): The element now indicates that an additional 14 ADU permit applications were submitted in September 2021 to justify its projection of 150 ADUs in the planning period. The analysis should be based on permitted ADUs.
Further, the City did not address discrepancies between the City and HCD’s records on ADUs permitted in 2018, 2019, and 2020. The City must reconcile ADU figures with HCD records and rescale assumptions based on permitted ADUs.
3. 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: In response to HCD’s prior review to analyze development standards for impacts on achieving maximum densities, the element now includes additional examples of projects recently approved in the R-4 zone. In addition, the element addresses lot assemblage issues, noting that some of the R-4 projects involved singular lots and still achieved high densities. However, revisions added to Program
12.1 (Development Standards) to “study” and “consider” do not result in meaningful actions to address potential constraints on multifamily housing and this analysis.
Fees: In response to HCD’s prior review to analyze fees for impacts on development costs, the element now includes a statement that indicates Program 12.2 (Reduced Fees for Affordable Housing) commits the City to conducting a fee study to assess whether additional waivers can be granted for affordable housing projects. However, City of Beverly Hills’ 6th Cycle Adopted Housing Element Page 3 January 14, 2022
there are no revisions found in Program 12.2, nor is there an evaluation of fees. Please see HCD’s prior review.
Processing and Permit Procedures: In response to HCD’s prior review to analyze its permit and processing procedures for impacts on cost, supply, and built density, the element now adds minor revisions describing the design content of the “Residential Design Style Catalog,” which includes architectural features, materials, and pictures of each design style. These revisions do not address HCD’s findings. Please see HCD’s prior review.
Constraints on Persons with Disabilities:
• Family Definition: In response to HCD’s prior review, which found that the City’s definition of family acts as a constraint on persons with disabilities and is discriminatory, the City responded to HCD by noting that “the City believes that the current definition complies with State law and that no revisions are necessary or appropriate at this time. It is important to recognize that the existing definition is part of an integrated set of land use regulations that has been carefully crafted to protect the integrity of existing single-and-multi-family neighborhoods...” (Exhibit 1, Housing Element Comments and Responses). Based upon the City’s refusal to address these constraints, the adopted element still does not address this finding. Please see HCD’s prior review.
• Group Homes: Similarly, HCD’s prior review found that group homes for seven or more persons are excluded from most residential zones and did not evaluate approval requirements for impacts on objectivity and approval certainty. The City responded to HCD by noting that “the City believes the regulations for group homes for 7+ persons complies with State law” (Exhibit 1, Housing Element Comments and Responses). Based upon the City’s response, the adopted element still does not address this finding. Please see HCD’s prior review.
4. 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. (Gov. Code, § 65583, subd. (a)(6).)
HCD’s prior review found the element must address requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for housing development and submittal of application for building permits. The element was not revised to address this requirement. Please see HCD’s prior review for additional information.
5. Analyze existing assisted housing developments that are eligible to change to non-lowincome housing uses during the next 10 years due to termination of subsidy contracts, City of Beverly Hills’ 6th Cycle Adopted Housing Element Page 4 January 14, 2022
mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).)
HCD’s prior review found the element must estimate the total costs of preserving at-risk units that are in danger of converting to market-rate during the next ten years. In response, the element presents confounding information that the earliest date of conversion for the Beverly Hills Senior Housing project is 2028 and is “technically classified as being at-risk of conversion...”; however, the “City has the right to purchase the upper floor for one dollar in 2041; therefore, this project is not at risk of conversion to market rate.” These revisions do not address HCD’s findings. Please see HCD’s prior review for additional information.
B. Housing Programs
1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov.
Code, § 65583, subd. (c).)
The element now includes revisions that satisfactorily addresses timeframes for Programs 11.5 and 12.1. However, there are no revisions to Programs 9.3 (Home Repair and Improvement) and 10.3 (Housing Trust Fund). In addition, Program 10,4 (Accessory Dwelling Units) still requires timeframes for creating pre-approved ADU plans and for outreach materials, including an ADU webpage.
2. 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 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 A2, 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 City of Beverly Hills’ 6th Cycle Adopted Housing Element Page 5 January 14, 2022
to address a shortfall of sites or zoning available to encourage a variety of housing types.
3. 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 moderateincome households. (Gov. Code, § 65583, subd. (c)(2).) In response to HCD’s prior review, the element now includes revisions that identify additional actions to assist low-, very low-, low- and moderate-income households in Program 10.6 (Partnerships with Affordable Housing Developers). However, none of these actions have corresponding timeframe commitments for implementation that will result in beneficial impacts during the planning period.
4. 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).) As noted in Findings A3 and A4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to add programs and address and remove or mitigate any identified constraints. In addition, while the element now includes revisions to Program
12.1 (Development Standards) that commit the City to amendments by 2024, it still contains terms including “studying” and “evaluating” that do not result in beneficial impacts during the planning period.
5. 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 must include a complete analysis of affirmatively furthering fair housing (AFFH). Based on the outcomes of that analysis, the element must add or modify programs.
6. 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).)
City of Beverly Hills’ 6th Cycle Adopted Housing Element Page 6 January 14, 2022
As noted in Finding A5, the element must complete an analysis of units at risk of conversion to market rate during the planning period. The element must add or modify programs based on the outcomes of that analysis.
7. Develop a plan that incentivizes and promotes the creation of ADU that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “ADU” has the same meaning as “ADU” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd. (c)(7).)
The element now includes revisions that address some timeframes to actions identified in Program 10.4 (Accessory Dwelling Units). However, other actions still lack specified timeframes other than indicating “throughout the planning period,” including amending the zoning code to remove barriers regarding ADUs in multi-family zones, pre-plan checks and pre-approved ADU plans, and creating an ADU webpage.
C. Public Participation
Include a diligent effort by the local government to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort. (Gov. Code, § 65583, subd. (c)(9).) The element now includes revisions that address when the draft was disseminated and how public comments were incorporated. The element also includes clarifying revisions on the types of outreach conducted, including an additional Planning Commission meeting, mailings to property owners, and an ADU survey. However, these revisions are insufficient in demonstrating that all economic segments of the community, particularly low-and moderate-income households and organizations that represent them, were involved in the development of the housing element. Please see HCD’s prior review.
Attachment 5
City Council Agenda Report – 10-12-
2022 (without attachments)
AGENDA REPORT
Meeting Date: October 12, 2021
Item Number:
To: Honorable Mayor & City Council
From: Timothea Tway, AICP, City Planner
Chloe Chen, Associate Planner
Subject: RESOLUTION OF THE COUNCIL OF THE CITY OF BEVERLY HILLS ADOPTING THE 2021-2029 HOUSING ELEMENT, MAKING
FINDINGS RELATED THERETO, AND ADOPTING A MITIGATED
NEGATIVE DECLARATION
Attachments: 1. 2021-2029 Housing Element
2. Resolution
RECOMMENDATION
Staff recommends that the City Council adopt the resolution adopting the General Plan Amendment to adopt an updated Housing Element, and to adopt the Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program.
INTRODUCTION
The State of California requires every city to have a Housing Element in its General Plan. The City of Beverly Hills’ current Housing Element, which covers the planning period from 2014-2021, was adopted by the City Council on December 17, 2013 and certified by the State Department of Housing and Community Development (HCD) as fully compliant with State law in February of 2014. The Housing Element, which is part of the City’s General Plan, is a plan to meet the housing needs of all members of the community. State law requires that the City of Beverly Hills update its Housing Element every eight years, with the next update to cover the planning period from 2021-2029.
HCD has established October 15, 2021 as the due date for submittal of an adopted Housing Element for the 2021-2029 planning period.
Since August 2020, staff has held five study sessions with the Planning Commission and two separate community meetings on the process of updating the Housing Element and
3. HCD Comment Letter
4. Matrix of Responses to HCD
5. Public Notices
6. Public Comments
7. Initial Study/Mitigated Negative Declaration
8. Track Changes – Housing Element Document
'
Meeting Date: October 12, 2021
contents of the housing element. Most recently, on May 27, 2021, the Planning Commission held a study session on the Draft Housing Element. Subsequently, staff submitted the Draft Housing Element to HCD. The City received comments back from HCD on July 30, 2021. Since that time, staff and the Housing Element Consultant have been working to address the comments from the state and prepare the Final Housing Element document for consideration by the Planning Commission and City Council. The remainder of this report discusses the contents of the Housing Element document, provides a summary of the comments received by HCD during their review of the draft document, and highlights the changes that have been made in response to HCD comments.
DISCUSSION
2021- 2029 HOUSING ELEMENT
Required Content
Per State law, a Housing Element must include information that addresses the following broad topics:
• Analysis of the City's demographic characteristics and housing needs • Evaluation of resources and opportunities available to address housing needs • Analysis of potential constraints to meeting the City's housing needs • A review of the City’s accomplishments during the previous planning period and the effectiveness of current policies and programs in meeting housing needs
In addition, a main component of the Housing Element is the Regional Housing Needs Assessment (RHNA). In short, RHNA is the process by which each city is assigned a share of the region’s need for additional housing units during the next Housing Element planning period (2021-2029). RHNA allocations are determined for the City by the Southern California Association of Governments (SCAG) based on criteria established in State law. As discussed at previous Housing Element study sessions, the City’s final RHNA allocation is as follows, and is included here for ease of reference.
Final 6th Cycle RHNA by Income Category – Beverly Hills Very Low Low Moderate Above
Moderate Total
1,008 units 680 units 602 units 814 units 3,104 units
Source: SCAG, 2/23/2021
Structure of 2021-2029 Housing Element
The current Housing Element, and the 2021-2029 Housing Element document are divided into the “Housing Plan,” which includes the policies and programs that ensure there is an adequate supply of safe, affordable housing for all community members, as well as the following five appendices:
x Appendix A - Community Profile
x Appendix B - Potential Constraints on Housing Production and Conservation Meeting Date: October 12, 2021
x Appendix C – Housing Resources
x Appendix D – Review of Past Accomplishments
x Appendix E – Public Participation
Below is a breakdown of the major components of the Housing Element document and notable highlights in each section. Each section also includes a discussion on the main comments received from HCD as a result of their initial review of the draft Housing Element and an overview of the main changes made by staff in response to these comments.
Comments from HCD on Draft 2021-2029 Housing Element
The comment letter that the City received from HCD in response to submittal of the Draft Housing Element is provided in Attachment 3. This letter outlines the changes and/or additions that HCD would like to see in order to achieve a certified housing element.
Specific comments that relate to the various sections of the Housing Element are summarized within each section below.
A response matrix is included as Attachment 4 to this report. This matrix outlines the entirety of the changes that were made to the Draft Housing Element in response to the comments received from HCD during their review. Where changes were not made in response to an HCD comment, an explanation is provided as to why a change was not made. A track changes version of the Housing Element is also provided for additional clarity in Attachment 8.
Planning Commission and City Council Review
Planning Commission Review
On May 27, 2021, the Planning Commission reviewed the draft Housing Element, which provided a chance for the Commission to provide input and comments on the draft prior to the submittal of the draft Housing Element to HCD. The Commission generally found that the report was informative and thought that the draft was in good shape for submittal to the state. Other comments provided included that the Commission wanted to stress the importance of outreach and education on many of the issues included in the draft Housing Element as well as the programs available to residents and special populations.
The Commission also emphasized the importance of the link between housing and mobility, given the City’s recent adoption of the Complete Streets Plan.
On September 23, 2021, the Planning Commission reviewed the revised Housing Element document, which has been updated pursuant to the comments provided by HCD. The Commission provided their thoughts and comments on the document, including how the timing of the adoption of the element might interact with newly adopted state laws, and the adoption of amended inclusionary housing regulations. The Commission also discussed the next steps and asked staff for clarification regarding some content of the document. The Commission unanimously recommended the adoption of the Housing Element document to the City Council.
City Council Review
On June 1, 2021, the draft Housing Element was included on the City Council meeting agenda as an informational item. The City Council did not choose to call up this item for discussion, but was informed that the draft Housing Element would be submitted to HCD for the 60-day review and comment period after the Council meeting.
Meeting Date: October 12, 2021
Housing Plan
Contents
The first component of the Housing Element is the Housing Plan, which includes policies and programs that are designed to ensure there is an adequate supply of safe, affordable housing for all members of the community. The policies address the following topics:
x Housing Maintenance and Conservation
o Program activities under this category include: preserving neighborhood character, historic preservation regulations, rent stabilization regulations, conservation of rental housing, home repair assistance programs x Housing Supply and Diversity
o Program activities under this category include: incentives for affordable housing (i.e. density bonus provisions), inclusionary housing program, accessory dwelling units as affordable units, transit-oriented housing, workforce housing, creating an equitable jobs-housing balance, City partnerships to develop affordable housing
x Fair Housing and Special Needs Residents
o Program activities under this category include: supporting senior populations and housing, homeless services, promoting fair housing practices, allowing low barrier navigation centers
x Removing Governmental Constraints
o Program activities under this category include: amending regulations to allow housing for special needs grounds, affordable housing, and reducing fees for certain housing developments
Significant updates to the Housing Plan from the previous Housing Element (2013-2021) include:
x The establishment of a program to implement regulations related to Low Barrier Navigation Centers, which are services to help reduce barriers to entry for housing and to help move people into permanent housing.
x The exploration of amendments to the zoning code development standards as a removal of governmental constraints. This may include the use of maximum floor area ratios for multi-family developments, more flexible parking regulations, and providing incentives to construct workforce housing.
Summary of Comments from HCD on the Housing Plan
In general HCD requested that all programs have discreet timelines for implementation of the various implementation measures. Further, HCD included comments in their letter requesting additional programs with specific actions and timelines to address the needs of extremely low-income households and households with special needs and the addition of programs to specifically address affirmatively furthering fair housing opportunities. HCD also requested additional action items in the Housing Plan to address identified constraints to the provision of housing.
Meeting Date: October 12, 2021
Summary of Changes Since May 2021 Housing Element Draft Several changes were made to the Housing Plan in response to the comments received from HCD. Namely, discreet timelines were added for implementation of outlined programs in the Plan. A more robust implementation strategy related to affirmatively furthering fair housing was added to the Plan (see Implementation Measure 11.1), which now includes the following language:
“...the City will undertake the following actions intended to foster an inclusive community and enhance access to opportunity for all:
x Ensure that all development applications are considered, reviewed, and approved without prejudice to the proposed residents, contingent on the development application’s compliance with all entitlement requirements. x Accommodate persons with disabilities who seek reasonable waiver or modification of land use controls and/or development standards pursuant to procedures and criteria set forth in the applicable development regulations. x Work with the County to implement the regional Analysis of Impediments to Fair Housing Choice and HUD Consolidated Plan.
x Facilitate public education and outreach by posting informational flyers on fair housing at public counters, libraries, and on the City’s website. x Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources will be invested to provide interpretation and translation services when requested at public meetings when feasible.
x As feasible and legal per state law, provide a virtual option for public meetings to increase ability of all members of the public to participate. x Continue to facilitate the placement of qualified households into affordable housing units constructed in the City. Advertise the units on affordable housing websites with a regional reach. Notify adjacent jurisdiction housing departments when affordable units are available.
x Maintain the affordable housing webpage on the City website with information on applying for available units.
x Encourage community and stakeholder engagement during development decisions.
x Process a Municipal Code amendment clarifying that agricultural employee housing for six or fewer employees is treated as a single-family structure permitted in the same manner as other dwellings of the same type in the same zone.
x By end of 2023, City will work with a consultant to develop fair housing action plan that includes, but is not limited to the programs outlined below. o The City will provide annual fair housing training for staff that are involved directly or indirectly in housing, the capital improvement plan, code enforcement, rent stabilization, and the development of planning and zoning documents.
o The City will provide an update to the Planning Commission on fair housing issues annually
Meeting Date: October 12, 2021
o The City will develop a website that provides fair housing resources o The City will provide brochures and information regarding fair housing, tenant rights, rent stabilization, available grants and loans, first-time homebuyer programs, and Section 8 programs on the city website. o Build upon the existing rent stabilization and tenant’s right protections by creating brochures that will be placed on the website and provided at key community sites (such as City Hall, the library, and community centers). o Review and discuss developments in fair housing related legislation and litigation and consider code amendments to maintain compliance with applicable law.
o Study and amend Municipal code sections 10-3-12.5 and 10-3-12.8 related to incentives for construction multiple-family housing for the elderly and disabled and multiple-family congregate housing for elderly and disabled persons to address identified outdated language and ensure code provisions are not inhibiting such development.
o As feasible and legal per state law, provide a virtual option for public meetings to increase ability of all members of the public to participate. o Continue to facilitate the placement of qualified households into affordable housing units constructed in the City. Advertise the units on affordable housing websites with a regional reach. Notify adjacent jurisdiction housing departments when affordable units are available. o Maintain the affordable housing webpage on the City website with information on applying for available units.”
In addition, Implementation Measure 10.4 has been revised to add additional actions that the City will undertake to encourage the construction of ADUs including:
x Consider greater flexibility in ADU standards in R-1 zones in the Central Area of the City;
x Consider allowances for reduced setback requirements where privacy is not compromised;
x Amend zoning code regarding ADUs in multi-family zones to remove barriers to construction of units above existing garages and allowing additional height; x Create “by right” plan options for residents who wish to pick a pre-approved ADU plan created and pre-plan checked by the City;
x Hold workshops twice a year for the public to explain ADU regulations and answer questions;
x Create a webpage specifically for ADU regulations with frequently asked questions and contact information for planning and building and safety staff; x Report annually to the Planning Commission and City Council on the number of ADUs constructed in the City; and
x Revisit the ADU regulations in 2025 to assess whether further changes to regulations are needed if ADU production falls below targets in the sites inventory.
Additional language was also added to Implementation Measure 12.1 Development standards to address governmental constraints to the production of housing. Notably an Meeting Date: October 12, 2021
implementation measure was added to study and revise the provisions of municipal code sections 10-3-12.5 and 10-3-12.8 related to incentives for construction multiple-family housing for the elderly and disabled and multiple-family congregate housing for elderly and disabled persons to address identified outdated language and ensure code provisions are not inhibiting such development.
Appendix A: Community Profile
Contents
This portion of the Housing Element provides data on the City’s demographics and housing makeup, including information on special needs populations, employment characteristics, and rent and ownership statistics. The majority of this information has been sourced from the Southern California Association of Governments (SCAG) precertified housing data for the City of Beverly Hills.
This data is important because it helps the City understand the current state of housing in the City, and informs what types of policies or programs are needed to specifically address housing needs in the City. Some major highlights include:
x The City had a population of 33,775 in 2020
o 16,639 residents of the City are workers, the majority of which perform management functions
o Higher population share of seniors than the SCAG region o Lower population share of young persons than the SCAG region o Lower share of households experiencing poverty than the SCAG region o Very low share of households are large family households (5 or more people) o Very low share of households are large family households (5 or more people) x Majority (58.6%) of residents are renters, rather than owners o Half of renter households are cost burdened (spend more than 30% of their gross income on housing costs)
x 25% of elderly family households (two persons aged 62 or over) have incomes below 30% of the surrounding area income
x Lower share of single-family residences than the SCAG region o A significant share (38%) of housing units are 80 years or older o 600 housing units were added to the City over the last 20 years x Overcrowding is rare compared to the SCAG region
The general takeaways from this data are that housing and population trends in the City may not always align with the greater SCAG region, and housing policies and programs in the City should focus on providing housing assistance for the growing senior population, security and affordability for renter households to reduce cost burdening, and maintenance of aging housing stock.
Summary of Comments from HCD on Appendix A
In general the comments pertaining to this section of the Housing Element related to a desire from HCD to see additional information about affirmatively furthering fair housing.
Meeting Date: October 12, 2021
In addition, HCD requested further analysis on projected housing need for extremely low-income households.
Summary of Changes Since May 2021 Housing Element Draft The most notable change in this portion of the Housing Element is the addition of the “Fair Housing Assessment” in Section E of Appendix A. This section was added to address the HCD comments about the need to specifically analyze and address fair housing issues. This analysis indicates that the primary barrier to fair housing in the city is high housing cost, which has the effect of limiting access by lower-income households to the high opportunities and resources available in Beverly Hills. There is no evidence to suggest that discrimination against racial groups or persons with disabilities is a major issue. This analysis informs the various implementation measures included in the Housing Plan, especially the implementation measures aimed at addressing housing affordability and fair housing issues.
Appendix A has also been revised to provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness).
The element has been revised to include a description of public outreach, an assessment of fair housing, identification and prioritization of contributing factors to fair housing issues and goals, and actions sufficient to overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity.
In addition, the analysis of extremely low-income (ELI) households has been expanded to include projected housing needs based upon 50% of the RHNA for very-low-income households pursuant to Gov. Code, §65583(a)(1).
Appendix B: Potential Constraints on Housing Production and Conservation Contents
This portion of the Housing Element provides a picture of the potential limiting factors that affect housing production and conservation in the City. These includes market, governmental and environmental and infrastructure constraints. x Market constraints can include economic constraints, construction costs, the cost and availability of land, and the cost and availability of financing for housing projects.
Key aspects of this category of constraints includes:
o Construction costs have generally continued to increase, but are not significantly higher than the greater Los Angeles area. o The vast majority of properties in the City (those previously developed, rather than vacant) are infill properties, which sometimes require more expensive construction types and components.
o The cost of land is relatively high due to a desirable location and limited availability of land suitable for development.
o Interest rates have been declining in recent years, which reduces the cost of construction loans and home mortgages.
x Governmental constraints can include local regulations or policies that affect land development, such as zoning use restrictions or permit processing times. Key aspects of this category of constraints includes:
Meeting Date: October 12, 2021
o Since the last Housing Element, there have been some notable changes to regulations affecting housing:
In 2015, the City updated its Historic Preservation regulations, which now include the Mills Act Program and Historic Incentive Permit program. These programs intend to incentivize the preservation of historic properties through tax and development incentives. In 2019, the City adopted an urgency ordinance that requires inclusionary housing (a minimum number or percentage of affordable income units) in new multi-family residential developments. In 2017-2019, the City made significant changes to its Rent Stabilization ordinance, which included a change to the allowable rent increase calculation, the elimination of no cause evictions, and the establishment of the Rent Stabilization Commission.
In 2020, the City adopted the Mixed Use (MU) Overlay, which allows multi-family residential uses in certain commercial zones, where this use was not previously allowed. This has created a significant opportunity to add net new housing units in the City.
The State legislature adopted SB 330, which requires replacement of existing housing units in any new multi-family development project.
The requirements of this law essentially result in the application of the General Plan Land Use density and height limits, rather than the zoning code density and height regulations.
The State legislature adopted AB 2345, which amends existing density bonus law provisions to allow up to a 50% density bonus to be granted for housing projects, as well as parking reductions. The State Legislature adopted AB 101, which establishes requirements related to local regulation of low barrier navigation centers, which help move people into permanent housing with services to reduce barriers to entry into housing.
The Special Housing Needs Overlay Zone has been established to encourage the construction of housing for persons with special needs. The City has established regulations to specifically encourage the provision of higher density rental housing for seniors and persons with disabilities at costs lower than could otherwise be achieved. o City review processes and fees have not changed significantly during this period.
x Environmental or infrastructure constraints can include natural hazards, geographic/topographic, or public resource conditions that can affect the appropriate locations and cost for housing to be built. Key aspects of this category of constraints includes:
o Environmental and Infrastructure Constraints
There are three active and potentially active seismic faults located in the City: the Hollywood Fault, the Santa Monica Fault, and the Newport-Inglewood Zone of Deformation. The City has implemented a mandatory seismic retrofit program for soft-story buildings.
Meeting Date: October 12, 2021
The hillside areas could be potentially affected by landslides in a weather or natural disaster event, and development of these areas may place additional stress on the bedrock. Future growth in these areas may be limited by this constraint.
There are no FEMA-designated flood zones in the City, but the Lower Franklin Canyon Dam could present a flooding hazard in the event it fails.
The hillside and canyon areas are also affected by wildfire hazards, and all areas located north of Sunset Boulevard are designated a Very High Fire Hazard Severity Zone (VHFHSZ). The City has implemented programs to educate and reduce fire risk in these areas. There is also potential fire risk in denser, built-out areas of the community, particularly for high-rise buildings that do not have sprinkler systems, but the City has implemented programs to mitigate these risks.
The City provides water service to all residents, the majority of which is imported from the Metropolitan Water District, and continues to explore the use of groundwater wells. The water supply is expected to meet future population growth up to 2030.
More than half of the sewer system is over 50 years old, and the City currently implements a rehabilitation program to replace and repair the sewer.
The City owns approximately two-thirds of improved storm drains, and the regional Hollyhills Storm Drain improvement project has increased capacity and reduced the risk of flooding.
The City is located at the center of regional traffic generators and the convergence of several major thoroughfares. The City is served by several transit agencies, and notably, Metro has planned two underground rail stations in the City that will connect to the Purple Line. The Complete Streets Plan was recently adopted, which promotes a more holistic bike and pedestrian network.
Summary of Comments from HCD on Appendix B
In general, the HCD comments related to this appendix include a request for additional information related to, and analysis of, the various constraints outlined in the draft appendix. In addition, the letter provides direction as to where programs may be necessary to address identified constraints.
Summary of Changes Since May 2021 Housing Element Draft The element has been revised to include additional analysis of potential environmental constraints, and concludes that environmental issues will require development to incorporate measures to mitigate potential hazards, but these constraints are not expected to preclude housing development consistent with the RHNA.
Additional analysis of sewer capacity to accommodate the City’s RHNA allocation has been provided. The analysis concludes that sewer capacity is expected to be sufficient to accommodate projected housing development.
Meeting Date: October 12, 2021
The element has been revised to expand the analysis of development standards and criteria on the cost of development in the City. This additional analysis has informed changes to some of the Implementation Measures outlined in the Housing Plan, including additional measures to encourage and facilitate ADU development, and measures to address identified zoning code barriers to the development of multi-family projects, especially multiple-family housing for the elderly and disabled and multiplefamily congregate housing for elderly and disabled persons. Additional information regarding recently approved or constructed multi-family development projects has also been included to demonstrate the typical densities of recent projects. This information resulted in the addition of Programs Imp. 11.1 and 12.1 to the Housing Plan in order to study how to encourage the construction of more housing for the elderly and disabled populations, and congregate care housing.
Appendix C: Housing Resources
This portion of the Housing Element discusses the land, financial, and organizational resources available to help address housing needs. The most important component of this appendix is the sites inventory, which identifies sites for future housing development, and evaluates the adequacy of those sites to accommodate the City’s RHNA allocation.
The RHNA identifies the amount of additional housing at different price levels a jurisdiction would need in order to fully accommodate its existing population plus its assigned share projected growth over the next 8 years while avoiding problems like overcrowding and overpayment. The RHNA is a planning requirement based upon housing need, not a construction quota or mandate. Highlights of the RHNA analysis includes:
x As shown in the Sites Inventory section, the combination of approved projects, underutilized sites, and potential ADUs results in a total of 8,570 housing units that could potentially be constructed in the City. This satisfies the City’s overall RHNA allocation of 3,104 total units for the 2021-2029 planning period, as well as the number of housing units in each income category. Table C-1 provides a summary of the adequate sites analysis, and Exhibit A of the appendix contains Table C-3, which includes parcel data for the MU Overlay Zone.
x The majority of housing units that can satisfy the RHNA allocation are derived from the calculation of the residential development potential in the Mixed Use (MU) Overlay Zone. Maximum residential density within the MU Overlay is 79 dwelling units per acre, and height limitations range from 3 to 5 stories (location-based). Since the MU Overlay has been applied to certain commercial zones, any new residential units constructed on these sites are net new housing units. Even when small sites (those less than ½ an acre) are excluded from the sites inventory, the remaining capacity would still total more than 3,000 housing units. x Another significant contributor to satisfying the RHNA allocation are accessory dwelling units (ADUs). State law now allows two ADUs on the majority of singlefamily residential properties. ADUs are also permitted on multi-family residential properties.
This appendix also includes three subsections regarding three broad categories of housing resources: financial resources, administrative resources, and opportunities for energy conservation. Highlights include:
Meeting Date: October 12, 2021
x Financial Resources:
o The Community Development Block Grant (CDBG) provides funds to local governments for housing and development activities that serve low-income groups. The City receives approximately $169,000 in funding each year, which support the Handyworker Program (Residential Rehabilitation Program) for lower income tenants and homeowners, and Senior Case Management programs.
o The Community Assistance Grant Funding (CAGF) allocates funding for a variety of service organizations that provide social services in the community, such as homeless assistance programs.
o The Affordable Housing Trust Fund was established in FY 2016-17 to be used to construct or help construct affordable housing. Funds have been collected through development agreements, and will continue to be collected through the inclusionary housing in lieu fee.
o The City approved a COVID-19 rent subsidy program to prevent evictions during the pandemic.
x Administrative Resources:
o Menorah Housing Foundation is a non-profit organization that developed and operates the Beverly Hills Senior Housing building on N. Crescent Drive. o Alternative Living for the Aging is a non-profit organization that assists elderly people in finding housing suited to their specific needs. o West Hollywood Community Housing Corporation buys, builds, rehabilitates, and manages affordable housing for lower-income populations in West Hollywood and the greater Los Angeles area.
x Opportunities for Energy Conservation:
o The City recognizes the need to reduce energy consumption and address climate change through emissions reduction, and has adopted a Sustainable Living Program to promote environmental responsibility. The City continues to implement sustainability initiatives to reduce environmental footprints, and improve residents’ quality of life.
o The City implements and enforces Energy Efficiency Standards for residential and non-residential construction through its plan review and inspection programs.
o The City has amended the 2019 CALGreen standards to include enhanced requirements for electric vehicle charging and water conversation, and continues to enforce CALGreen regulations.
o The Sustainable City Plan provides a framework to ensure that the City’s infrastructure and development is designed with sustainable practices. o The City is developing a Climate Action Adaptability Plan to support the State’s climate goals and the Paris Climate Agreement of 2050, which will provide a Citywide greenhouse gas inventory and reduction analyses. o The City’s Clean Power Alliance provides utility rate reduction programs that incentivize energy conservation and the use of renewable energy sources.
Meeting Date: October 12, 2021
Summary of Comments from HCD on Appendix C
In their letter, HCD requested additional information and analysis related to the sites inventory including: more complete information related to the current use for each parcel, further analysis of why non-vacant sites are suitable for inclusion in the sites inventory, and further analysis of “realistic capacity” of the sites in the inventory.
Summary of Changes Since May 2021 Housing Element Draft A number of changes and refinements were made to the sites inventory based on questions and comments from HCD. Notably, several properties were removed from the sites inventory because they are highly unlikely to be developed with housing in the near future, such as the Saban Theater, the Peninsula Hotel, the Fine Arts Theater, and the Beverly Wilshire Hotel. In addition, several vacant R-4 parcels near commercial areas (mostly adjacent to Wilshire Blvd. to the south) have been added to the inventory because they are currently only improved with surface parking lots. Due to these refinements, the estimated RHNA capacity of the sites inventory is: 8,570 units, the vast majority of which are located within the mixed use overlay zone, but which also includes approved projects, and potential accessory dwelling units (ADUs).
The element has been revised to include analysis of the potential for additional development on non-vacant sites in the mixed-use overlay, including the extent to which existing uses may constitute an impediment to 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 residential development on these sites.
Additional information has been added regarding the mixed use overlay to further support the City’s position that this zone can accommodate the allocated RHNA. This includes an explanation about a specific provision of the overlay zone language that allows a property owner to convert an existing building in the zone to housing, even if it does not meet the current zoning requirements. This is meant to encourage the adaptive reuse of existing commercial buildings and provide as much flexibility for the reuse of buildings as possible. This also ensures that buildings do not need to be demolished in order to provide additional housing in the mixed-use overlay area. Further, additional analysis has been included regarding the improvement-to-land (I/L) value ratio, which can be used to measure the likelihood of redevelopment (an I/L ratio of less than 1 generally indicates development could be likely). Over 60% of the parcels included in the sites inventory have an I/L ratio of less than 1, with the potential to yield 5,074 units through the mixed use regulations, which provides significant buffer room over the RHNA total of 3,104 units. This supports the City’s findings that parcels in the mixed-use zone provide adequate realistic capacity to accommodate the RHNA allocation during the planning period.
Information has also been added regarding recently approved or constructed mixed use buildings in Table C-4. These buildings were approved prior to the establishment of the mixed use zone, which illustrates that, even before mixed use was an allowed use in the City, there was developer demand to construct such projects, which resulted in a number of net new units in the City (including affordable units).
Since the element is relying on non-vacant sites to accommodate 50% or more of lowerincome needs households, the analysis supports the City’s findings based on substantial evidence that the existing uses do not constitute an impediment to additional residential Meeting Date: October 12, 2021
development during the planning period and will likely discontinue in the planning period pursuant to Government Code §65583.2(g)(2).
The analysis of site capacity has been expanded to provide additional information describing how the number of units for each site was determined based upon land-use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. The revised element also analyzes the likelihood of residential development in zoning districts where 100% nonresidential uses are allowed based on factors such as development trends including nonresidential, performance standards requiring residential uses, or other relevant factors such as enhanced policies and programs.
Appendix D: Review of Past Accomplishments
This component of the Housing Element provides an overview of the City’s progress in achieving the policies and programs set forth in the previous Housing Element planning period from 2014 to 2021. The City is required to submit General Plan Annual Progress reports to HCD on a yearly basis, which also includes information on the City’s progress in achieving the RHNA for the planning period.
As noted in this appendix, the City met its RHNA allocation of 3 units, as a total of 208 housing units were constructed during the last planning period. In addition, the City has continued to take steps towards accomplishing its housing policies and goals through its implementation of programs. Table D-2 in this appendix provides a summary of all of these accomplishments, but some notable highlights include:
x Significant update to the Rent Stabilization regulation and program x Proclamation of a local emergency in response to the COVID-19 pandemic and adoption of urgency ordinances to establish an eviction moratorium on all residential rental properties, and to establish a rent subsidy program for eligible tenants x Adoption of an urgency ordinance to establish inclusionary housing regulations x Ongoing financial support of service organizations that serve the homeless and persons at risk of homelessness
x Ongoing financial support of housing and senior pro bono legal services x Continuing to explore opportunities to develop affordable housing through a partnership with non-profit developers or the use of City-owned land x Negotiation of approximately $4.5 million from development agreements to be contributed to the Affordable Housing Trust Fund
Summary of Comments from HCD on Appendix D
In general, the comments on this portion of the Housing Element were minimal, and some were conveyed verbally via a phone call with HCD staff. HCD requested additional analysis of the effectiveness of goals, policies and related actions to meet the housing needs of special populations.
Meeting Date: October 12, 2021
Summary of Changes Since May 2021 Housing Element Draft The City amended Appendix D by adding additional details to the status of housing programs where possible. In addition, analysis was added to outline how the existing goals, policies and programs addressed the housing needs of special populations.
Appendix E: Public Participation
The last component of the Housing Element discusses the public outreach efforts that were conducted. This included several Planning Commission study sessions focused on various Housing Element topics, which intended to both educate and disseminate important information about the Housing Element Update process and requirements.
In addition, staff hosted community meetings designed to further educate and engage members of the public with the Housing Element Update. The community meetings were advertised to the public via multiple methods of noticing, and staff has maintained a list of interested parties to whom any important updates and information related to the Housing Element Update (such as any scheduled study sessions or community meetings) is sent.
Staff has also published a survey focused on housing, which received responses from 91 individuals. A survey was also published specific to ADU regulations in order to inform future ADU ordinances and policy. The results of the surveys are contained as an attachment to Appendix E. In addition, staff maintains a dedicated webpage1 , and
monitors a dedicated email inbox2 for the Housing Element Update project.
Summary of Comments from HCD on Appendix E
HCD provided comments to the City regarding additional information that should be included in Appendix E regarding outreach efforts and providing the opportunity for the public to view the housing element document prior to approval.
Summary of Changes Since May 2021 Housing Element Draft Changes have been made to Appendix E to further describe the various outreach efforts that were undertaken throughout the year-long Housing Element Update process including highlighting the public meetings and study sessions that took place, and providing examples of the flyers, notices, and social media posts that were used to disseminate information to the public. In addition, information has been included as to how public comments were addressed into the Housing Element document.
ENVIRONMENTAL REVIEW
The proposed project has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines3
, and the environmental regulations of the City. An Initial Study/Mitigated Negative Declaration has been prepared for the project by the City of Beverly Hills, the lead agency for this project. The Initial Study/Mitigated Negative Declaration was made available for public review beginning on June 10, 2020, and the public comment period will be open from June 10, 2020 to July 17, 2020.
1 www.beverlyhills.org/housingelementupdate
2 Email address: [email protected]
3 The CEQA Guidelines and Statute are available online at http://ceres.ca.gov/ceqa/guidelines.
Meeting Date: October 12, 2021
The Initial Study/Mitigated Negative Declaration (Attachment 7) analyzes the proposed project’s effects on environmental factors and concludes that there will be no impact to Agricultural and Forestry Resources, and Mineral Resources, and less than significant impacts, with certain mitigations, related to Aesthetics, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Noise, Population and Housing, Transportation/Traffic, Public Services, Recreation, Tribal Cultural Resources, Utilities and Service Systems, and Wildfire. The Initial Study/Mitigated Negative Declaration identifies that there is no substantial evidence that the proposed project would result in significant impacts to any of the environmental factors listed above, and the proposed project would result in in less than significant impacts for the Mandatory Findings of Significance, as the proposed project is the update of the Housing Element, which is a policy document, and does not include any physical changes or development in the City at this time.
In accordance with the regulations outlined in CEQA, the Notice of Intent to Adopt an Initial Study/Mitigated Negative Declaration, in combination with the Notice of Public Hearing, was provided to the public at least 20 days in advance of this hearing date.
The notice is included as Attachment 5.
Since the Initial Study/Mitigated Negative Declaration was circulated, minor changes have been made to the Housing Element programs, as summarized in Table 1 of the Initial Study/Mitigated Negative Declaration. These changes were not substantial, and more information can be found in Exhibit A to the Initial Study/Mitigated Negative Declaration. Exhibits B and C have also been attached to the Initial Study/Mitigated Negative Declaration, which are respectively: the responses to any comments received, and the Mitigation Monitoring and Reporting Program for the project.
FISCAL IMPACT
Since the update to the Housing Element is a state-mandated process, the City Council has previously allocated budget for this activity. Staff has utilized this budget allocation for activities including public outreach, and the use of consulting firms to assist with the preparation of the Housing Element. The Housing Element includes policies and goals that the City must undertake in the next planning period from 2021 to 2029, some of which may require additional budget allocations as work plans are adjusted to accommodate these activities. Therefore, the adoption of the Housing Element document may require future budget allocations, but does not have a direct fiscal impact at this time.
Ryan Gohlich, AICP,
Director of Community Development
Approved By
Attachment 6
Public Comments Received Before
Adoption (10-12-2022)
9/14/21, 11:06 AM 2021 Housing Element Update
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Dear Mayor Friedman, Mr. Chavez, and Mr. Gohlich,
My name is Anthony Dedousis, and I'm director of policy and research at Abundant Housing LA. We're a pro-housing education and advocacy group focused on helping to solve Southern California's housing crisis.
I'm reaching out to share a letter offering guidance for Beverly Hills’ upcoming 2021 housing element update. It contains a detailed summary of key legal requirements and recommended best practices for housing element updates, and highlights four critical components of the site inventory analysis portion of the housing element. We strongly recommend that you and your team follow these standards as you begin the housing element update process.
Additionally, we'd like to share a memo with additional detail on recommended best practices and legal requirements for the site inventory analysis, as well as a one-page "checklist" summary version.
These reflect guidance from the state Department of Housing and Community Development (HCD), legal scholars, and planners.
We would be glad to engage with your office and with the Planning Department throughout the housing element update process. We look forward to a productive and collaborative working relationship with the City of Beverly Hills on this critical effort.
Thank you,
Anthony
--
Anthony Dedousis
2021 Housing Element Update
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Abundant Housing LA
515 S Flower Street, 18th Floor
Los Angeles, CA 90071
516-660-7402
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October 16, 2020
Mayor Lester Friedman
City of Beverly Hills
455 North Rexford Drive
Beverly Hills, CA 90210
Dear Mayor Friedman,
We are writing on behalf of Abundant Housing LA regarding Beverly Hills’ upcoming 6th Cycle housing element update. Abundant Housing LA is a pro-housing education and advocacy organization working to help solve Southern California’s housing crisis. We support efforts to reform zoning codes and expand housing production, which are needed to reduce rents, improve access to jobs and transit, strengthen the local economy and job market, and combat segregation. We have a large and growing membership base throughout Los Angeles County, including Beverly Hills.
California has a statewide housing shortage of nearly 3.5 million homes, and has the highest poverty rate in the nation after accounting for housing costs. Households at all levels of income face a historically high rent burden. Exclusionary zoning and longstanding constraints on denser housing have led to an undersupply of medium and high density housing near jobs and transit.
This contributes to high rents and displacement of households.
Over the past few years, new state laws (e.g. AB 686 (2018), SB 166 (2017), AB 1397 (2017), SB 828 (2018), SB 35 (2017), etc.) have strengthened the Regional Housing Needs Assessment (RHNA), which sets a housing growth target for individual jurisdictions and requires jurisdictions to update their housing elements in order to achieve these targets.
These changes to state law have led to historically high jurisdiction-level housing growth targets in the upcoming 6th Cycle Housing Element Planning Cycle, and have empowered the state Department of Housing and Community Development (HCD) to enforce appropriately high standards for housing element updates. We are encouraged that Beverly Hills was given a target of 3,096 new homes, of which 1,683 must be affordable to lower-income households.
As jurisdictions start the housing element update process, AHLA seeks to provide guidance on how jurisdictions should fulfill both the letter and the spirit of housing element law. Unfortunately, some jurisdictions are already seeking to skirt their obligation to sufficiently plan to meet their housing needs. AHLA will scrutinize jurisdictions’ housing elements, submit comments to HCD as needed, and collaborate closely with nonprofits that bring legal action against jurisdictions that fail to comply with state housing laws.
1 Of course, AHLA recognizes that the COVID-19 pandemic and resulting economic devastation have made it more difficult for jurisdictions to meet ambitious RHNA targets. But the pandemic has made it even more critical than ever for jurisdictions to solve the region’s housing crisis and encourage economic recovery. We seek to collaborate with you and your team on policy efforts to achieve the RHNA goals.
To that end, we have published a memo, Requirements and Best Practices for Housing Element Updates: The Site Inventory , explaining the key legal requirements, as well as HCD and AHLA’s recommended best practices, for housing element updates. Additionally, this checklist provides a summary of our core policy recommendations . We respectfully encourage you to incorporate the concepts detailed in these documents into Beverly Hills’ housing element update.
As your team begins to develop Beverly Hills’ housing element update, we would like to draw particular attention to four critical components of the site inventory analysis:
1. Incorporating an estimate of the likelihood of development and the net new units if developed of inventory sites
2. Using an HCD-recommended “safe harbor” methodology for forecasting future ADU production
3. Prioritizing high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) when selecting sites for lower-income housing opportunities, in order to affirmatively further fair housing
4. Including the HCD-recommended buffer of at least 15-30% extra capacity in the site inventory, in order to avoid violating the No Net Loss requirement Component #1: Housing elements should estimate and report both the likelihood of development and the net new units if developed of inventory sites.
Just because jurisdictions zone for more housing doesn’t mean that the housing will actually be built. The economic cycle, uncertainty of market conditions, the current usage of nonvacant sites, and land use regulations all influence the extent to which rezoned parcels are built to their maximum theoretical capacity.
A parcel’s maximum theoretical capacity is not the same as its realistic capacity. To draw a parallel to college admissions, when UCLA wants 2,000 students in its incoming class, they admit 4,000 students. Similarly, to achieve housing production targets, jurisdictions must increase zoned capacity well above the target number of new homes.
An accurate assessment of site capacity is necessary in order for the housing element to achieve sufficient housing production. The site capacity estimate should account for the following two factors:
2 ● What is the likelihood that the site will be developed during the planning period? ● If the site were to be developed during the planning period, how many net new units of housing are likely to be built on it?
These are the likelihood of development and net new units if developed factors, as 1 2 required by HCD guidelines. The portion of the jurisdiction’s RHNA target that a site will realistically accommodate during the planning period is:
(likelihood of development) x (net new units if developed) = realistic capacity.
In past planning cycles, the likelihood of development factor was not expressly considered; housing elements frequently assumed that most or all site inventory locations would be redeveloped to their maximum theoretical capacity. Since this generally did not happen, jurisdictions consistently fell short of their RHNA targets as a result. While Beverly Hills achieved its 5th cycle RHNA targets for very low, low, and moderate income housing, this is because the 5th cycle RHNA goal was extremely low -- just 3 homes!
5th Cycle RHNA Targets vs. Actual Housing Production (2014-19) Income Bucket RHNA Target Homes Permitted
VLI 1 9
LI 1 3
MI 1 2
AMI 0 181
Total 3 195
According to Beverly Hills’ 5th cycle housing element, the city had theoretical capacity for roughly 1,218 more housing units. Through 2019, Beverly Hills permitted 195 housing units , 3 4 which equates to 260 housing units permitted by the end of the 5th cycle (assuming that the same annual permitting pace continues in 2020 and 2021). This implies that in Beverly Hills, excess zoned capacity has a 21% likelihood of being developed (260 actual units divided by 1,218 theoretical units).
Beverly Hills’ 6th cycle housing element should incorporate this likelihood of development estimate into its site inventory analysis. This would be consistent with HCD guidelines, while 5 also ensuring that enough zoned capacity is available to encourage 3,096 housing units to be 1 HCD Site Inventory Guidebook, pg. 20
2 HCD Site Inventory Guidebook, pg. 21
3 Beverly Hills 5th Cycle Housing Element, pg. 35
4 HCD Annual Progress Report dataset, 2020
5 HCD Site Inventory Guidebook, pg. 20
3 built by the end of the 6th cycle. Assuming that zoned capacity has a 21% likelihood of being developed in the next 8 years, the housing element must allow for 14,743 units of zoned capacity in order to achieve 3,096 actual housing units. If Planning believes that a higher likelihood of development (and thus a smaller zoned capacity increase) is justified for certain parcels in the site inventory, persuasive data to support this assumption must be provided. 6 Component #2: Housing element updates should use an HCD-recommended “safe harbor” methodology for forecasting future ADU production.
Local jurisdictions frequently use overly optimistic estimates of future ADU production to avoid necessary housing reform and rezoning. ADU development estimates must reflect actual on-the-ground conditions to ensure that they are realistic. Overly aggressive ADU production estimates set jurisdictions up for failure in providing the required housing for residents.
To that end, HCD has established two safe harbors for forecasting ADU production during the 6th Cycle . One option (“Option #1”) is to project forward the local trend in ADU construction 7 since January 2018. The other, for use when no other data is available (“Option #2”), assumes ADU production at five times the local rate of production prior to 2018. Jurisdictions are also permitted to include programs that aggressively promote and incentivize ADU construction.
Where no other data is available, jurisdictions may assume an average increase of five times the previous planning period construction trends prior to 2018. Jurisdictions may also use regional ADU production trends, and include programs that aggressively promote and incentivize ADU construction. Jurisdictions should clearly and explicitly state their methodology and data sources for future ADU development forecasts.
According to HCD, Beverly Hills issued permits for 0 ADUs in 2017, 0 ADUs in 2018, and 6 ADUs in 2019. Under HCD’s “Option #1”, Beverly Hills could take the average of the 2018 and 2019 ADU production trends, and forecast that 3 ADUs will be permitted per year during the 6th cycle. This would allow for a total 6th cycle forecast of 24 ADUs.
Under HCD’s “Option #2”, Beverly Hills could multiply the 2017 ADU production trend by five, and forecast that 0 ADUs will be permitted per year during the 6th cycle. This would allow for a total 6th cycle forecast of 0 ADUs. Abundant Housing LA does not recommend this methodology, since based on the ADU permit totals in 2019, it is extremely unlikely that no ADUs would be permitted between 2021 and 2029.
Another, more aggressive, option would take the average of the 2018 and 2019 ADU production trends, and multiply that average by five. This methodology would forecast that 15 ADUs will be permitted per year during the 6th cycle. This would allow for a total 6th cycle forecast of 120 6 HCD Site Inventory Guidebook, pg. 20-21
7 HCD Site Inventory Guidebook, pg. 31
4 ADUs. Abundant Housing LA does not recommend this methodology, since it is not an HCD-defined safe harbor forecasting option.
Beverly Hills should use HCD’s Option 1 safe harbor when projecting annual ADU production. If it believes that higher ADU production forecasts are warranted, it must provide well-grounded estimates, based on the pace of ADU production in neighboring jurisdictions, and must explain programs or policy efforts that could lead to higher ADU production.
Finally, per HCD, the housing element “should also include a monitoring program that a) tracks ADU and JADU creation and affordability levels, and b) commits to a review at the planning cycle midpoint to evaluate if production estimates are being achieved.” Beverly Hills’ housing 8 element should commit to mid-cycle rezoning if ADU production is lower than forecasted, and its midpoint review should be linked with immediate and automatic programs to increase housing production in the second half of the RHNA cycle. AHLA’s recommended approach is to incorporate by-right density bonuses on inventory sites, which would automatically take effect mid-cycle if the ADU target is not met. The density bonus should be large enough, and apply to enough parcels, to fully make up for any ADU production shortfall.
Component #3: Housing elements must prioritize high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) when selecting sites for lower-income housing opportunities, in order to affirmatively further fair housing.
AB 686 (2018) requires housing element updates to “affirmatively further fair housing”, which is defined as “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.”
Beverly Hills’ history details examples of how housing policy and land use regulations were once used to exclude members of minority groups. Restrictive covenants were once common in Beverly Hills, and forbade the sale or rental of property to Black and Jewish Americans. In 1995, several Black residents filed a federal civil rights lawsuit against the city of Beverly Hills , alleging police misconduct.
Beverly Hills remains segregated today, with white Americans making up nearly 80% of the city’s population . Exclusion continues on the basis of income: the median home sale price in 9 Beverly Hills was $2,619,000 in 2018 , and 50% of the city’s renters are “rent-burdened” (i.e. 10 they spend more than 30% of their income on rent) . High housing costs place a 11 8 HCD Site Inventory Guidebook, pg. 31
9 American Community Survey, 2014-18
10 SCAG Pre-Certified Local Housing Data, Beverly Hills 11 American Community Survey, 2014-18 5 disproportionate burden on lower-income communities of color, and have the effect of excluding them from the city altogether.
Jurisdictions must address this issue by accommodating the lower-income RHNA targets in a way that conforms with AFFH requirements. HCD’s Site Inventory Guidebook offers recommendations for how jurisdictions should accomplish this. HCD is likely to require jurisdictions to distribute lower-income housing opportunities throughout the jurisdiction, and recommends that jurisdictions first identify development potential for lower-income housing in high-opportunity neighborhoods . 12 Given that single-family, exclusionary zoning predominates in many of Beverly Hills’ high- and highest-opportunity census tracts ( as defined in the TCAC/HCD Opportunity Map ), rezoning is required in order to accommodate the RHNA targets for lower-income households. Additionally, focusing rezoning in single-family zoned areas will expand housing opportunities while minimizing the impact on existing renters in multifamily-zoned areas.
In order to fairly distribute housing opportunities citywide, Beverly Hills should develop a quantitative methodology for scoring neighborhoods, based on factors like housing costs, median income, access to transit, access to jobs, access to schools, and environmental quality.
Neighborhoods that score higher on these dimensions should be allocated higher housing growth targets, and rezoning should be based on these neighborhood-level housing growth targets.
Finally, Beverly Hills should identify funding sources, public resources, and density bonus programs to maximize the likelihood that housing projects with below market-rate units are actually built. Local measures like a real estate transfer tax and congestion pricing could help generate new funding to support affordable housing production and preservation.
Component #4: Housing elements should include the HCD-recommended buffer of at least 15-30% extra capacity in the site inventory, in order to avoid violating the No Net Loss requirement.
SB 166 (2017) requires adequate sites to be maintained at all times throughout the planning period to accommodate the remaining RHNA target by each income category. This means that 13 if a jurisdiction approves a development on a parcel listed in the site inventory that will have fewer units (either in total or at a given income level) than the number of units (either in total or at a given income level) anticipated in the site inventory, then the jurisdiction must identify and make available enough sites to accommodate the remaining unmet RHNA target for each income category. 14
12 HCD Site Inventory Guidebook, pg. 3 13 HCD No Net Loss Law Memo, pg. 1 14 HCD Site Inventory Guidebook, pg. 22 6 If additional sites with adequate zoned capacity don’t exist, then the jurisdiction must rezone enough sites to accommodate the remaining unmet RHNA target within 180 days. If the jurisdiction fails to accomplish this rezoning in the required period, then the consequences will include decertification of the housing element and potential state legal action.
To ensure that adequate housing capacity at all income levels exists in the housing element through the 6th Cycle, HCD recommends that “the jurisdiction create a buffer in the housing element inventory of at least 15-30% more capacity than required, especially for capacity to accommodate the lower income RHNA.” Beverly Hills should “overshoot” on total site 15 capacity for each income level, in order to ensure that the City’s RHNA target is achieved at all income levels.
The City of Beverly Hills has an obligation to sufficiently plan to meet current and future residents’ housing needs. The housing element update affords Beverly Hills, and the broader Southern California region, the chance to take bold action on lowering housing costs, reducing car dependency, strengthening the local economy, and guaranteeing access to opportunity for Californians of all racial and ethnic backgrounds. We urge you and your colleagues to fully embrace this opportunity to transform Beverly Hills for the better.
Finally, it is worth noting that state law imposes penalties on jurisdictions that fail to adopt a compliant 6th cycle housing element update by October 15, 2021. On that date, noncompliant jurisdictions will forfeit the right to deny residential projects on the basis of local zoning, so long as projects include at least a 20% set-aside for below market-rate units . Jurisdictions that want 16 to maintain local control over new development should therefore plan to adopt a compliant housing element update on time.
We would be glad to engage with your office and with the Planning Department throughout the housing element update process. We look forward to a productive and collaborative working relationship with the City of Beverly Hills on this critical effort. Thank you for your consideration.
Sincerely,
Leonora Camner
Executive Director
Abundant Housing LA
Anthony Dedousis
Director of Policy and Research
Abundant Housing LA
15 HCD Site Inventory Guidebook, pg. 22 16 California Government Code 65589.5(d)(5) 7 Read about the coalition here
JOHN JACKSON
September 14, 2021
Beverly Hills City Council
Beverly Hills City Hall
455 North Rexford Drive
Beverly Hills, CA 90210
Dear Councilmembers:
Thank you for the opportunity to comment on the process of updating the housing element of Beverly Hills’ general plan. We are writing on behalf of the Our Future LA Coalition regarding the 6th Cycle housing element update.
Why does this matter? Because we face a cascade of housing crises in our region. And while nearly everyone in Los Angeles County feels the crush of our housing crisis, Black and Latino residents feel it more than most:
● Black households have 1.12% the wealth of white households, and Latino households less than 5% (Federal Reserve Bank of San Francisco)
● Black people make up 8% of the county population, but 33.7% of people experiencing homelessness (LAHSA)
● Even under COVID-related eviction moratoriums, Black and Latino neighborhoods face disproportionately higher eviction threats (Los Angeles Times, UCLA) ● One in four AAPIs pay more than half of their income toward housing costs compared to whites (16 percent), putting many on the edge of financial vulnerability. This segment of 2 the population is considered severely cost-burdened (Crisis to Impact Report, A joint publication of the National Coalition of Asian Pacific American Community Development and the University of California, Los Angeles)
These are the effects of decades of racist policies that we have not eradicated: Restrictive covenants, exclusionary zoning, and redlining made it impossible for Black families to build wealth through homeownership, and result in lower homeownership and higher rents today. The California Constitution’s Article 34 and local “crime-free housing” policies put roadblocks in the way of addressing racial divisions in Californians’ housing affordability and security.
This impact was felt devastatingly during the pandemic, when essential workers living in overcrowded housing were exposed to COVID at work and had no choice but to expose their families at home, leading to disproportionate deaths among Black and Latino people.
Neighborhoods in South and Southeast LA, where nearly 20% of homes are overcrowded (defined as more than one person per room) had COVID rates of roughly 14,000 cases per 100,000 people. Neighborhoods on the Westside, where less than 5% of homes are overcrowded, had rates well under 5,000 cases per 100,000 people.1 Death rates were similarly disproportionate -- at a time (January 2021) when the city of Beverly Hills was reporting 21 COVID deaths, and the neighborhood of Brentwood 9, the city of Compton reported 147, and the neighborhood of Westlake 202.2 In all, COVID-19 mortality rates in LA County were roughly twice as high for Black people (31 deaths/100,000 individuals) and Latinos (29/100K) as for whites (15/100K) (from CGLA).
Of the 3,007 counties in the United States, L.A. County ranks last in housing affordability, overcrowding, and unsheltered homelessness. We are not doing enough to preserve and create homes for working class and lower-income people. The affordable housing crisis, rampant speculation, lack of tenant protections and rent control, and affordable housing shortage have gotten so bad that lower-income Black, Latino and AAPI families are being pushed out of their homes and communities at an alarming rate. At the rate we’re going, next generations won’t be able to live in Los Angeles County.
Los Angeles County is legally required to build 341,000 affordable homes by 2030. To truly address our needs, we need more than double that. At the rate we’re going today, we might build 25,000. That’s 7% of what’s needed. That kind of failure will fall hardest on Black and Latino families, who disproportionately face eviction, homelessness and having to choose between rent and food. Our Future LA demands we not let that happen.
In order to create a better housing future, we must make every neighborhood resource-rich so people can live where they want to live and don’t have to leave their community to find opportunity. The Housing Element must also consider the intersection between housing, public health, and environmental justice. The very communities facing the highest rent burden are often the same communities who bear the brunt of the negative impacts brought on by 2 “We Are Forced to Live in These Conditions’: In Los Angeles, Virus Ravages Overcrowded Homes”, NY Times, 1/23/21 1 “When coronavirus invaded their tiny apartment, children desperately tried to protect dad”, LA Times, 1/29/21 3 environmental contamination and exposure to the worst air and soil qualities. For example, in LA County, 75% of active oil wells are located within 2,500 feet of homes, the vast majority of which are occupied by low-income people of color. We must also achieve equitable land use and zoning so that historically exclusionary communities build at greater densities, with value capture, while also ensuring that areas already zoned for density are protected from environmental and spatial racism and displacement pressures. As the region plans for growth, there must be no conversion of wildlife habitat to housing or further development in wildfire hazard areas, as identified by CalFire. We understand that Beverly Hills cares deeply about these issues, and we hope to offer assistance in addressing them.
As it stands right now, the draft housing element will not meet Beverly Hills’ goals around equity and affordability. We submit these comments in the spirit of collaboration in order to partner and provide research, grounded data to help in meeting housing needs. We are interested in having a meeting to discuss these comments more.
Our Future LA Housing Element Comments
1. Protections
A. The housing element should codify a tenant’s right to counsel in an eviction proceeding.
B. The housing element should strengthen its permanent tenant education program to inform tenants of their rights and how to access eviction defense resources.
C. The HE should create and implement a tenant anti-harassment ordinance combined with enforcement resources.
2. Preservation
A. The housing element must do more to prioritize rezoning - with value capture - in high-resource neighborhoods which are transit- and job-rich, including single-family zoned areas. This is necessary to expand affordable housing opportunities while minimizing the impact on existing renters in multifamily-zoned areas.
B. The housing element should exclude parcels containing RSO housing units in the housing element’s site inventory.
C. The housing element should require that no net loss provisions apply to parcels in the site inventory and rezoning program with a monitoring and implementation program.
D. The housing element should institute local programs and funding sources for preservation of existing affordable housing.
4 3. Prioritization of affordable housing
A. The housing element should utilize a value capture mechanism to locally fund and/or incentivize affordable housing.
B. The housing element should prioritize creation of affordable housing on public land.
C. The housing element should streamline affordable housing production.
D. The housing element should include programs for 100% affordable housing zoning overlays, and should ensure that these overlays apply to high-opportunity areas.
E. The housing element should include programs for 100% affordable housing zoning overlays, and should ensure that these overlays apply to high-opportunity areas currently zoned R1.
4. Site Capacity Assessment
A. The housing element should estimate and report both the likelihood of discontinuation and the realistic capacity of inventory sites, both vacant and nonvacant. 5 Comparison of claimed capacity vs. estimated realistic capacity Income
Category RHNA Target
Claimed
Capacity in
Draft HE
NNL Buffer
Estimated
Add'n Dev
Potential in
Draft HE
(20% dev
likelihood)
Recommended
Add'n Dev
Potential
w/20% NNL
Gap in
Add'n Dev
Potential
VLI 1,008 1,008 0% 202 1,210 -1,008
LI 680 680 0% 136 816 -680
MI 602 602 0% 120 722 -602
AMI 814 6,958 755% 1,392 977 415
Total 3,104 9,248 198% 1,850 3,725 -1,875
We estimate that the draft housing element will fall short of the RHNA goal, by 1,875 units of realistic capacity. The City must fairly estimate the likelihood of development for all parcels on the suitable sites inventory.
B. The housing element should report the proportion of sites from the previous housing element’s inventory that were developed during the previous planning period, and HCD-recommended methodologies and data sources should be used in order to conduct a thorough “factors” analysis of sites’ realistic development capacity.
C. The housing element assigns more than 50% of the lower-income RHNA target to nonvacant sites, but should use statistical methods (e.g. surveying a random sample of owners of nonvacant sites) to determine that the sites’ existing uses are likely to be discontinued during the planning period.
D. A buffer of at least 15-30% extra capacity should be included in the housing element site inventory. This capacity buffer is especially necessary in order to accommodate the lower-income RHNA target.
See No Net Loss (NNL) section of 3A.
E. The housing element should provide a quantitative estimate of the likelihood that in-pipeline projects will be completed, based on historical data, and should adjust the number of in-pipeline units counted towards the 6th cycle RHNA target accordingly.
F. The housing element should commit to a mid-cycle review to verify the housing element’s assumptions about development probabilities.
6 5. Affirmatively Furthering Fair Housing
A. The housing element should meaningfully increase the concentration of lower-income households in areas of the city where the existing concentration of lower-income households is low.
B. The housing element should meaningfully reduce the concentration of lower-income households in areas with significant exposure to noise/pollution and commit to reducing/addressing noise and pollution.
C. The housing element should ensure community-serving investment in historically disinvested areas. This includes place-based strategies that create a net gain of affordable housing and stop displacement, prioritize environmental justice, enhance community health and strengthen equitable community leadership in land use planning.
D. The housing element should include a thorough analysis of local patterns in socioeconomic/racial segregation and integration, including patterns of overt racial or ethnic discrimination in the housing and land development market.
E. The housing element should adequately prioritize high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) when selecting sites for lower-income housing opportunities.
F. The housing element should adequately identify funding sources, public resources, and density bonus programs to maximize the likelihood that projects with below-market-rate units are built.
G. The jurisdiction should adequately solicit public feedback and commentary on the housing element in a way that accurately reflects the jurisdiction’s socioeconomic makeup.
6. Forecasts of ADU Development
A. The housing element should use an HCD-recommended safe harbor methodology for forecasting future ADU production.
B. The housing element should provide for mid-cycle adjustments if inventory sites are developed at lower rates, or lesser densities, than the housing element anticipated and if ADU production falls short of projections. Mid-cycle adjustments should automatically implement a by-right density bonus on inventory sites, starting mid-cycle, and be large enough to make up for an ADU shortfall.
C. The housing element should assess the affordability of forecasted ADUs using city-specific data; it instead uses a regional average. 7 ***
We request the opportunity to meet with you and your colleagues to address the concerns raised in this letter. Thank you for your time and consideration.
Sincerely,
Our Future LA
Steering Committee Members
CC: Jason Elliott, Senior Counselor to Governor Gavin Newsom Megan Kirkeby, Deputy Director, Housing Policy Development, HCD Melinda Coy, Land Use and Planning Manager, HCD
Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD Paul McDougall, Housing Policy Development Manager, HCD 8 June 7, 2021
Beverly Hills City Council
Beverly Hills City Hall
455 North Rexford Drive
Beverly Hills, CA 90210
Dear Councilmembers:
Thank you for the opportunity to comment on the process of updating the housing element of Beverly Hills’ general plan. We are writing on behalf of Abundant Housing LA and YIMBY Law regarding Beverly Hills’ 6th Cycle housing element update. Abundant Housing LA is a pro-housing, nonprofit advocacy organization working to help solve Southern California’s housing crisis, and YIMBY Law’s mission is to make housing in California more accessible and affordable through enforcement of state housing law. We support more housing at all levels of affordability and reforms to land use and zoning codes, which are needed in order to make housing more affordable, improve access to jobs and transit, promote greater environmental sustainability, and advance racial and economic equity.
In October 2020, AHLA shared a letter with the City of Beverly Hills, providing guidance on how the City should fulfill both the letter and the spirit of housing element law. We have reviewed the City’s draft Housing Element, and have major concerns about the City of Beverly Hills’ willingness and ability to meet its state-mandated RHNA targets. The staff report and draft site inventory are inconsistent with HCD’s instructions and the requirement that housing element updates affirmatively further fair housing under Assembly Bill 686.
The following issues are of particular concern to us:
1. Planning’s process for selecting sites and assessing their capacity does not accurately estimate parcels’ likelihood of development or net new units if redeveloped.
Therefore, Planning has not identified enough sites where 3,104 homes will realistically be developed by 2029.
An accurate assessment of the site inventory’s housing capacity is necessary in order for the housing element to achieve sufficient housing production. The site capacity estimate should account for the following two factors:
● What is the likelihood that the site will be developed during the planning period? ● If the site were to be developed during the planning period, how many net new units of housing are likely to be built on it?
1 These are the likelihood of development1 and net new units if developed2 factors, as required by HCD guidelines. The portion of the jurisdiction’s RHNA target that a site will realistically accommodate during the planning period is:
(likelihood of development) x (net new units if developed) = realistic capacity.
The City identifies a theoretical zoned capacity of 8,686 housing units on 110 acres of land on major roads, which were rezoned to allow mixed-use development in 2020. However, the City does not estimate the likelihood of development for these parcels. While the City acknowledges that “it is unlikely that a high percentage of the parcels within the MU Overlay would be developed with mixed-use projects during the planning period”3 , the City does not provide an
estimate of how many parcels they do anticipate being redeveloped by 2029, nor does the City share letters from property owners indicating their interest in selling or redeveloping these sites.
Per HCD guidelines, if a jurisdiction assigns more than 50% of its lower-income RHNA to nonvacant sites (as Beverly Hills does), the jurisdiction must make findings supported by “substantial evidence” that the sites’ existing uses are “likely to be discontinued during the planning period.”4 Planning did not follow this instruction, which is a requirement under Assembly Bill 1397.
The City’s site inventory includes many parcels that are very unlikely to be redeveloped under the current zoning and land use rules governing the Mixed-Use Overlay Zone, which, among other things, limits new development to 3-5 stories. To cite one example, the City anticipates a 5-story apartment building with 185 apartments being built at 8383 Wilshire Boulevard.
However, the site is currently occupied by a 10-story office building, currently advertised as “one of the largest and most prestigious properties in the eastern end of Beverly Hills.”5 The City’s site inventory includes many other locations where redevelopment is highly improbable, including a fire station and the Saban Theater:
Address Current use Proposed redevelopment
8383 Wilshire Bl 10-story class-A offices 5-story apartment building (183 units) 8484 Wilshire Bl 10-story class-A offices 5-story apartment building (126 units) 144 S Beverly Dr 7-story class-B offices 4-story apartment building (11 units) 5 https://www.douglasemmett.com/8383-Wilshire
4 Gov’t Code 65583.2(g)(2), also HCD Site Inventory Guidebook, pg. 26-28. “when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50 percent or more of its housing need for lower income households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential development during the period covered by the housing element. An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.” 3 Draft Housing Element, pg. C-4
2 HCD Site Inventory Guidebook, pg. 21
1 HCD Site Inventory Guidebook, pg. 20
2 9150 Wilshire Bl 4-story class-A offices 5-story apartment building (29 units) 8920 Wilshire Bl 6-story medical building 3-story apartment building (42 units) 9700 Wilshire Bl Neiman Marcus flagship
department store
5-story apartment building (70 units)
8440 Wilshire Bl Saban Historic Theater 5-story apartment building (48 units) 154 S Doheny Dr Fire Station No. 3 3-story apartment building (20 units) 8601 Wilshire Bl 11-story apartment building
(37 units)
3-story apartment building (24 units)
Housing production data from the 5th cycle further casts doubt on the City’s implicit assumption that 2,542 homes will be built on underutilized parcels by 2029. At the outset of the 5th cycle, Beverly Hills claimed a theoretical capacity of roughly 1,218 more housing units.6 Through 2020, Beverly Hills permitted 208 housing units, which equates to 237 housing units permitted by the end of the 5th cycle (assuming that the same annual permitting pace continues in 2021).7 This implies that in Beverly Hills, excess zoned capacity has a 19% likelihood of being developed (237 actual units divided by 1,218 theoretical units). By claiming that 2,542 homes will be built on parcels with a zoned capacity of 8,600 units, the City implicitly assumes that parcels have a 35% likelihood of being developed, which recent data shows is overly optimistic.
The City must fairly estimate the likelihood of development for all parcels on the suitable sites inventory. The City of Sacramento’s draft site inventory provided a high-quality, numerical analysis of the likelihood of their sites’ development through a “tiered classification system to classify the non-vacant underutilized sites”.8 Sacramento’s good approach offers a model for Beverly Hills to build on.
Recommendations:
1.1 Provide a quantitative estimate of parcels’ development probabilities, and incorporate this factor into the estimate of sites’ realistic capacity.
1.2 Report the proportion of sites in the previous housing element's inventory that were developed during the planning period.
1.3 Share letters from owners of the site inventory parcels, indicating their interest in selling or redeveloping these properties during the 6th Cycle.
1.4 Remove parcels from the site inventory where redevelopment is unlikely to occur during the 6th Cycle.
1.5 Commit to a mid-cycle review to verify Planning’s assumptions about development probabilities. If it turns out that sites within a tier, or category, were developed at a lower-than-expected rate during the first half of the cycle, then the city 8 Public Review Draft, City of Sacramento Housing Element 2021-2029, p. H-2-15 7 Draft Housing Element, D-2
6 Beverly Hills 5th Cycle Housing Element, 493.
3 should rezone for additional capacity or make other appropriate adjustments for the second half of the planning period.
1.6 If the City lacks enough suitable sites to achieve the RHNA target, rezone additional parcels where redevelopment is likely.
2. The City assumes that 490 housing units that were approved or pending approval during the 5th Cycle will be built during the 6th Cycle, without accounting for the near-certainty that some projects will never be built.
The City counts 490 units in projects that have received “some form of approval”9 towards Beverly Hills’ 6th cycle RHNA target, and assumes that all 490 units will ultimately be built. This is a faulty assumption: not every pending project gets approved, and not every approved project gets built.
While the City may count permitted or entitled units towards its 6th Cycle RHNA goals, it must realistically estimate how many of these units will ultimately be built during the 6th Cycle, based on recent historical data. The City of Los Angeles’ Initial Study counted active planning entitlements, approved planning entitlements with no building permit, and permitted projects that have not yet been completed towards its 6th Cycle RHNA goals, but discounted each category based on the share of proposed units expected to be built, using the City’s historical data.
The City must incorporate a similar estimate into its Inventory Analysis, and must provide more information about the status of each 5th cycle project. Using data from recent projects, the City of Los Angeles estimated that 37% of projects with pending entitlements, 45% of projects with approved entitlements, and 79% of permitted projects, are ultimately completed.10 Beverly Hills, with more restrictive permitting and flat population growth since 1970, should discount the number of pending and approved entitlements counted toward its RHNA target by at least the same factors:
490 units entitled x 45% chance of completion = 221 units Thus, the City might reasonably claim 221 units from pending and entitled projects towards the RHNA target. Alternatively, the City could use local data from recent projects to estimate these percentages. But the City should certainly not count 490 units towards its 6th cycle RHNA goal.
Recommendation:
2.1 Provide a quantitative estimate of the likelihood that in-pipeline projects will be completed, based on historical data, and adjust the number of in-pipeline units counted towards the 6th cycle RHNA target accordingly.
10 Initial Study, City of Los Angeles, pg. 21
9 Draft Housing Element, pg. C-2
4 3. The City does not provide an adequate No Net Loss buffer for the very low income, low income, and moderate income RHNA targets, which disregards HCD’s recommendation that 15-30% capacity be provided at each level of income.
The No Net Loss law established by SB 166 (2017) requires adequate sites to be maintained at all times throughout the planning period to accommodate the remaining RHNA target by each income category.
11 If a jurisdiction approves a development on a parcel listed in the site inventory that will have fewer units (either in total or at a given income level) than the number of units (either in total or at a given income level) anticipated in the site inventory, then the jurisdiction must identify and make available enough sites to accommodate the remaining unmet RHNA target for each income category.12
If additional sites with adequate zoned capacity don’t exist, then the jurisdiction must rezone enough sites to accommodate the remaining unmet RHNA target within 180 days. If the jurisdiction fails to accomplish this rezoning in the required period, then the consequences will include decertification of the housing element and potential state legal action. To ensure that adequate housing capacity at all income levels exists in the housing element through the 6th Cycle, HCD recommends that “the jurisdiction create a buffer in the housing element inventory of at least 15-30% more capacity than required, especially for capacity to accommodate the lower income RHNA.”13
The City’s draft housing element claims to provide capacity for 9,248 housing units, 198% higher than the City’s RHNA goal of 3,104 homes. However, the City did not provide the recommended 15-30% capacity buffer at each income level, giving the City little margin in the event that a site intended for affordable housing is developed with market-rate housing.
Income Category RHNA Target Claimed Capacity Buffer
Very Low Income 1,008 1,008 0%
Low Income 680 680 0%
Moderate Income 602 602 0%
Above Moderate Income 814 6,958 755%
Total 3,104 9,248 198%
The City should ensure that enough housing capacity is created to provide 15-30% capacity buffers at each level of income, to avoid violating the No Net Loss requirement.
Otherwise, the City risks falling afoul of the No Net Loss requirement, making it vulnerable to mid-cycle rezoning, a costly process in terms of time, money, and political will. 13 HCD Site Inventory Guidebook, pg. 22
12 HCD Site Inventory Guidebook, pg. 22
11 HCD No Net Loss Law Memo, pg. 1
5 Recommendation:
3.1 Identify sufficient sites to provide a 15-30% No Net Loss buffer, especially for the VLI, LI, and MI categories, and rezone if there aren’t enough suitable sites to provide this buffer.
4. Planning did not propose adequate reforms to address the major constraints on redevelopment that exist in Beverly Hills.
Building housing in Beverly Hills is difficult, expensive, and time-consuming, with many governmental constraints on homebuilding in place, as the City’s own analysis explains in detail.14 Every new apartment building above four units and all condominium buildings require Planning Commission review, taking up to six months for multifamily project approval.15 Approval is not based on any objective factors, like setbacks or height limits. Instead, the Planning Commission requires conformance with more nebulous factors like “harmonious development of the area”, a process that even the City admits is a moving target.16 In addition, the City subjects every single new proposed building to its architectural review commission, which operates on similarly opaque precedents subject to change at the whims of the Commission members. Even simple determinations, like minimum legal setbacks, are set somewhat arbitrarily, with legal requirements either buried deep in the City’s records or requiring a surveyor to average the front setbacks of every house on the block.17
According to the City, projects usually gain Planning Commission clearance in six months or less, and Architectural Commission clearance in 60 days or less, but the City provides no data to support this. Approvals appear much slower in practice: for example, although the former Robinsons-May department store closed in 2004 and was demolished in 2014, the new apartment-hotel complex planned for the site isn’t scheduled to be finished until 2026, largely due to the difficulty of getting permits.18
Unnecessarily heavy restrictions on minimum housing unit size also act as a major deterrent to housing production. The City requires 600 square feet for a studio apartment, plus a 400 square foot parking space, even though nationwide, the average studio apartment is 500 square feet.
Likewise, the City requires 1,300 square feet plus 2.5 parking spaces (1,000 square feet) for a two bedroom apartment, even though the nationwide average is 1,000 square feet.
Additionally, Beverly Hills has very high on-site parking requirements. Beverly Hills requires two parking spaces for a one-bedroom apartment, three parking spaces for every suburban-style single-family home, and three parking spaces for apartments with three bedrooms or more.19 19 Draft Housing Element, B-16
18 https://urbanize.city/la/post/one-beverly-hills-hilton-9900-wilshire 17 Draft Housing Element, B-9
16 Draft Housing Element, B-23: “The findings used by the Planning Commission to evaluate applications for Development Plan Review entitlements have been in place since the early 1990s and constitute a substantial body of cases to reference in determining the appropriateness of future applications.” In other words, the Planning Commission’s rules on what projects are legal change over time.
15 Draft Housing Element, B-24
14 Draft Housing Element, pgs. B-4 to B-48
6 Mandatory on-site parking requirements drive up the costs of building housing. Providing one parking space per unit drives up the cost of a new home by 12.5%.20 Each above-ground garage space costs $24,000 to build and each underground space costs $34,000.21 Finally, Beverly Hills has an inclusionary zoning policy that requires 10% of all new apartment or condominium units to be set aside for lower-income households. Unlike density bonus programs, which pair set-asides with valuable incentives like additional units, faster permitting, and reduced on-site parking requirements, inclusionary zoning requirements add a significant cost to new development without creating new sources of economic value. In recent years, high inclusionary requirements were introduced in other expensive cities, like San Francisco and Santa Monica, and the result was a major slowdown in the production of both market-rate and deed-restricted affordable units. This may help to explain why Beverly Hills only permitted 14 homes between 2014 and 2019 that are affordable to lower-income households22; after all, 10% of a small number is a very small number.
As a result of this restrictive regulatory regime, Beverly Hills’s housing stock only grew 0.1% between 2015 and 202023 (putting it 9th lowest out of 89 jurisdictions in Los Angeles County), despite extremely strong demand for housing as evidenced by high rents (the median renter household pays $2,079/month, 13th-highest in Los Angeles County)24. Similarly, the ratio of home price to replacement cost is 4.1, one of the highest in the state.25 The City’s population has been stagnant for 50 years, despite being one of the most desirable places on Earth to live.
In 1970, Beverly Hills had 33,416 residents; in 2019, it had 33,792.26 Per Professor Chris Elmendorf of the University of California, Davis and his co-authors of Superintending Local Constraints on Housing Development, the above data suggest that restrictive land use rules are making homebuilding difficult in Beverly Hills, leading to continued shortage and high costs.
Housing element law requires cities to provide an analysis of constraints on housing development, as well as a program to mitigate or remove these constraints. While the Draft Housing Element discusses constraints in detail, including long approval timelines, extremely high approval fees, strict limits on building size, high construction costs, large minimum apartment sizes,27 and a lack of local funding for affordable housing production, the report does not commit to any program to remove policy constraints that deter housing production. The City must commit to specific policy changes and rapid implementation.
Other cities in California have successfully implemented process reforms that streamline housing production. The City of Los Angeles’ Transit Oriented Communities program approves qualifying projects by-right, leading to an average approval time of 6 months for by-right projects. Santa Monica recently made all new residential and mixed-use development project 27 Draft Housing Element, B-10
26 American Community Survey, U.S. Census Bureau
25 Elmendorf et al., Superintending Local Constraints on Housing Development, 2020 24 American Community Survey
23 California Department of Finance, Report E-5, 2020
22 HCD Annual Progress Report
21 http://shoup.bol.ucla.edu/HighCost.pdf
20 https://www.vtpi.org/park-hou.pdf
7 approvals by-right, and has gotten its approval time down to 6 months or less for most new development. But the best ordinance to emulate comes from Sacramento, where the Ministerial Housing Ordinance provides for ministerial approval of 2-150 unit mixed-use and multifamily projects within 60 days, and 151-200 unit mixed-use projects in 90 days.28 This would dramatically streamline the process of building new housing, and reduce the administrative workload on city staff by reducing the number of unnecessary hearings and studies.
We urge Beverly Hills to commit to major constraint removal policies in order to encourage strong housing growth at all levels of income.
Recommendations:
4.1 Establish a fast by-right review process for all new multifamily and mixed-use buildings which meet the zoning law and the General Plan. Sacramento’s Ministerial Housing Ordinance is an excellent model to follow.
4.2 Pre-approve standard ADU, small-scale “missing middle” multifamily and small lot subdivision housing plans, allowing developers to receive a permit quickly if they use a pre-approved design.
4.3 Eliminate on-site parking requirements, instead allowing property owners to decide how much on-site parking is necessary.
4.4 Reduce restrictions on maximum height, floor-area ratio, unit size, and lot coverage.
4.5 Introduce a density bonus program similar to Los Angeles’ Transit Oriented Communities program (with 50-80% density bonuses) to permit additional affordable housing to be built near mass transit.
5. The housing element does not adequately promote new housing opportunities near planned Metro subway stations or in the Mixed-Use Overlay Zone.
While the City proposes to meet the RHNA goal primarily through redevelopment of commercial sites in the Mixed-Use Overlay Zone, the City does not propose or commit to reform of zoning, height limits, parking requirements, minimum unit size, and the project approval process in the Mixed-Use Overlay Zone, which are necessary to make redevelopment feasible. Additionally, although two new Metro subway stations are being built on Wilshire Boulevard, the City’s draft housing element does not adequately accommodate new housing near transit, maintaining R1 zoning (i.e. apartment bans) even within a half-mile of new Metro stations.
Beverly Hills must plan for more housing near the Purple Line. The City has a population that hasn’t grown in 50 years, and is rapidly aging. Its school enrollment is shrinking because even affluent young families can’t afford to purchase a home in Beverly Hills. The much-vaunted Beverly Hills High School may have to close electives due to declining enrollment.29 29 https://beverlyhighlights.com/2015/12/11/low-enrollment-could-affect-electives-administration-says/ 28 https://www.cityofsacramento.org/Community-Development/Planning/Major-Projects/Ministerial-Housing 8 The solution is straightforward: build more housing near Metro, and start by reforming the Mixed-Use Overlay Zone rules. The overlay allows apartment buildings which are only half the height of existing commercial buildings, and requires huge amounts of on-site parking (1,000 square feet of parking for a typical 1,750 square foot 3-bedroom apartment) - a requirement which makes no sense near subway stations and which dramatically drives up the cost of building.30 The overlay also excludes many areas near Metro where development would be viable, such as the entire Golden Triangle and all side streets.
The City should revise the existing mixed-use overlay and adjacent residential areas to allow new, large apartment buildings everywhere within one-half mile of the subway, including the Golden Triangle. A good model ordinance would allow high-rise residential buildings (like on Wilshire Boulevard in Westwood) within one-quarter mile of Metro, and mid-rise buildings within one-half mile of the Metro stations, with density bonuses adapted from the City of Los Angeles’s Transit Oriented Communities program, which offers generous by-right density bonuses to developers who include affordable housing in new developments near mass transit. Transit Oriented Communities has led to the proposal of over 30,000 homes (of which 20% are deed-restricted affordable units) in Los Angeles, built at no cost to the taxpayer.
Zoning map of Beverly Hills with land close to Metro stations overlaid 30 http://www.beverlyhills.org/cbhfiles/storage/files/1108659042674523311/BeverlyHillsMixedUseGuideFeb2021.pdf 9 Proposed Residential/Mixed-Use standards near Metro
Distance from
Purple Line
Height limit Density allowed Parking Density bonus
¼ mile 13 stories31 218 DU/acre
(Los Angeles R5)
None required;
Developer to
decide
50-80% (Transit
Oriented
Communities)
¼ - ½ mile 8 stories32 109 DU/acre
(Los Angeles R4)
None required;
Developer to
decide
50-80% (Transit
Oriented
Communities)
Existing Mixed
Use overlay
5 stories
maximum;
as low as 3
stories
79 DU/acre Required by law:
400 sf/studio
800 sf/1 bedroom
1000 sf/2 bedroom
1200 sf/3 bedroom
1200 sf/4 bedroom
1600 sf/5 bedroom
State minimum
Beverly Hills should also legalize small lot single-family homes and small apartment buildings in R1 zones. Homes in Beverly Hills are generally old: 83% of homes are over 30 years old, and over 70% are over 50 years old.33 Many of these homes are on large lots of 7,500 square feet or more, due to the City’s minimum lot size rules, and even old tract homes sell for over $3 million.34
The City should reform its zoning law to allow the subdivision of normal R1 zones into small lot rowhouses as of right, with appropriately loosened setback and parking requirements. This type of development is common in the Venice and Silver Lake neighborhoods of Los Angeles, as well as in Park Slope (Brooklyn, New York City), Brookline (Boston), and Chestnut Hill (Philadelphia).
Allowing this change would shore up the City’s tax base, population, and school enrollment without causing major changes to the City’s built environment.
Recommendations:
5.1 Rezone parcels in the Mixed-Use Overlay Zone and near the new Purple Line stations, including R1 parcels where single-family detached homes are currently mandated by law.
5.2 Enact a citywide small lot subdivision ordinance modeled on the policy in Los Angeles.
34 E.g., https://www.zillow.com/homedetails/208-S-Maple-Dr-Beverly-Hills-CA-90212/20512402_zpid/ 33 Draft Housing Element, A-17
32 This is the current legal maximum allowed for wood-over-concrete podium construction. 31 This matches the existing heights of the new Waldorf-Astoria and the Camden Medical Arts Building; other common examples of similar size buildings are 8383 Wilshire, 8484 Wilshire, and 9737 Wilshire. 10 6. For all of the above reasons, the City’s intended approach to updating the housing element does not affirmatively further fair housing or reverse existing patterns of residential segregation in Beverly Hills.
AB 686 (2018) requires housing element updates to “affirmatively further fair housing”, which is defined as “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.” The City must address the issue of residential segregation by accommodating the lower-income RHNA targets in a way that conforms with AFFH requirements.
In April 2021, HCD issued an AFFH Guidance Memo, which establishes a number of important principles for promoting fair housing, including:
● A city’s AFFH analysis should reveal “current and historical spatial patterns of subsidized housing within and surrounding the jurisdiction, including emergency shelters, subsidized affordable housing, supportive housing, and usage of housing choice vouchers.”35 ● The distribution of housing-element inventory sites with lower or moderate income capacity must not be skewed toward lower-income neighborhoods. To demonstrate that the site inventory furthers fair housing, the city must calculate the percentage of households at lower, moderate, and above-moderate income levels in each census tract or “block group” in the city, and then do the same for the lower, moderate, and above-moderate-income RHNA units assigned to the tract or block group. The share of lower-income RHNA units assigned to tracts (or block groups) with a higher-than-average share of lower-income households should be less than the current share of lower-income households in those tracts.36
● The housing element must benchmark the citywide distribution of household incomes against the distribution in the county or region, and state. The AFFH program of a predominantly high-income city, like Beverly Hills, must break down barriers that keep lower income and minority households from accessing housing in the city.37 ● “Goals, policies, and actions” to further fair housing must be “aggressively set to overcome ... contributing factors [to fair housing problems, and thus] to meet the ‘meaningful impact’ requirement in statute.”38 The list of actions shall include concrete timeframes for implementation, measurable outcomes, explicit prioritization (“high,” “medium,” or “low”), and “must be created with the intention to have a significant impact, well beyond a continuation of past actions.”39
● “The schedule of actions generally must” (1) enhance the mobility of low-income and minority communities, (2) encourage the development of new affordable housing in high-opportunity areas, (3) protect existing residents from displacement, and (4) invest in disadvantaged places.40
40 AFFH Guidance Memo, p. 54
39 AFFH Guidance Memo pp. 52, 71
38 AFFH Guidance Memo, p. 52
37 AFFH Guidance Memo, pp. 15, 32-34, 77
36 AFFH Guidance Memo, p. 47
35 AFFH Guidance Memo, p. 46
11 Based on the draft housing element, and on the five problems we’ve identified above, we are concerned that Beverly Hills’ housing element update is unlikely to fulfill the state’s AFFH requirement for housing elements.
In our region, housing policy and land use regulations were once used to exclude members of minority groups. Redlining and restrictive covenants, which restricted where Black, Latino, and Asian Americans could live, were once common in Los Angeles County. Discrimination in housing takes other forms today: even after de jure segregation was banned, opponents of neighborhood change in prosperous areas weaponized zoning policy to make apartment construction illegal in much of Los Angeles County, especially in high-income areas. Restrictive zoning has perpetuated historic patterns of segregation and exclusion, and continues to push housing opportunities for lower-income households away from high-cost, high-opportunity cities.
To this day, apartments are banned on 89% of the residentially-zoned land in Beverly Hills, and on 77% of the city’s total land area.41 The median home sale price in Beverly Hills was over $2.6 million in 2018, and 50% of the city’s renters are “rent-burdened” (i.e. they spend more than 30% of their income on rent)42. This denies historically disadvantaged groups housing opportunities near job centers, quality schools, and other public resources, a situation that persists today.
The City is obligated to promote fair housing opportunities and undo patterns of segregation. Beverly Hills should follow HCD’s recommendation that cities distribute lower-income housing opportunities throughout the city, and recommends that cities first identify development potential for lower-income housing in high-opportunity neighborhoods.43 This would mean rezoning more parcels, including residential parcels currently zoned single-family only, to encourage enough housing growth to achieve the RHNA target.
However, the City’s proposed site inventory does not include enough parcels where redevelopment is economically feasible (Problem #1), does not provide a No Net Loss buffer for the below market-rate RHNA targets (Problem #3), and does not commit to the major reforms to zoning, land use, and project approval that are necessary in order to make strong housing development in the Mixed-Use Overlay Zone realistic (Problem #4 and #5). The City proposes no rezoning on any R1-zoned parcels, even those that are near the forthcoming Purple Line stations (Problem #5). All this is a recipe for missing the RHNA target, which means that the housing element is unlikely to advance the goal of socioeconomic integration or greater housing affordability.
The City’s draft housing element does not provide meaningful AFFH analysis, including any evidence that its proposed distribution of lower-income housing opportunities would reduce the concentration of lower-income households in locations with an existing concentration of low43 HCD Site Inventory Guidebook, pg. 3 42 Abundant Housing LA letter to Beverly Hills, October 2020 41 Draft Housing Element, pg. B-7
12 and moderate-income households. HCD’s recent AFFH guidance makes it abundantly clear that this benchmark will be used to help determine AFFH compliance.44 By failing to reform exclusionary zoning and encourage strong overall housing growth in Beverly Hills, the draft housing element will continue to steer housing opportunities for lower-income households away from high-opportunity cities like Beverly Hills, and will fail to achieve Beverly Hills’ lower-income RHNA target. It is very hard to see how such a policy affirmatively furthers fair housing.
Therefore, Beverly Hills must legalize and streamline denser housing development near jobs and transit, including in single-family zoned areas, in order to expand housing opportunities at all levels of income and achieve the RHNA target.
Recommendations:
6.1 Ensure that housing opportunities for lower-income households are not concentrated in neighborhoods with high concentrations of low and moderate income households, or in neighborhoods with significant exposure to noise or air pollution.
6.2 Identify new funding sources and public resources to encourage the production of affordable housing, such as reform of the City’s real estate transfer tax and introduction of congestion pricing.
6.3 Exempt parcels containing rent-restricted and de facto affordable housing units from rezoning.
***
The City of Beverly Hills has a legal obligation to sufficiently plan to meet current and future residents’ housing needs, in a way that guarantees access to opportunity for Californians of all racial and ethnic backgrounds. The issues that we’ve highlighted above suggest that the City is not on a path to fulfilling this legal obligation. We urge you to change course and actively embrace this opportunity to provide a variety of attainable housing options for Beverly Hills’ residents and workers.
Finally, state law imposes penalties on jurisdictions that fail to adopt a compliant 6th Cycle housing element update by October 15, 2021. On that date, noncompliant jurisdictions will forfeit the right to deny residential projects on the basis of local zoning, so long as projects include at least a 20% set-aside for below market-rate units or are 100% moderate-rate projects45.
Noncompliant jurisdictions may also lose the ability to issue building permits, potentially including permits for kitchen and bath renovations. Jurisdictions that want to maintain local control over new development should therefore plan to adopt a compliant housing element update on time.
45 California Government Code 65589.5(d)(5)
44 AFFH Guidance Memo, p. 47
13 In May, HCD declined to certify San Diego’s 6th Cycle housing element, on the grounds that it did not adequately meet the legal requirements to affirmatively further fair housing, and to demonstrate the likelihood of redevelopment of non-vacant sites. If San Diego does not meet these requirements by June 16, 2021, HCD will find the housing element out of compliance.
This suggests that HCD will be bold in enforcing housing element law, and that Beverly Hills risks rejection of its 6th Cycle housing element and decertification if it continues down this path.
We request the opportunity to meet with you and your colleagues to address the concerns raised in this letter. Thank you for your time and consideration.
Sincerely,
Leonora Camner
Executive Director
Abundant Housing LA
Anthony Dedousis
Director of Policy and Research
Abundant Housing LA
Sonja Trauss
Executive Director
YIMBY Law
CC: Jason Elliott, Senior Counselor to Governor Gavin Newsom Assemblymember David Chiu, California State Assembly
Senator Scott Wiener, California State Senate
Megan Kirkeby, Deputy Director, Housing Policy Development, HCD Melinda Coy, Land Use and Planning Manager, HCD
Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD Paul McDougall, Housing Policy Development Manager, HCD 14 9/10/21, 2:26 PM Santa Monica & Beverly Hills, please capture public land for non-compliant housing elements, give land to LA City. https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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Hello,
Santa Monica City in LA County has NOT done enough when it comes to affordable housing on the westside of Los Angeles! The same is true for the city of Beverly Hills who recently approved a housing project that offers 7 parking spots PER UNIT and 0 affordable housing... I mean really??? In this climate crisis????? We need more affordable housing in ALL neighborhoods across LA County, we need to quickly end single-family zoning! Why should these residents living in single-family zoned neighborhoods get the benefits that our cities offer???? It is rumored that Santa Monica's housing department has been ONLY housing White Eastern European Immigrants in the Downtown Santa Monica affordable housing! Illegal housing discrimination & segregation continues through today in many of the local cities!
I'm asking that HCD please capture public land from Santa Monica City and Beverly Hills so that LA City can rezone correctly and build the necessary affordable housing. I believe that we need more public housing or let's call it, community-city-owned Santa Monica & Beverly Hills, please capture public land for non-compliant housing elements, give land to LA City.
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9/10/21, 2:26 PM Santa Monica & Beverly Hills, please capture public land for non-compliant housing elements, give land to LA City. https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/2 affordable & market-rate housing! The working class needs a hand in the housing game, right now the private market is dominating and only competes against itself & that shouldn't be. It should have to compete against permanent affordable & market-rate housing that is community-controlled! The working class IS DYING in SoCal, the same can be said for seniors living on the streets and students sleeping in their cars! We can and should want to do much better than we are currently doing! To HCD, please capture and close the incorrectly zoned Santa Monica airport so that a walkable community that is mostly affordable housing can be developed! Please capture any/all public land from mentioned cities, the delay has gone on long enough! We've been requesting more affordable housing for more than 10 years now, we shouldn't be waiting on local cities to NOT do the right thing! Let's get this right! Thank You for your time regarding the matter!
Best,
Tieira
https://htwws.org/santamonicaairport/
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9/14/21, 10:33 AM Citizen From Encintas
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________________________________
I was wondering if you could advise me on any creative solutions to the housing element that the state placed on the smaller city’s.
Sent from my iPhone
Citizen From Encintas
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HousingElement
Flag for follow up. Start by Friday, April 09, 2021. Due by Friday, April 09, 2021.
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9/14/21, 10:51 AM Feb. 1 6:00 p.m. Housing Element Meeting https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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________________________________
Comment to be read at tonight’s meeting:
These meetings are nothing more than a charade at which the planning commissioners pretend to have an interest in public input, because they are required to reach out and consider public input about how the housing element plan should be met. Hopefully the planning commissioners can do a better acting job than they did at the last Planning Commission meeting of the year, where one planning commissioner was rude and insulting to a public member— labeling his legitimate concern as a “red herring”. That planning commissioner made it very clear that he had no interest in public comments of any kind. It was also pretty clear that he was unfit to serve as a planning commissioner.
The commission has wasted months when it should have made it easier for residents to create ADU’s which would count toward the housing element plan, and should have invited owners of existing commercial buildings—especially those having tenancy problems—an opportunity to convert to mixed use.
But instead, the Planning Commission formulated and recommended the extensive mixed use ordinance for areas where the commissioners do not live, to accommodate more than three times the additional housing which was required. And this was done with complete disregard of residents’ interests, and only to benefit developers, commercial property owners, and real estate interests.
By doing so, the Planning Commission usurped the public’s right to provide input on the housing element plan, and also lost the respect of the majority of residents who know what was done. And standing on their heads to come up with unanimous decisions, do not make the decisions or the Planning Commission any better or worthy of respect.
Darian Bojeaux
Feb. 1 6:00 p.m. Housing Element Meeting
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9/14/21, 10:45 AM RE: Housing Element Update - Community Meeting and Survey https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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Thank u for sending me the link had an opportunity to watch presentaƟon.
SƟll a lot of quesƟons re ADU s and ramificaƟons as to what happens if you fail to idenƟfy enough properƟes to meet the Rhna numbers.
How do u propose to deal with all of the residents that don’t want to see revised zoning and potenƟal growth.
What could happen if you idenƟfy zones , but because of other state ordinances developers can’t comply with those ordinances so can’t accomplish the goal of adding more affordable units.
Do you plan on having discussions with the state as to problems of land use costs. And affordability rents.
Also no menƟon of ciƟes willingness to rezone the foothill properƟes and or working with school district as to rezone their properƟes.
Look forward to more discussions.
murray
310-276-3600
Law Offices of Murray D. Fischer
433 N. Camden Drive, Suite 970
Beverly Hills, CA 90210
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From: HousingElement [mailto:[email protected]] Sent: Wednesday, February 3, 2021 6:17 PM
To: HousingElement
Cc: Teresa Revis; Timmi Tway; Chloe Chen
Subject: Housing Element Update - Community Meeting and Survey Hello,
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9/14/21, 10:45 AM RE: Housing Element Update - Community Meeting and Survey https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/2 You are receiving this email because records show that you are on the interested parƟes list for the 2021 Housing Element Update project.
Thank you to all who were able to aƩend the Housing Element Update community meeƟng this past Monday, and for your contribuƟons to the discussion. If you were unable to aƩend, the meeƟng was recorded and is available to view here. For future reference, links to any recorded public meeƟngs related to the Housing Element Update are available under the "Past Events" secƟon of the Housing Element Update webpage.
Staff has prepared a survey to beƩer understand the public's perspecƟve of housing issues in the City. Please take the Housing Element Update survey, accessed here. Public parƟcipaƟon is an important part of the Housing Element Update process, so please encourage your friends, family, and colleagues to parƟcipate in this survey as well!
Please email [email protected] with any quesƟons or concerns. Thank you in advance for your parƟcipaƟon!
Regards,
The Long Range Planning Team
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9/10/21, 2:26 PM Regarding affordable housing, it’s time to end racist and classist zoning! https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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Hello,
When it comes to affordable housing, it must include both rent and homeownership options for the working class, seniors, students, and others in need of such housing. In the last 10 years rent has increased by over 65%, during that time the number of unhoused residents increased by over 50%, that is shameful! Residents have a right to housing they can afford, it’s time to end racist and classist, REDLINE zoning that has disrupted the lives of many residents. The state can forfeit a local city’s right to govern land in said city if the city fails to meet housing element requirements. I’m looking forward to the affordable housing that Beverly Hills will be creating! Best,
Tieira
https://smex-ctp.trendmicro.com:443/wis/clicktime/v1/query?url=www.HTWWS.org&umid=26052965- bc04-49bf-8b3a-36d94230a96f&auth=de06deaa9b6e816d59511fb0380877fe90266c9b816c476c566dc24dea5d46f409fc60b9f524eca1 Regarding affordable housing, it’s time to end racist and classist zoning! Reply all |
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DiaryofTieira Ryder < >
Mon 4/5, 8:53 PM
HousingElement
Flag for follow up. Start by Monday, April 05, 2021. Due by Monday, April 05, 2021.
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6/18/2021 2100 Parking spots for 300 homes and 0 affordable housing in an approved Beverly Hills housing development. https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/3 CAUTION: External Sender
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https://urbanize.city/la/post/one-beverly-hills-norman-foster-9900-wilshire-approval LA County currently has over 60,000+ unhoused residents and the core workforce is fleeing the state because we can no longer afford to live and work here! Any new developments must include affordable housing AND a project as massive as the one linked above should be required to pay into an affordable housing development fund!
Local cities like Beverly Hills have been upholding illegal segregation as it relates to race & class, 60,000+ unhoused residents in LA County is a testament to BAD HOUSING POLICY! I'm asking that the state please step in and capture public land from local sub-cities in LA County so that walkable communities that include majority affordable housing can be developed. We need community-city-owned market-rate & affordable housing to compete with the private market!
2100 Parking spots for 300 homes and 0 affordable housing in an approved Beverly Hills housing development.
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[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
You replied on 6/18/2021 2:19 PM.
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6/18/2021 2100 Parking spots for 300 homes and 0 affordable housing in an approved Beverly Hills housing development. https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/3 Local cities have had 10 years to do the right thing and most of them have not! NOT ONLY can residents not wait around another 10 years, the Earth cannot wait that long either! We must start creating housing now that our core workforce, our veterans, our students, our seniors, and many others in need can actually afford! Everything does not need to be a drive away so YES workers should be living closer and/or living in the cities that they work in! Again, I'm asking the state to step in for LA County and please help housing advocates capture public land from local cities who are REFUSING to do the right thing! We DO NOT have a housing market in LA but we DO have a lot of corruption going on!
Best,
Tieira
www.HTWWS.org
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6/18/2021 2100 Parking spots for 300 homes and 0 affordable housing in an approved Beverly Hills housing development. https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 3/3 Reply all | Delete Junk |
9/14/21, 10:32 AM Traffic in the street
https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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My name is gytte Taylor
329 n palm dr
99210
I have a house on the corner of 3rd street and n palm dr.
We have been subjected to a traffickers like we never seen before,our street have been made into a freeway cars coming from east la and they use an app on their phone to finde the fastest way to come thrugh Beverly Hills. Not only that we have the toristbusses all day long and into the night. We have a full stop on the corner when the big trucks make a stop my whole hose is shaking and it wakes us up in the night. We have had enough now you must put bombers in the street they do it everywhere I go Brentwood and even in Compton you have to do somthing about this Gytte Taylor
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Traffic in the street
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HousingElement
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September 15, 2021
Beverly Hills City Council
City of Beverly Hills
455 North Rexford Drive
Beverly Hills, CA 90210
Dear Councilmembers:
Thank you for the opportunity to comment on the process of updating the housing element of the City of Beverly Hills’s general plan. We are writing on behalf of Abundant Housing LA and YIMBY Law regarding the 6th Cycle housing element update. Abundant Housing LA is a pro-housing, nonprofit advocacy organization working to help solve Southern California’s housing crisis and YIMBY Law’s mission is to make housing in California more accessible and affordable through enforcement of state housing law.
We support more housing at all levels of affordability and reforms to land use and zoning codes, which are needed in order to make housing more affordable, improve access to jobs and transit, promote greater environmental sustainability, and advance racial and economic equity.
In June 2021, we submitted a comment letter regarding Beverly Hills’ draft housing element update. In the letter, we highlighted significant inconsistencies with state housing element law, including the requirement that housing element updates affirmatively further fair housing (AFFH), as well as inconsistencies with the State Department of Housing and Community Development (HCD)’s instructions regarding housing element design and implementation.
HCD’s recent comment letter on the City’s draft housing element update directly addresses many of the same deficiencies that our letter highlighted, and also states that “revisions will be necessary to comply with State Housing Element Law.”1 We have provided a brief summary below (Exhibit A) illustrating how HCD’s comments on the City’s draft housing element are largely congruent with our previous analysis.
These deficiencies must be addressed in the final version of the housing element update. We urge the City to swiftly adopt a legally compliant housing element that accommodates the City’s RHNA target and provides a variety of attainable housing options for the City’s residents and workers.
Thank you for your time and consideration.
Sincerely,
1 HCD, Review of the City of Beverly Hills’ 6th Cycle (2021-2029) Draft Housing Element Update, 7/30/21, pg. 1 1 Leonora Camner
Executive Director
Abundant Housing LA
Sonja Trauss
Executive Director
YIMBY Law
CC: Megan Kirkeby, Deputy Director, Housing Policy Development, HCD Melinda Coy, Land Use and Planning Manager, HCD
Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD Paul McDougall, Housing Policy Development Manager, HCD 2 “Provide a safe and reliable transportation network that serves all people and respects the environment” STATE OF CALIFORNIA-------CALIFORNIA STATE TRANSPORTATION AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF TRANSPORTATION
DISTRICT 7
100 S. MAIN STREET, MS 16
LOS ANGELES, CA 90012
PHONE (213) 269-1124
FAX (213) 897-1337
TTY 711
www.dot.ca.gov
Making Conservation
a California Way of Life
September 29, 2021
Ms. Timothea Tway, AICP, City Planner
City of Beverly Hills
Community Development Department
455 North Rexford Drive
Beverly Hills, CA 90210
RE: 2021-2029 City of Beverly Hills Housing
Element Update
SCH # 2021090102
Vic. Citywide
GTS # LA-2021-03704-MND
Dear Ms. Tway:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced MND. The City of Beverly Hills 2021-2029 Housing Element Update contains an analysis of the housing needs of all economic segments of the community, including persons with special needs, as well as goals, policies, programs and objectives to address those needs. The location is the entire City of Beverly Hills. Some of the programs contained in the Housing Plan would not cause physical changes in the environment. Such programs include those intended to reduce the cost of housing through techniques such as rent stabilization, the preservation of affordability covenants, or reducing development cost by minimizing fees or streamlining the development review process. Other programs are intended to facilitate the preservation, maintenance and improvement of existing housing. The remaining programs are those that could cause physical change to the environment, such as those that would address existing barriers to the construction of housing and could induce the physical construction of new housing in the City.
The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. Senate Bill 743 (2013) has codified into CEQA law and mandated that CEQA review of transportation impacts of proposed development be modified by using Vehicle Miles Traveled (VMT) as the primary metric in identifying transportation impacts for all future development projects. You may reference the Governor’s Office of Planning and Research (OPR) for more information:
http://opr.ca.gov/ceqa/updates/guidelines/
Ms. Timothea Tway, AICP, City Planner
September 29, 2021
“Provide a safe and reliable transportation network that serves all people and respects the environment” As a reminder, VMT is the standard transportation analysis metric in CEQA for land use projects after July 1, 2020, which is the statewide implementation date.
We encourage the Lead Agency to evaluate the potential of Transportation Demand Management (TDM) strategies and Intelligent Transportation System (ITS) applications in order to better manage the transportation network, as well as transit service and bicycle or pedestrian connectivity improvements. For additional TDM options, please refer to the Federal Highway Administration’s Integrating Demand Management into the Transportation Planning Process: A Desk Reference (Chapter 8). This reference is available online at:
http://www.ops.fhwa.dot.gov/publications/fhwahop12035/fhwahop12035.pdf You can also refer to the 2010 Quantifying Greenhouse Gas Mitigation Measures report by the California Air Pollution Control Officers Association (CAPCOA), which is available online at:
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9- 14-Final.pdf
No specific development project is proposed at this time in connection with adoption of the Housing Element, and no changes are proposed to existing plans, policies or regulations addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. The Housing Element would facilitate the provision of new housing near mass transit and commercial areas consistent with regional transportation plans and Growth Forecast and the City’s existing land use plans and development regulations.
Most of the new housing expected to be built in the city during the 2021-2029 planning period would be located within the Mixed Use Overlay area. The Mixed Use Overlay is located within and adjacent to High Quality Transit Corridors and Transit Priority Areas.
Therefore, we concur that the impacts for the Housing Element would be less than significant.
If you have any questions, please feel free to contact Mr. Alan Lin the project coordinator at (213) 269-1124 and refer to GTS # LA-2021-03704-MND.
Sincerely,
MIYA EDMONSON
IGR/CEQA Branch Chief
email: State Clearinghouse
Exhibit A: Comparison of HCD Comment Letter and AHLA/YIMBY Law and Policy Recommendations Deficiency HCD Comment Letter Appendix AHLA/YIMBY Law
Comment Letter
AHLA/YIMBY Law
Policy Recommendations
Insufficient
AFFH analysis
and policy
reforms to
promote
integrated
neighborhoods
address this requirement. The element,
among other things, must include
outreach, an assessment of fair housing,
identification, and prioritization of
contributing factors to fair housing issues
and goals and actions sufficient to
overcome patterns of segregation and
foster inclusive communities free
from barriers that restrict access to
opportunity.”
complete assessment of fair housing.
Based on the outcomes of that analysis,
the element must add or modify
programs.”
Pages 11-12: “...we are concerned
that Beverly Hills’ housing element
update is unlikely to fulfill the state’s
AFFH requirement for housing
elements.
[...]
Restrictive zoning has perpetuated
historic patterns of segregation and
exclusion, and continues to push
housing opportunities for
lower-income households away from
high-cost, high-opportunity cities.
To this day, apartments are banned
on 89% of the residentially-zoned
land in Beverly Hills, and
on 77% of the city’s total land area.
The median home sale price in
Beverly Hills was over $2.6
million in 2018, and 50% of the city’s
renters are “rent-burdened” (i.e. they
spend more than 30% of their
income on rent). This denies
historically disadvantaged groups
housing opportunities near job
centers, quality schools, and other
public resources, a situation that
persists today.”
exclusionary zoning and encourage
Legalize and streamline denser
housing development near jobs and
transit, including in single-family
zoned areas, in order to expand
housing opportunities at all levels of
income and achieve the RHNA
target. Rezone all parcels near the
Purple Line to allow high-density
housing.
Do more to reduce the concentration
of lower-income households in
neighborhoods with high
concentrations of low- and
moderate-income households.
Identify new funding sources and
public resources to encourage the
production and preservation of
affordable housing, such as a real
estate transfer tax, an introduction of
congestion pricing, creation of a
local density bonus program, and
active abatement of unhealthy
facilities, such as pumping stations,
incinerators, and other polluting
infrastructure.
Exempt parcels containing
rent-restricted and de facto
affordable housing units from
rezoning to prevent displacement of
vulnerable households.
3 strong overall housing growth in
Beverly Hills, the draft housing
element will continue to steer
housing opportunities for
lower-income households away from
high-opportunity cities like Beverly
Hills, and will fail to achieve Beverly
Hills’ lower-income RHNA target. It
is very hard to see how such a
policy affirmatively furthers fair
housing.
Therefore, Beverly Hills must
legalize and streamline denser
housing development near jobs and
transit, including in single-family
zoned areas, in order to expand
housing opportunities at all levels of
income and achieve the RHNA
target.”
Ensure that “no net loss” provisions
apply to parcels in the site inventory
and rezoning program with an
annual and ongoing monitoring and
implementation program.
Prioritize the production of
affordable housing on
publicly-owned land, and offer that
land to nonprofit developers at no
cost as a lawful and bona fide
concession through state density
bonus law.
Create a 100% affordable housing
zoning overlay that encompasses
high-opportunity neighborhoods,
including R1 zoned parcels.
Poor site
suitability and
failure to
analyze
likelihood of
discontinuation
for nonvacant
sites
analysis to demonstrate the potential for
additional development. The methodology
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
theoretical zoned capacity of 8,686
housing units on 110 acres of land
on major roads, which were rezoned
to allow mixed-use development in
2020. However, the City does not
estimate the likelihood of
development for these parcels.
While the City acknowledges
that “it is unlikely that a high
percentage of the parcels within the
MU Overlay would be developed
with mixed-use projects during the
planning period”, the City does not
provide an estimate of how many
parcels they do anticipate being
redeveloped by 2029, nor does the
City share letters from property
Provide a quantitative estimate of
parcels’ development probabilities,
and incorporate this factor into the
estimate of sites’ realistic capacity.
Valid methodologies include the
Survey Method or the Historical
Redevelopment Rate Method.
Report the proportion of sites in the
previous housing element's
inventory that were developed
during the planning period.
Share letters from owners of the site
inventory parcels, indicating their
interest in selling or redeveloping
these properties during the 6th
Cycle. At a minimum, these letters
4 these sites.
In addition, relying on nonvacant sites to
accommodate 50% or more of the housing
needs for lower-income households
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.”
acreage, general plan and zoning but
must also identify the anticipated
affordability levels of all the units on
identified sites. In addition, the parcel
listing includes a column for existing uses.
However, in many cases, the column is
blank and should be completed.”
estimate of the number of units that
can be accommodated on each site in the
inventory, the estimate should rely on
minimum density standards or include
analysis demonstrating how the number of
units for each site was determined. The
estimate of the number of units for each
site must account for land-use controls and
site improvements, typical densities of
existing or approved residential
developments at a similar affordability level
in the City.”
than half an acre. Sites smaller than a
half-acre in size are deemed inadequate to
accommodate housing for lower-income
households unless it is demonstrated that
sites of equivalent size were successfully
owners indicating their interest in
selling or redeveloping these sites.
Per HCD guidelines, if a jurisdiction
assigns more than 50% of its
lower-income RHNA to nonvacant
sites (as Beverly Hills does), the
jurisdiction must make findings
supported by “substantial evidence”
that the sites’ existing uses are
“likely to be discontinued during the
planning period.” Planning did not
follow this instruction, which is a
requirement under Assembly Bill
1397.
homes will be built on parcels with a
zoned capacity of 8,600 units, the
City implicitly assumes that parcels
have a 35% likelihood of being
developed, which recent data shows
is overly optimistic.”
would express interest, but, ideally,
letters would describe plans in
sufficient detail as to allow the City
to quantify such interest into a
likelihood of development.
Remove parcels from the site
inventory where redevelopment is
unlikely to occur during the 6th
Cycle.
If the City lacks enough suitable
sites to achieve the RHNA target,
rezone additional parcels where
redevelopment is likely.
Commit to a mid-cycle review to
verify Planning’s assumptions about
development probabilities and make
adjustments if necessary.
Adjust Planning’s estimate of “net
new units if developed” to reflect
typical FARs that developers have
actually used in Beverly Hills within
the last RHNA cycle.
5 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 to HCD that the site is
adequate to accommodate lower-income
housing.”
Failure to
estimate
realistic
capacity for
residential
development
on
commerciallyzoned sites
Pages 2-3: “The element appears to
assume residential development on sites
zoned for nonresidential uses, but to
support this assumption, the element must
analyze the likelihood of residential in
zoning where 100% nonresidential uses
are allowed. The analysis should be based
on factors such as development trends
including nonresidential, performance
standards requiring residential uses or
other relevant factors such as enhanced
policies and programs.”
includes many parcels that are very
unlikely to be redeveloped under the
current zoning and land use rules
governing the Mixed-Use Overlay
Zone, which, among other things,
limits new development to 3-5
stories. To cite one example, the
City anticipates a 5-story apartment
building with 185 apartments being
built at 8383 Wilshire Boulevard.
However, the site is currently
occupied by a 10-story office
building, currently advertised as ‘one
of the largest and most prestigious
properties in the eastern end of
Beverly Hills.’”
Provide a quantitative estimate of
parcels’ development probabilities,
adjusted for the expected mix of
residential vs. commercial
development, and incorporate this
factor into the estimate of sites’
realistic capacity.
Lack of
concrete
constraint
removal and
adequate
rezoning
program
potential constraints, particularly unit
sizes, setbacks, parking, modulation
requirements and heights and then
appears to conclude these standards are
not constraints because projects have
been built near maximum densities. This
analysis does not demonstrate these land
use controls are not constraints. [...] Based
on the outcomes of the analysis, the
element must include programs to address
identified constraints.”
requires cities to provide an analysis
of constraints on housing
development, as well as a program
to mitigate or remove these
constraints. While the Draft
Housing Element discusses
constraints in detail, including long
approval timelines, extremely
high approval fees, strict limits on
building size, high construction
costs, large minimum apartment
sizes, and a lack of local funding for
Create a high-quality local density
bonus program, which would also
apply to low-density parcels where
apartments are banned today.
Pre-approve standard accessory
dwelling unit (ADU), small-scale
“missing middle” multifamily and
small lot subdivision housing plans,
allowing developers to receive a
permit quickly if they use a
pre-approved design.
6
length of time between receiving approval
for housing development and submittal of
application for building permits.”
are approximately $100,000 per multifamily
unit and concludes the fees are nominal
based on sales prices. However,
regardless of proportion of sales prices,
cumulative fees of $100,000 per unit have
a significant impact on development costs.
The element should include a closer
evaluation of these fees and add programs
to address the constraint as appropriate.”
complete analysis of potential
governmental constraints. Depending upon
the results of that analysis, the City may
need to revise or add programs to address
and remove or mitigate any identified
constraints. In addition, Program 12.1 must
be revised with specific commitment to
complete actions early in the planning
period. While the program commits to
“explore” and “evaluating”, these actions
must be coupled with specific actions to
amend and complete the appropriate
zoning changes. Finally...this program
should be revised to evaluate and revise
parking requirements.”
complete sites inventory and analysis.
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
affordable housing production, the
report does not commit to any
program to remove policy
constraints that deter housing
production. The City must commit to
specific policy changes and rapid
implementation.”
projects usually gain Planning
Commission clearance in six months
or less, and Architectural
Commission clearance in 60 days or
less, but the City provides no data to
support this. Approvals appear
much slower in practice…”
restrictions on minimum housing unit
size also act as a major deterrent to
housing production.”
on-site parking requirements.
Beverly Hills requires two parking
spaces for a one-bedroom
apartment, three parking spaces for
every suburban-style single-family
home, and three parking spaces for
apartments with three bedrooms or
more.”
restrictive regulatory regime, Beverly
Hills’s housing stock only grew 0.1%
between 2015 and 2020 (putting it
9th lowest out of 89 jurisdictions in
Los Angeles County), despite
extremely strong demand for
Speed up the timeline for ministerial
review, and expand ministerial
review to apply to more projects.
Eliminate on-site parking
requirements, instead allowing
property owners to decide how
much on-site parking is necessary.
Reduce restrictions on maximum
height, floor-area ratio, unit size,
setbacks, and lot coverage.
Rezone parcels located near transit,
job centers, schools, and parks in
order to expand the supply of
housing in high- and
highest-resource areas, including
R1 parcels where single-family
detached homes are currently
mandated by law.
Reduce fees on multifamily
residential development.
Enact a citywide small lot
subdivision ordinance modeled on
the policy in Los Angeles.
7 encourage a variety of housing types.” housing as evidenced by high rents...”
Failure to
reform
subjective
development
standards
and architectural commission reviews as
well as decision making standards such as
“...promote harmonious development...”,
“...conformity with good taste....”, and
“...contributes to the image of Beverly Hills
as a place of beauty, spaciousness,
balance, taste, fitness, broad vistas and
high quality.” The City’s processing
approach to these potentially roving
standards is to provide technical
assistance and examples of past projects.
While this approach could be effective in
facilitating approval certainty, the analysis
should also consider impacts on costs,
supply and built density. Also, given the
significant ambiguity implied in these
decision-making standards, the element
should include programs to monitor their
impacts and should consider more fixed
and objective standards.”
Hills is difficult, expensive, and
time-consuming, with many
governmental constraints on
homebuilding in place...Every new
apartment building above four units
and all condominium buildings
require Planning Commission
review, taking up to six months for
multifamily project approval.
Approval is not based on any
objective factors, like setbacks or
height limits. Instead, the Planning
Commission requires conformance
with more nebulous factors like
“harmonious development of the
area”, a process that even the City
admits is a moving target. In
addition, the City subjects every
single new proposed building to its
architectural review commission,
which operates on similarly opaque
precedents subject to change at the
whims of the Commission members.
Even simple determinations, like
minimum legal setbacks, are set
somewhat arbitrarily, with legal
requirements either buried deep in
the City’s records or requiring a
surveyor to average the front
setbacks of every house on the
block.”
Establish objective by-right
standards for development in
Beverly Hills, and establish a fast
by-right review process for all new
multifamily and mixed use buildings
which meet the zoning law and
General Plan.
8 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 1/26 Housing Element Update
Project Engagement
VIEWS
463
PARTICIPANTS
91 RESPONSES
2,135
COMMENTS
193
SUBSCRIBERS
76 * Do you live or work in the City of Beverly Hills?
81 respondents
60%
19%
16%
5%
I live in Beverly Hills
I work in Beverly Hills
I live and work in Beverly Hills
I do not live or work in Beverly Hills
If you live in Beverly Hills, How long have you lived in Beverly Hills? 78 respondents
55%
19%
14%
8%
4%
0%
21+ years
I do not live in Beverly Hills
11-20 years
6-10 years
1-5 years
Less than 1 year
MOVE FILTER BY SEGMENT OPTIONS
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 2/26 If you live in Beverly Hills, select the type of housing unit you reside in:
79 respondents
59%
20%
15%
4%
1%
Single-family home
I do not live in Beverly Hills
Apartment
Condominium
Others
Do you rent or own the home you live in?
73 respondents
68%
27%
4%
Own
Rent
Others
What age range most accurately describes you?
78 respondents
42%
22%
18%
17%
1%
56 to 74 years old
26-39 years old
40 to 55 years old
75 and over
Under 25
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 3/26 What is the primary language spoken in your home?
70 Respondents
If you reside in a single-family house, does the property have a second unit / guest house / ADU?
64 respondents
83% No
17% Yes
Is this second unit / guesthouse / ADU occupied?
62 respondents
79%
13%
6%
2%
N/A
No
Yes, full time
Yes, part time
96%
6%
4%
3%
0%
0%
0%
67
4
3
2
0
0
0
English
Spanish
Other
Farsi
Mandarin
Cantonese
Korean
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 4/26 How satisfied are you with your current housing situation? 74 respondents
68%
22%
7%
4%
I am very satisfied
I am somewhat satisfied
I am dissatisfied
I am somewhat dissatisfied
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 5/26 Please elaborate on your answer, why are you satisfied or dissatisfied? 2 months ago
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Walkability, safety, City services
Affordable housing in BH is non-existent.
No street parking, no parks nearby, few amenities.
The city needs a lot more housing and ADUs
It is hard sharing responsibility for a condo building with other people, especially when the others do not appear to care about the building. I wish I could afford a home.
We lived in the city for over 60 years. We recently were forced to sell our home and lost everything we had due to a real estate fraud against us. We are unable to even rent in the city we called home for so many years. We long to be able to move back in but, even renting is very difficult. We currently live in a place we can afford but, it is not ideal and not for long.
Many places offer low income units with a waitlist that goes on for years -I don't believe this list is even looked at, ever. It is as if it exits to meet some requirement. Need help finding affordable housing.
I work in the vicinity and also I need to be close to medical care services.
I like my living situation because I have a private outdoor area and don't have to worry about neighbors sharing walls and sharing noise. It's already noisy enough with neighbors next door and I like having a separate building and property from others.
I do not support further low income or affordable housing in Beverly Hills Own and live in a three townhouse building.
The house in an original 1928 home, and a nice lot and we have maintained it so it is lovely.
I have everything I need.
Love our home, raised our family here
Cost of rent is high
Semi-private street with phenomenal views!
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 6/26 3 months ago
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I am dissatisfied because the Planning Commission and City Council have undertaken to ruin our neighborhood by unnecessarily rezoning extensive areas near residents to mixed use which will result in tall buildings with inadequate parking. By the way, I did not receive this survey by e-mail. Someone had to forward it to me. And why is this part of the survey separated from the rest? And have you bothered to ask people whether they want to add ADU's?
Love my house. Love the added income of guest unit. Love the neighborhood: Echo Park. close to work, schools and shops
Happy in our house for 39 years. Able to add an elevator for my disabled husband so can age in place I live in a great house, in a beautiful neighborhood and in a great city I would prefer to live in Beverly Hills but can't find affordable housing. I will soon be a senior (65) and as you know, Beverly Hills greatly lacks affordable Senior housing. have lived in this house 61 years it is onRodeo south and probably one of the most convenient areas of the city, I am fearful that although we are not new york it is coming Please so all in your power to try to keep it a commumity
Unpermitted construction going on. Disrespectful neighbor. Too many people coming into town. Town appears sad and grey with all the vacancies and the homelessness on burton way. Seriously considering moving out of town. Breaks my heart.
My late husband and I worked with the architects Craig Elwood and Jerry Lomax on the architectural design and construction this home. It is a mid-century total steel and glass building--totally beautiful tons when we built it, and equally beautiful now. The onlynfunctional change in all these years is the additional a vacuum elevator and some gas generators for electricity.
Location is very convenient for my lifestyle
Right size. Right location.
It's a fine apartment and we're mainly here for the School District. We'd like to buy in the not-so-distant future, so we'll probably move to a condo in the area. (Freestanding home is a bit out of our price range.)
I love my home but dislike the - pre COVID - hour/hour +15 minutes commute to travel 15 miles one way
It has always been our desire for ownership of our own home with backyard.
I am satisfied with the neighborhood and access to parts of the City. 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 7/26 3 months ago
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sold our last house and are in the process of buying another. Renting in the meantime.
We tried for years to get into our neighborhood (south of Wilshire). We finally found our home on a single family block (one block away from us is a multifamily block), an easy walk to the BH business district. We are very satisfied with our block and neighborhood.
Older building. Poor construction, new management company isn't upholding it to previous standards.
My family moved into BH for the schools about 13 years ago. We live in a 2 bedroom apartment. We would have loved to have moved into a larger apartment years ago but rents became outrageous all over the city. So while our apartment meets our needs, it is not ideal. It feels cramped. Owners of building have changed 3 times over the years and each time with less interest in maintaining building.
We have new owners now so we will see how they care for building and apartments. We feel we have little choice but to stay here. Apartment itself is decent. Lots of light. Quiet street.
I would like to live by myself in a rented studio or 1 bedroom apartment, but the prices are too high.
We used to live in a safe, quiet neighborhood. No more. Pre-pandemic, We were invaded by traffic, congestion, chaos, and construction. Traffic spilled over to Charlesville and Gregory until emergency vehicles could no longer navigate the streets. We could not back out of our driveway for fear of speeding cut-through traffic. We have had a stable population for 70 years. Adding 10-30% over a six year period is the choking death of the city. Don't do it. we have big shortage of units in town
We love our house, our neighbors and our neighborhood.
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 8/26 Please rank the top 4 reason(s) you choose to live, or would like to live in Beverly Hills:
60 Respondents
5%
30%
67%
23%
22%
60%
10%
22%
45%
17%
35%
3
18
40
14
13
36
6
13
27
10
21
I do not want to live in Beverly Hills Rank: 1.00
Quality of local school system Rank: 1.78
Safety of neighborhood Rank: 1.90
Quality of home Rank: 2.00
Proximity to jobs Rank: 2.15
Quality / ambiance of neighborhood Rank: 2.22
Proximity to family Rank: 2.67
Cleanliness of streets and surroundings Rank: 2.92
City services and programs Rank: 2.93
Proximity to medical care Rank: 3.10
Proximity to shopping and services Rank: 3.14
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 9/26 How important are the following concerns to you?
Very
important
Somewhat
important
Not
important
Don't
know
Maintaining the character of existing
residential neighborhoods in the City
71%
Very
important
14%
Very
important
13%
Somewhat
important
2%
Not
important
-
Don't
know
Ensuring that children who grow up
in Beverly Hills can afford to live in
Beverly Hills
29%
Very
important
37%
Somewhat
important
33%
Not
important
1%
Don't
know
Ensuring that the housing market in
Beverly Hills provides a diverse range
of housing types, including singlefamily, townhomes, apartments, duplex/triplex, and condominiums to
meet the varied needs of local
residents
49%
Very
important
30%
Somewhat
important
21%
Not
important
-
Don't
know
Establishing special needs housing
for seniors, large families, veterans
and/or persons with disabilities.
31%
Very
important
51%
Somewhat
important
17%
Not
important
2%
Don't
know
Integrating affordable housing
throughout the community to create
mixed-income neighborhoods
27%
Very
important
30%
Somewhat
important
41%
Not
important
2%
Don't
know
Providing shelters and transitional
housing for the homeless, along with
services to help move people into
permanent housing
25%
Very
important
23%
Somewhat
important
42%
Not
important
9%
Don't
know
Encouraging the rehabilitation of
existing housing stock
40%
Very
important
38%
Somewhat
important
21%
Not
important
1%
Don't
know
Establishing programs to help at-risk
homeowners keep their homes
22%
Very
important
48%
Somewhat
important
28%
Not
important
2%
Don't
know
Fair/Equitable housing opportunities
and programs to help maintain and
secure neighborhoods
36%
Very
important
34%
Somewhat
important
21%
Not
important
8%
Don't
know
73 respondents
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 10/26 What type of housing do you think is most needed in the City of Beverly Hills? 61 Respondents
The City may need to consider rezoning areas to accommodate more housing units.
Where do you think these housing units should be accommodated? 59 Respondents
67%
67%
51%
51%
44%
31%
26%
15%
68%
61%
76%
54%
8%
34%
41
41
31
31
27
19
16
9
40
36
45
32
5
20
Condominiums / Townhouses Rank: 2.32
Apartments Rank: 2.37
Single-family houses Rank: 2.55
Senior Housing Rank: 2.97
ADUs/Secondary Units or "Granny Flats" Rank: 3.19
Deed restricted affordable housing Rank: 3.63
Housing for persons with Disabilities Rank: 3.69
Other Rank: 4.33
Rank: 2.00 Allowing residential units in commercial areas where they are currently not allowed
Allowing more density near future subway station areas Rank: 2.08 Allowing more density in mixed-use zones Rank: 2.11
Allowing more density in multi-family zones Rank: 2.38
Other Rank: 2.80
Allowing more density in single family areas Rank: 3.65 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 11/26 Please elaborate on the reasoning for your rankings.
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Need to focus on low-hanging fruit and identify locations where increased density is less likely to run into significant opposition.
Areas with single family homes should be kept that way. It is difficult to find in the city already. Having larger single family homes made smaller (ie property near sunset blvd divided in half or thirds) would be preferable to building apartments, duplexes or condos. Keeping single family homes an option but making it as accessible as possible. Areas that already have multi-family homes like condos or apartments already have residents that know what they are moving into, but it wouldn't be right to change a single family home to a multi-family home because that affects the neighbors in unexpected ways.
BH is already crowded. The city was not originally built nor planned for so many large families (and multiple families living together) to reside here. The infrastructure cannot handle more multi-unit housing. In addition, our police department is too small to handle an influx of more residents. BH was meant to remain quaint, personal, and intimate, not a busy metropolis.
Reluctant to suggest many changes but more multi-unit buildings could be considered - condos or apartments
The market is based on limited and high end housing, we should not subsidize housing thru the the government (if a parent wants to help their kids live in BH that is their business). The city should, if needed pay to keep subsidized house in an other area.
We DO NOT WANT dense housing in BH, near the subways (it is back enough we have a subway, bringing crime in).
Density does not have to be a bad thing. Well-designed density near transit will enhance our community and help reduce the traffic burden.
Multi-family zones already very dense; glut on office space that could be converted to housing. I also prefer home/condo/townhouse ownership to apartments as it slows rate of vacancies/turnover.
There needs to be more development for multifamily homes and affordable options including homes for the elderly
This is nonsense. The city has already rezoned. All the city should have done was rezone existing commercial buildings to mixed use. And they should have made it easier to build ADU's. Instead the planning commission and city council set out to ruin the areas of the city where they don't live. And this horrid conduct of city officials is not going to be forgotten.
We need housing for vulnerable seniors and our work force who cannot afford the median home Priceand rentals. Younger families in mixed use rentals would revitalize our city and potentially decrease traffic impact
Don't want to adversely impact current value of single family residences 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 12/26 3 months ago
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With limited parking one needs to be near the station in order to make use of it.
Multi family is already more dense and this would seem consistent with the area Commercial (not industrial) areas have always created communities or neighborhoods in other cities and that would work well here
Housing near convenient subway transportation "is the future"... and (eventually) as a senior, I'll want to take the subway.
I think there is currently too much construction currently being done on existing property by either expanding up or out or with additional structures on the property and creating water elements, gates or other unnecessary elements. But creating mixed use density around the subway stops, (which never should have been allowed in the city) makes the most sense.
There is a pressing need for greater density in business and commercial areas where workers are needed and where proximity to goods and services can eliminate the need for travel. This does not mean that single family areas need to be changed. There is room for both concepts in this city.
Additional density in single family areas would negatively change the garden character of the city---but additional housing is needed, at more affordable levels The City needs to provide support for the people who work and live there. Building affordable apartments could be a first step. Allowing the apartments to be in a mixed use buildings will help with the economics. Locating them near transportation corridors further helps with affordability (car not needed, for example). Except for the addition of ADU's, our current single family residentially zoned areas would be severely impacted, and I believe detrimental, to allow more density.
Need BH to provide more housing, since LA County in general needs more housing and BH has to participate
Beverly Hills is unique and there is no reason it cannot stay that way, but needs to do its part to create affordable housing where it makes sense to do it.
There is an absolute need to maintain single family residences in the areas already reserved for that in order to maintain the character of the city.
Need to repurpose empty office buildings into residential living spaces.
Pandemic has shown us we no longer need to
work in large commercial office buildings.
We have been fighting hard against legislation like SB 50 for a few years now. It is very frustrating, but it seems that some Sacramento politicians will not be satisfied until every single-family residential block is forced to have apartment buildings on them, which would absolutely destroy the character of our neighborhoods. I do support more housing and affordable housing be built in Beverly Hills, but it should be built along the major thoroughfares. Related to this, California cities should maintain their autonomy over zoning (specifically height, setbacks and design restrictions). The state of California must not be handed this authority to create one-size-fits-all standards. This is horrendous state government overreach.
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 13/26 3 months ago
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Why don't you have "Proximity to transportation" or an "Other" option for the question "Please rank the top 4 reason(s) you choose to live, or would like to live in Beverly Hills:"? It is hands down the #1 reason for where I live. Sad that we just can't think about that. You just won't handle this next round of housing properly if you keep looking at it through the lens of the automobile.
The city could allow taller residential and mixed use buildings in areas not currently zoned for single houses
These are all terrible ideas. The city is in Gridlock already (pre-pandemic). The gross over-developement this represents will destroy the quality of life for everyone in the city. Who's neighborhood are is going to be sacrificed? What neighborhood will have thousands of low-income units? There is only La Cienega with enough outdoor space to accomodate the "slums of Beverly Hills that this will create. The assumption that wealthy people take public transportation is a joke. Lessening parking requirements and increasing height is the destruction of safe, residential neighborhoods and turns the city into an urban jungle of class inequality.
By permitting mixed-use complexes on the major thoroughfares, we can add many more housing units, and create more vibrant commercial stretches - all while protecting single-family blocks for those of us who want to live in single-family houses.
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 14/26 What do you think are the most important housing related issues facing Beverly Hills today?
55 Respondents
65%
20%
5%
35%
35%
29%
22%
25%
15%
24%
24%
7%
36
11
3
19
19
16
12
14
8
13
13
4
Affordability Rank: 1.47
Lack of support for homeowners Rank: 1.64
Other Rank: 1.67
Process for building housing is too burdensome Rank: 2.37 Lack of senior housing Rank: 2.68
Not enough new housing development Rank: 2.69
Lack of deed restricted affordable housing Rank: 2.83
Lack of housing for smaller families Rank: 3.07
Too much new housing development Rank: 3.38
Lack of support for renters Rank: 3.77
Age of housing stock Rank: 3.92
Lack of housing for large families Rank: 5.25
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 15/26 Please elaborate on your answer(s) to the above question. 2 months ago
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People are being priced out of the housing market. Young people who grew up here cannot afford to purchase homes here.
When even smaller properties on the edge of the city border are selling for over $1 million, there is no option for young families to buy single family homes. There is little diversity in people in single family homes because of the cost. Apartments or condos are used while kids are younger to have them in good schools but once children are grown there is nothing keeping families tied to beverly hills. Large numbers of renters drive up the number of children in our schools, but then have no ties to the city once their children are grown. There isn't a way to settle permanently because owning a starter home is out of price reach.
Overly built homes are ruining the original beautiful style of the city, and crowding streets with less greenery/open land and more vehicles per dwelling. It is a very small footprint of a city within a large county, thus will never be able to accommodate a mass influx of people affecting our traffic, city services, and lean streets.
Need more flexibility in new buildings - and less tear-down build up new construction designs. Too many new buildings (after a tear-down) are not compatible with their neighbors buildings and much too large for the lots.
Property owners are not helped as much as tenants. We are TAXED, water hikes, etc, yet renter can "delay and not be evicted" it is grossly unfair to hard working people.
There is a lot of construction going on in BH and we all feel the burden of that. But it is mostly 1 single family house replaced with a larger single family house. Construction should be allowed or incentivized only when additional housing units are added to the supply, eg. if you demolish a single family house, you can only rebuild if you add an ADU on the lot, etc. Or demolishing an existing apartment building only if the new building will have more units (more supply).
There is a glut of high-end housing on Wilshire corridor and more coming in Beverly Hills. Mid-range housing, especially for seniors, is limited. Small family (4-5 people) housing is too expensive.
I'm probably not the only person that doesn't know what deed restricted affordable housing is. It should have been explained.
The city has dragged its feet as it were and has continued to fail to make it easier for residents to create ADU's. Also, all the city officials care about are the developers and commercial property owners--not the residents.
More affordable housing for younger people with good public transportation is important. We need to improve mobility for walking and
Bicycling in the city. Less focus on parking and more on mobility is important.
The plan check process is way to burdensome and the City is anti-development 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 16/26 3 months ago
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Market prices are pricing many people out of market when even high end homes become overly expensive to buy and maintain
We need affordable housing to attaact people who will be engaged and employed in the City It is too costly, takes too much time to get a plan approved and for construction to start No one, except higher income folks, can afford to rent in Beverly Hills, let alone buy.
Affordable units are needed, period
Lack of imagination to create more housing where it makes sense to - mixed use areas (homes above stores on Robertson, Wilshire, etc.)
Housing is expensive in Beverly Hills but it also maintains its value.
The City desperately needs to revise the permit process for single family homes.
The City has a well deserved Reputation for
taking too and Changing Code Requirements once Permits are approved.
And NO...It is not the Architect...It is the fault of
Plan Checkers.This is WRONG!
Architectural restrictions to conform with neighborhoods style Beautiful old homes that hold the character of the City are torn down and replaced by featureless houses that emphasize interior square footage at the expense of civic aesthetic.
I do not have strong feelings about the the above, so I cannot rank them. As I stated earlier, protectingsingle family blocks, while creating new and affordable housing in Beverly Hills along the major thoroughfares is for me the most important housing related issue facing Beverly Hills Building and safety department is very difficult to work with creating delays and extra unnecessary delays and expenses for almost anything
We have had a stable population of 35,000 for 70 years. A building boom will destroy what we know as Beverly Hills and turn it into something else. What we have is great. Overcrowding is deadly in this day and age.
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 17/26 What are the biggest barriers that are keeping you from your ideal housing situation? 2 months ago
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I consider my current housing situation to be pretty ideal.
Price.
Cost of the property and yearly taxes on property. Even if I could save up for the outright cost, the yearly property taxes alone would take up almost half my income.
I live in an ideal housing situation.
I love my home others need to as well.
As a professional worker in BH, even with a good salary it is impossible to afford anything in BH, as well as nearby BH. The commute to where I can afford housing is way to far and long and adds traffic and reduces quality of life and health.
Cost/penalty for moving from large family home to small, one-story home, townhouse with yard.
Cost of housing
price
Capital gains tax due on sale and the city's failure to make it easier to create ADU's. Also the city government which only cares about the interests of developers and commercial property owners and has rezoned to ruin our neighborhoods where they do not live.
None
City's over burdensome plan check and development department.
I am in the ideal situation
Affordability
Affordability
I am living in my ideal housing situation!
affordability and lack of interest by City to address
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 18/26 3 months ago
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Beverly Hills is too expensive; Los Angeles is pricing everyone out in general No barriers at this time.
We are in our ideal housing situtation
City Inexcusable Permit Delays.
Overblown Permit Fees.
We love our house and our neighborhood
Lack of affordable housing options
Prices.
None
We had the ideal housing situation. We are fighting to maintain it. Increase the population by 10-20% without major infrastructure adjustments is a disaster waiting to happen. We do not want to live in a crowded dangerous environment. We don't have it now... we sure will then. 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 19/26 What would you like to see change in Beverly Hills as it relates to Housing in the next 10 years?
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More housing options. New product.
More housing that is AFFORDABLE
Increased density in areas where it makes the most sense and opportunities for people of different incomes to live in Beverly Hills.
Don't try to cram in more people near a subway line and not look at how that affects quality of life for them and existing residents. But that needs to be balanced by a need for more affordable housing options for ownership. I would like to see more options for young families that need outdoor space (than can be used even in a pandemic, unlike our parks). It seems that much of new development is geared towards population density geared towards working professionals and not young families. minimize multi- family dwellings, update our few, tiny parks, complete our school renovations that seem to be taking way too long, double our BHPD officer headcount to better accommodate the number of current residents, restrict overly built homes per property limits.
More design compatible construction - less size on smaller lots in the southern streets - out of control at present. More new condos and apartments to be built and more flexibility in locations allowed.
More fairness toward property owner, less restriction, rent control, and red tape More affordable housing. Not just mega-mansions. Control or tax foreign investment and/or vacant housing as this reduces supply for those of us who actually want to live here and contribute to this community. Allow for mixed use development, particularly along Wilshire and within walking distance of the new subway stations.
Fewer mega-mansions using a disproportionate amount of land, building material, water, for the number of people who occupy them.
More support for green construction. More one-way streets in south-east sector with narrow roads.
Become more affordable
Not the kind of change the PC and the CC want in areas where they don't live.
More apartments and mixes use projects.
Less restrictions on setbacks, landscaping, and size of houses that can be built on lots.
Revitalize the south east part of the city and create new multi use reasonably priced housing. 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 20/26 3 months ago
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More senior housing so we could still serve in (and grow old in) the city we love. Also, if needed, allow affordable housing to be built that exceeds three stories! More affordable housing for young families.
Mixed use by subway stops.
More affordable units, so that pur police, firepersons, and teachers could afford to live here, near their work.
affordable units, both deed restricted and not. I would like to see the majority of these in Mixed Use buildings that line the transportation corridors
Actually creating and building new housing opportunities...not just talking about it for decades. Build and test the waters.
In areas high traffic areas and around transit zones mixed use combination of housing and business.
Expedite the BuildingPermit Process.
There is a Reason why Beverly Hills has a bad reputation for doing construction.
More historic preservation and stricter restrictions on the size of single family homes and new development.
Affordable housing. Homeless outreach
I would be fine with more mixed use along the major thoroughfares. Beverly Hills can do its part to improve the housing situation in California.
Parity with the rest of Los Angeles. We're a decade behind in many categories, and that delay has not helped our way of life in any way.
More affordable apartment units built
Improve the quality of school system that has been declining significantly over the past years. Improve safety to avoid burglaries and other crime
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 21/26 3 months ago
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DO NOT CHANGE THE CHARACTER OF THE CITY. Do not allow the city to become an urban jungle of teeming overpopulation, gridlock, and chaos. Do not create an area dedicated to low and very low income residents who cannot afford our good or services, but will require enormous demand for utilities and city resources. Do not think that we can't ruin the experience of living in Beverly Hills. The subway on Reeves makes it unsafe for nearby residents to leave their homes after dark. We have no control of who is coming in the city, Reeves park will quickly become a homeless shelter. This is in a residential neighborhood. If you destroy the value of living in BH, it will become a city for posers and status seekers. Our families will flee to safer places. Unfortunately, we live too close to Wilshire. It used to be convenient, but now our family has voted not to stay past the opening of the subway. You will have chased us away. This ridiculous housing plan will chase away the real residents who will have lost the traquility and safety of our neighborhoods.
More mixed-use complexes on major thoroughfares such as Wilshire Boulevard, Olympic Boulevard, Robertson Avenue, etc.
Less McMansions on these small lots. Houses are too big on some of those lots. 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 22/26 What would you like to see stay the same as it relates to Housing in the next 10 years in Beverly Hills?
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Character of streets.
Quality, well-maintained housing
The Flats, Hillside, and Trousdale Estates are not very good locations for increased density (with possible exception of the Flats, politics aside).
I like that there are areas of the city for single family homes blocks for multifamily homes. I think it looks better when similar types of housing is grouped on the same block. I would not want to see duplexes or triplexes next to single family homes.
Style of homes.
Approve more mixed use though locations should be restricted. Keep good design essential - not true at present. Not height increase recommended - keep a low level city. Make walking areas essential - more mini-parks.
clean streets
Less government interference in property owner doing what they need to, less rent control, city interference, and red tape
Preserve and maintain the historic houses (single family and apartment houses) and streetscapes of Beverly Hills. It is what gives the community character, a sense of place, and sets it apart from other areas. This translates financially as well.
Tree-lined streets, proximity to schools, parks, and services.
Safety of the neighborhood
I'll leave that to the Planning Commission
Stupid question which is overly broad.
Same
Emergency services response time, concern for parks and recreation. Less speeding on the residential streets by putting in speed humps or bumps.
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 23/26 3 months ago
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The flats remain single family homes
Maintain the wonderful safety with the police and fire departments. Keep school system top grade.
Neighbour character
Stop over building!!
Te areas of elegant gardens and single family residences that enhance the beauty four city.
The garden like quality of the single family areas in the City. As land value escalates, the City is facing tremendous pressure to allow more development. Hoping the City does not buckle to this pressure To not destroy what makes Beverly Hills so special. I think it can be done and they are not mutually exclusive.
Maintaining the existing single family residence areas.
Maintaining the special character of the neighborhoods in the City.
Hopefully the constant threat from Sacramento to our single family blocks will finally have subsided, and our beautiful neighborhoods will look more or less the same.
Density and transportation equity around the two subway stops, better mix of units, easing restrictions.
Keep relatively low density of housing in City without attempting to correct inequality problems that are beyond the responsibility of a small city
We must maintain a population of around 35,000. If we add 6,000 double occupancy units through the housing plan added to the Robinson's project and others. We will have increased our population by 30%. The city can not handle it. It will be the end. We must maintain the status quo. We must fight the State. We cannot take on the pain of bad planning. We cannot open our community to violence. One incident in Westwood in the 1980s destroyed the Village as a destination. We are teetering on the same.
Keep Beverly Hills a realistic size, keep a homogeneous population, and do not let high rise development choke Wilshire to death. Once Wilshire no longer flows. No one can get to Beverly Hills businesses anymore. It happened in 2016 when Waldorf construction increased the drive time from Westwood to City Hall from 5 minutes to 25 minutes. That was the beginning of the end. Retail on Wilshire and Little Santa Monica never recovered.
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 24/26 3 months ago
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For those of us who have invested enormous amounts of money, time and love into our houses, we need to protect and preserve the existing single-family blocks in Beverly Hills. Some people want to live in condos or apartments - and that's great. But some of us want to live in a house on a block with other houses - and not smack up against a large apartment building. We need to protect our homes from the politicians who hate single-family housing and are trying to ruin our blocks.
Nicely kept and SAFE communities
5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 25/26 Are there any additional comments/suggested goals that you would like to provide the City for its 2021 Housing Element update?
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Much of what is being built now seems to want to cram in the largest building the property will allow. I think we need to review how large a property can be, especially when it comes to established areas of smaller homes that then have very large homes being built next door. It can look cramped and out of proportion for the green space around the buildings.
Improved design, mixed use allowed in restricted areas, stricter codes for tear down/build up dwellings, more multi unit buildings but with a residential focus. Improved usage of existing buildings - vacated department stores could change to condos/apartments
Great job, thank you for engaging the community like this! Let's make positive change together. Please advocate for those who may not be able to participate in this process either - the poor, disabled, or politically disenfranchised. It is our job to protect them too.
Green construction, more emphasis on housing for families (not mansions, just reasonable homes/townhouses).
Have more input from immediate area when reallocating schools A much more competently drafted and more comprehensive survey which is not in segments.
No
If you go to mulit use buildings there should be strict limits and rules on they types of signage that can be used so that it does not create light or noise impositions on the residential tenants and does not become an eyesore
Hang in there! Keep up the great work! Could we build a senior citizen/affordable housing skyscraper on Lots 12 & 13? P S. A rooftop pool and jacuzzi is all I would require... and the angle would be right for "no shadows" on single family homes to the north (keep 'em happy). Thank you all!!! Require that developers include in their design proposal affordable housing Development of granny flats as affordable housing
The City should reach out to the locally vested design community (Architects, Designers, Engineers, Contractors, etc.) by hosting either design "charettes" or "competitions" to promote creativity and innovation before considering and zoning ordinance changes none
The City currently allows too much hardscape/concrete in landscaping. 5/19/2021 Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/10021?embeddedreport=False 26/26 Loading more report objects...
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increase racial and economic diversity in housing
Thank you for your work, and thank you for protecting our single-family neighborhoods. I know the mixed-use overlay was controversial, but if it gets Sacramento off our backs, it will be worth it.
The housing plan should we sent to residents via email or mail prior to adoption and a website that allows to correspond to City council be provided during a reasonable comment period We currently have a planned, stable population and housing situation. We like being a safe, suburban neighborhood. Over building and overcrowding exponentially will destroy the quality of life of our neighborhoods.
Please keep our communities clean and safe and aesthetically nice.
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Please provide your contact information if you would like to be added to the Housing Element Update interested parties list.
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9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 1/11 Housing Element Surveys
Project Engagement
VIEWS
447
PARTICIPANTS
80 RESPONSES
1,052
COMMENTS
93 Are you a resident of the City?
77 Respondents
Do you own residential property in the City? (select all that apply) 78 Respondents
MOVE TOGGLE COMMENTS FILTER BY SEGMENT OPTIONS 90%
9%
1%
64%
21%
13%
9%
69
7
1
50
16
10
7
Yes
No
Other
Yes - single-family residential property/properties
No - only resident of the City
Yes - multi-family residential property/properties
No
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 2/11 Have you ever considered building an ADU on your property? Please explain why or why not.
76 Respondents
7 days ago
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We have an additional structure on our property that was here when we bought our home 36 years ago. It has a bathroom -it was originally used as a cabana and we now use it as an office. The only thing we may want to do at some point is to add a second story to the structure, which many of our neighbors have done.
Increased property value.
no space and uninterested
No space
To maximize the land use and value
We did not follow through because we didn't think we would be allowed to build it two stories in order to make sense for usage.
But the permitting was so expensive and difficult we did not do it.
I don’t want a stranger on my property.
Do not want to overcrowd an already overcrowded city, not to even consider the traffic and additional amount of vehicles. This is a special city and if more ADUs are allowed you become less special and have too many more people!!!
No space to build
I can convert guest rooms to rental unit, and also would like to be able to add a unit over the garage. 1) full-time living space for older family member. 2) guest space for family and visiting friends. 50%
26%
24%
38
20
18
Yes
N/A - do not own property in the City
No
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 3/11 4 months ago
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We have not considered an ADU since it is not allowed for multi- family buildings' abutting SFR Single Family Residence properties zones or on other side of alley.
Accessory Dwelling Units are critical to a City’s ability to QUICKLY expand and Diversify / Equify the supply of housing.
California and Los Angeles already have approved ADU programs. i.e.,
https://www.ladbs.org/adu/standard-plan-program/approved-standard-plans Beverly Hills needs to quickly implement a similar program.
We needed an extra bedroom for our son in college when he visited and thought we could lease it out when no longer needed in a year or two.
It would be a nice addition to have for guests
My home is the right size for our family.
Came with property
do not have enough room
I would build it. I think it’s important for the city to allow ones that have already been built and make them legal. If they already have the environmental impact titles and architectural plans but they just didn’t get it permitted it should be allowed and easier to make it a permit Without any penalty.
Yes, if space would permit.
Extra space
i have an adu already. fantastic concept
Rochelle Ginsburg
We would like to have a guesthouse that could be used by family members and friends, and potentially in the future by a caretaker as we get older.
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 4/11 Please rank the following reasons for why you decided to build an ADU or are considering building an ADU. Please provide additional comments if desired. 44 Respondents
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I said not planning
As new owner of a R4 property, I find it that I am subsidizeing my tenants rent. My expenses and mortgage far exceeds the current income received from rent. It is a demoralizing for landlord to hold the title to the property for not only financial benefit of The tenant but be responsible for maintaining, repairing, accept liabilities. so basically our investment dollars and our time is used in service of general public - we should be considered as a philanthropist.
I do not have a first floor bedroom and bathroom, which I need for my limited-mobility mother.
I am very close to Cerdars Sinai hospital. Not only I can help Students, Nurses and Doctors rotating there, it will help me to have some income since I am retired.
Make Beverly Hills catch up with the State and Los Angeles in terms of having an ADU program to help ease our housing supply. Not all Beverly hills needs an ADU program. It is Only needed in the South Side of the city where Multi- Unit housing ( with permit parking) already exists and if still needed, where it won't affect the aestehtics of the City.
Not Needed for SFR single homes since they can develop their properties with current building permit/plans the city has in place.
We found that redeveloping to elevate both our property and the neighborhood overall was met with massive restriction, and cost prohibitive boundaries. The total cost of our development would be nearly $20M USD, which would have resulted in revenue to the city. We could not make the project work with existing regulations and therefore could not proceed.
66%
14%
48%
50%
39%
29
6
21
22
17
Additional space (recreation/bedrooms) Rank: 1.48
Other Rank: 1.83
Additional income Rank: 2.14
Property/resale value Rank: 2.18
Helping provide more housing in the city Rank: 2.24
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 5/11 Do you currently have an ADU or are you in the process of building an ADU on your property?
63 Respondents
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14%
3%
2%
51
9
2
1
No
Yes - the property has an ADU
Yes - currently in process of building an ADU
Other
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 6/11 If you plan to build an ADU, how likely is it that you will build one in the next 5 years? Please explain your response in the comments.
53 Respondents
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see above no space and no interest
see above
If I buy a home, so I can afford the mortgage.
I am waiting for higher density mandated by the state to be approved by BH city council.
City is TOO crowded !!
If I get City approval, I can start getting bids from different contractors and start it, once we get permit.
We own a house south of Olympic and west of Doheny. The current ADU rules are quite restrictive but we'd like to convert our garage if possible.
We will build an ADU only if a similar program is implemented ASAP or in 2021 such as is place in California ( Bay Area + ) and Los Angeles. Currently Beverly Hills does not allow ADU's in Multi-Family ( Apartments-Duplexes,etc,)areas of the City.
It would depend on the existing limitations placed on the project. The neighborhood South of Wilshire is in desperate need of newness. If we could find a way to make the project profitable by either limiting the affordable component, or increasing the total size allotment of the property, we could proceed.
I already have one
already built
We are thinking about it, but know that it would be an expensive thing to do, and are worried that it would be hard to get permits and inspections, and that there would be a lot of red tape. 32%
32%
25%
11%
17
17
13
6
Very Likely
Not Likely
Somewhat Likely
Other
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 7/11 No data to display...
If it is likely that you will build an ADU in the next 5 years, who would you most likely rent this unit to:
46 Respondents
No data to display...
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No data to display...
39%
35%
24%
13%
9%
7%
7%
2%
18
16
11
6
4
3
3
1
Family member at reduced rate (or no rent)
Market rate tenant
N/A - Use as guest house
Other
Family member at market rate
Low income tenant
Employee at reduced rate (or no rent)
Employee at market rate
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 8/11 What types of resources would be the most useful to you in developing an ADU? (Rank the following from most useful to least useful, and provide additional ideas as "other") 46 Respondents
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What is most needed is A genuine effort by planning department to help owners to maximize their use of land with their suggestions , to consider going over and beyond state minimum when it makes sense and when it results in better design. It helps if planing department attitude is changed from limiting development and applying as many constraints they can find in the book to an attitude of expansion and accommodation. Specially on R4 lots.
I assure you Making 10 blocks of Wiltshire mixed use , will not result in more residential units ( high cost of land, high cost of construction will not make the projects financially feasible) but giving higher density or increase in height limit to R4 properties has a significant impact on creating more unit in more distributed over city with more owners being interested rather than one big fat developer on Wiltshire.
Dont allow
Need a careful plan to convert the guest room to a unit. Have to cut down the window and make an entry door from the side of the house.
Adding a unit over the garage need walkway and stairway which would be little challenging, but there is enough land in front of garage to allow that.
Financial Assistance programs and incentives for building an ADU in non-SFR areas. ( Apartment Buildings.Duplexes,etc,)
Not relevant to my situation.
76%
74%
70%
15%
63%
35
34
32
7
29
Pre-approved ADU plans Rank: 1.86
Example floor plans or renderings of different ADU styles Rank: 2.09 ADU Design Guidelines (i.e. explanations of ADU restrictions) Rank: 2.19 Other Rank: 2.71
List of ADU builders Rank: 3.17
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 9/11 Do you have any other comments about ADUs?
3 months ago
3 months ago
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4 months ago
Annoying how I was given a hard time for having one which I used only, years ago. Now when it is convenient for city they say it is fine. Very one side laws. They actually told me to demolish my kitchen and make it into a bedroom. Now that they are legal where do I recoup all that lost money in demo and work. Thanks for nothing.
Give preferential treatment to homeowners that house low-income individuals like LA is thinking of doing.
Planing needs to visit my submitted project and increase the height of the ADU from 16’ because it is built Within the envelop of 33’ by right.
I'm happy that the city will consider adding ADU's to single family housing No
Any other comments or suggestions regarding the Housing Element Update? 3 months ago
3 months ago
3 months ago
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4 months ago
If this is for the homeless people it won't work because they will not be living in adus and we should send the ones sent here back to the state they arrived from. They dumped them on us. unfair.
Need more affordable housing/units. Consider higher density/micro-units. Intergenerational affordable housing to combat loneliness/isolation among different generations. Consider housing for LGBTQIA+ artists and artists of color to infuse BH with a new vibrant and diverse energy that is lacking.
It is unacceptable that after many years of state mandate from state for more units city of BH is still does not have a plan. Even multi unit zoom in 750 feet or less of metro are nit giver TOC Tier1 or 2 or 3 incentives. But giving the incentives to one or 2 big developers on Wiltshire that in a rare case find it feasible to build mix use.
If the City is serious in seeing affordable housing being developed they must get more pro active.
Senior affordable housing would be the most easily attainable and creative solutions should be found.
Getting permits in the past year have been ridiculous
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 10/11 What is your gender?
18 respondents
50%
39%
11%
0%
Male
Female
Prefer not to answer
Others
What is your age?
21 respondents
33%
24%
14%
10%
10%
5%
5%
0%
56-65
46-55
Over 75
26-35
66-75
36-45
Prefer not to answer
Others
9/10/21, 2:49 PM Beverly Hills, CA - Report Creation
https://publicinput.com/Reporting/ReportPreview/11400?embeddedreport=False 11/11 Loading more report objects...
What is your race/ethnicity?
14 Respondents
What is your marital status?
16 respondents
69%
19%
6%
6%
0%
Married or Domestic Partnership
I prefer not to answer
Never Married
Divorced
Others
71%
21%
7%
0%
0%
0%
0%
0%
10
3
1
0
0
0
0
0
White
I prefer not to answer
Other
Black or African-American
Hispanic, Latino, or Spanish
Asian
American Indian or Alaska Native
Native Hawaiian or Other Pacific Islander
Attachment 7
Public Comments Received After
Adoption (10-12-2022)
1/19/22, 3:11 PM Thank You HCD for declining Beverly Hills non-complaint housing element, please support housing advocates request to capture t… https://mail.beverlyhills.org/owa/projection.aspx 1/2
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Thank You HCD for declining the Beverly Hills non-compliant housing element.
Housing advocates are asking for the same response to the Santa Monica noncompliant housing element. We are also asking for your support to capture public land from local cities that have been upholding illegal segregation as it relates to race and class. We have a community plan formed for the incorrectly zoned Santa Monica airport & penmar golf course. The blue-collar working class, students, senior citizens, and many others need access to safe, clean, and affordable housing! Thank You HCD for declining Beverly Hills non-complaint housing element, please support housing advocates request to capture the incorrectly zoned Santa Monica airport along with Penmar golf course.
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Cc: <[email protected]>; [email protected]; Mayor Helpdesk <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Councilmember Bonin <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; housing <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; Black Agenda-SM <[email protected]>; [email protected]; [email protected]; Housing Update <[email protected]>; [email protected]; [email protected]; [email protected]; Chloe Chen; Timmi Tway; Cindy Gordon; Haley Feng <[email protected]>; Leonora <[email protected]>; [email protected]; [email protected] Label: E2K10 731 Day Retention Tag (2 years and 1 day) Expires: 1/20/2024 2:19 PM
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1/19/22, 3:11 PM Thank You HCD for declining Beverly Hills non-complaint housing element, please support housing advocates request to capture t… https://mail.beverlyhills.org/owa/projection.aspx 2/2
Side note; its not lost on me that we need critical investments in corrective behavioral, mental, and rehabilitation healthcare. It's critical that we invest in the well-being of residents, specifically those dealing with disorders/illnesses that could cause them to react violently towards others. I understand that some people are just violent b/c of their ego, but some ppl are violent b/c they are not mentally well. To leave them without the services that they need is a crime against humanity, it's a crime against the community that we claim we all want to keep safe!
Best,
Tieira
www.HTWWS.org/santamonicaairport
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3/15/22, 2:33 PM What Los Angeles County Needs; here's a hint, it doesn't need more "Law enforcement" officers. https://mail.beverlyhills.org/owa/projection.aspx 1/3
Action Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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Hello,
We are two years into a pandemic and we still haven't seen any structural changes in the current systems that are disrupting the lives of thousands upon thousands of residents living in LA County. I'm repeating myself but it's worth saying again, we have a countywide crisis and we need to address the matter as such. The current crisis is in multiple sectors but the primary are housing, land, healthcare and public safety! Let's start with housing, we need to fix the structural process for "affordable" housing.
The "affordable" threshold in cities like Santa Monica has reached $94,000 and I've noticed that most landlords in the area are catering towards residents in the higher end of the affordability which leaves out many blue-collar workers, students, retirees, residents impacted by generational systematic violence, and many many others. We cannot rely solely on the private housing market for housing that residents NEED! Safe, clean, & affordable housing is the right of every single human being on this planet and right now that right is being denied by segregationists hoarding PUBLIC land & other resources necessary to produce such a necessity.
Housing (if it can't be fixed, dismantle and start over!)
1. Establish a rent registry. What is actually available? Why are there empty buildings around the county? Vacant parking lots?
What Los Angeles County Needs; here's a hint, it doesn't need more "Law enforcement" officers.
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3/15/22, 2:33 PM What Los Angeles County Needs; here's a hint, it doesn't need more "Law enforcement" officers. https://mail.beverlyhills.org/owa/projection.aspx 2/3
2. Create a new process for community-owned housing, both market-rate & affordable, both "for rent" and homeownership. This is housing in which affordability needs to be protected and housing that has a secure trust fund to maintain the conditions of living for residents. Give local residents priority! I don't mind helping residents moving from other states but we aren't preventing the homeless crisis that we have in LA County by doing that. Create ONE housing website for LA County so that residents to find safe, clean, and affordable housing that is available immediately. The waitlist shouldn't be longer than 1-2 months. Again, we cannot depend solely on the private market, we cannot depend on the FED. for vouchers that never come/aren't available, aren't accepted by landlords!
3. Establish a process for PSH and revamp or dismantle to broken social services system. The social services building in MacArthur park is one-story and that shouldn't be, it needs to have PSH on top of it and qualified staff working on-site to offer wraparound services to those that need it. What services do some chronically homeless need? Some of them need; family planning services, youth crime & gang prevention programs, mental, behavioral, and rehabilitation healthcare. Attach a UBI to completed treatments and work assignments. PSH shouldn't feel like prison, it needs to feel like a community so people can feed of the GOOD energy that healing brings. ALL NONPROFITS and 'homeless service agencies" need to be an extension of the DPSS, we need to see where ALL MONEY IS BEING SPENT!
4. Establish a better foster program. No child should be sleeping outside in the U.S or any part of the world! It's a crime against humanity to allow it! Public Safety;
Almost every day and night there are LAPD helicopters flying over local neighborhoods and we are not any safer because of it. The heavy pollution and loud noise is a major disruption in the human psyche and many LAPD officers do not live in LA so they do not care that they are causing local residents disruptions! I've personally witnessed LAPD helicopters fly over unhoused residents who are in need of services not LAPD helicopters flying over them because they tried to utilize an abandoned building to shower! Why aren't there more mobile service teams out in the field? Why didn't the YMCA and other orgs like it stay open the entire pandemic to go out and offer mobile services to unhoused residents in need of food? In need of showers? How does LAPD flying helicopters non-stop in our communities make any of us safer? How does LAPD gatekeeping vacant buildings make any of us safer?
Traffic violence; we need communities where cars aren't dominating land space. We need bike and bus only lanes, we need car free streets. Sitting in traffic to breathe in heavy fumes, pedestrians being hit by cars is not normal! Healthcare; do I need to go into the what and why?
--
Best,
Tieira
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3/15/22, 2:33 PM What Los Angeles County Needs; here's a hint, it doesn't need more "Law enforcement" officers. https://mail.beverlyhills.org/owa/projection.aspx 3/3
https://htwws.org/santamonicaairport/ Reply all | Delete Junk | 8/17/22, 11:05 PM Requesting the support of the state Attorney General to help housing advocates capture public land! https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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We must redistribute public land fairly to residents impacted by systematic housing violence. The private market can and always should exist but we shouldn't be forced to rely on it for housing. We need community-owned market-rate & affordable housing that has its own trust fund. There are too many vacant parking lots, land plots, and buildings across LA County. We must build more housing but we must also capture these vacancies or charge a vacancy/land tax. The NIMBYS that bought their homes years ago were able to do so at a price that matched the cost of living, why shouldn't workers now be able to do the same today??
I'm asking again for the state Attorney General Rob Bonta to assist housing advocates in recapturing OUR PUBLIC land so that we may use it for safe, affordable, walkable communities with dense housing. Our community plans include both affordable & market-rate housing, they include both affordable rent & homeownership opportunities. The NIMBYS in cities like West LA do NOT want to do the right thing (see the attached comments that Santa Monica NIMBYS made on NextDoor), we shouldn't be forced to BEG them for LAND that belongs to all of us! Please assist us and force this violent GANG to take their foot off of our necks.
Requesting the support of the state Attorney General to help housing advocates capture public land!
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8/17/22, 11:05 PM Requesting the support of the state Attorney General to help housing advocates capture public land! https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/2 Please see my attached proposal for Penmar golf course & the incorrectly zoned Santa Monica airport. I have some peers that are working to create other walkable communities in other parts of LA as well. Also, we just had another car crash in the Westwood area of Los Angeles. There are way too many cars in that area and we should close off the Downtown Westwood area from cars completely unless it's emergency vehicles. We need rapid transit up Wilshire blvd., wider sidewalks, and a bike lane.
HCD please support us and create a civil peer team in local communities that will oversee these community-owned housing developments and private market developments that are placed in walkable communities that we are imagining. Its a matter of public safety, a matter of safety for Humanity & the Earth itself.
Restorative housing & land justice is owed today, we cannot wait years and years and years to get the housing that we needed over 10 years ago! My plans include priority placement for residents impacted by systematic housing violence; The Natives, the ADOS, the blue-collar working class, etc.
--
Best,
Tieira
https://htwws.org/santamonicaairport/
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8/17/22, 11:06 PM Social Housing Policy for Los Angeles County; Requesting support to implement social housing policy beginning in May https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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Hello Progressive housing advocates,
I'm sending all of you another email regarding social housing policy that I believe should be implemented immediately across LA County and most CA cities. The private housing market can no longer compete against itself and we MUST immediately begin developing community-owned PS, affordable, and market-rate housing! The state housing authority (HCD), local city councils, and the board of supervisors are cc'd on this email and it is my goal to have their support in developing ONE housing TRUST fund account per county where all money for housing & homelessness is overseen by community-led teams that work to develop community-owned housing across the entire county, mostly on publicly owned land.
Social Housing Policy for Los Angeles County; Requesting support to implement social housing policy beginning in May
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8/17/22, 11:06 PM Social Housing Policy for Los Angeles County; Requesting support to implement social housing policy beginning in May https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/2 Thus far, many localities are abusing their positions, there are many violations of the surplus land land act as well. We need progressive community control over housing policy as the blue-collar working class, college students, foster youth, retirees, and many others continue to fall into poverty & homelessness. I'm truly starting to think that the city/state is intentionally helping to create poverty that they then criminliaize by utilizing the militarized policing system.
Again, my goal is to work with city officials to begin quickly implementing social housing policy that will bring unhoused residents inside but also help keep our bluecollar workers, college students, and others housed in permanently affordable housing that is community owned. I invite you all to read my proposal, I'm open to suggestions as well. I'll wait until the end of May but if I don't hear back I will be securing a lawyer/filing a lawsuit to request public land to use on behalf of the people. The state is in violation of basic human rights. The reaction that you are seeing from civilians in local communities is distress, when we begin healing our community most of this distress will go away!
https://htwws.org/social-housing-ca/
--
Best,
Tieira
https://htwws.org/santamonicaairport/
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 HUEMANS life does NOT need to be a drive away. Reply all | Delete Junk |
8/17/22, 11:06 PM Public Hearing General Comment; May, 19, 2022 (Los Angeles Housing Element amendments) https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/3 CAUTION: External Sender
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Hello,
First, Thank You to the LA City planning team for the work that you all are doing. I have a general comment regarding the updates and I want to start by saying that we have a county-wide housing crisis and that we need to address that matter as such. Thus far, LA City is one of the main planning teams in Los Angeles County proving that they want to provide a compliant housing element and that they are actually working to further fair housing. Other cities in Los Angeles county are actually hiring consultants to NOT submit compliant housing elements & they are trying to find ways to NOT build housing! #ILLEGAL
I believe that the LA team will need more support in rezoning from the state, specifically in capturing PUBLIC land from localities abusing their positions like Santa Public Hearing General Comment; May, 19, 2022 (Los Angeles Housing Element amendments)
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8/17/22, 11:06 PM Public Hearing General Comment; May, 19, 2022 (Los Angeles Housing Element amendments) https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/3 Monica City, Beverly Hills, and many others. We have plenty of public land across Los Angeles county that can be used for some of the outlined social housing models like CLTs, co-ops, and community-owned PS, affordable, & market-rate rental housing.
There are many progressive advocates in Los Angeles that are ready to begin implementing a solid social housing policy today. We cannot rely solely on privatelyowned housing, the class that is primarily being displaced (Blue-collar workers & residents with low to no income), need to be able to hold their own cards in the housing game. The "affordable threshold" continues to get higher and higher and it's true that, when we build more housing, rent should go down but even then, it still likely won't go down enough for some blue-collar workers & other residents with limited incomes (disabilities, students, retirees, etc).
I want to remind you what city we are in, we are in Los Angeles where the AirBnb market is BOOMING. There is currently not enough accountability/enforcement within the private housing market which is currently lending MANY of their units for AirBnb/Short term usage (establish a rental registry please). I want to kindly remind you that we are in a city where some ppl can afford to pay $5,000-$10,000 a month for rent but many essential workers, college students, retirees, & others cannot afford to pay that much. In my opinion, for community-owned affordable rental housing, the "affordable rent" price needs to be based on the average of the blue-collar essential worker class. It's not fair to include the high earners in that average. With communityowned housing, we can set an affordable market-rate price that will be cheaper than privately-owned market-rate rental housing but the average we set should be based on that class's total average. Once residents are housed in community-owned housing, let's go ahead and rent stabilize them to avoid displacement. I hope that made sense! Attached, you will find a proposal for mixed-income housing, both rent & homeownership, for the incorrectly zoned Santa Monica airport. I was in the Venice/Santa Monica area today and strangely, the small airplanes leaving the "Santa Monica airport" were only flying low & circling over the Venice community. The small plane owners avoided flying over the Santa Monica residents so not to disturb them by causing noise & fuel pollution. If the state supports LA City, LA City can sue the FAA & SM City to win back over the airport that actually belongs to Venice & Mar Vista residents as much as it does Santa Monica residents. This should be a pretty easy win because 1. Santa Monica's measure LC likely violates the state's "Surplus land Act" and Article 34 isn't relevant because the development isn't for low-income housing but for mixed-income. The incorrectly zoned airport along with penmar golf course will allow for a beautiful community-owned housing development that is surrounded by a large park/rec center/hospital. I've talked to many students at SMC that are in need of housing, we need to deliver on that for them!
Thank You again to the Los Angeles City planning team! I'm looking forward to furthering fair housing & ending the housing crisis. I believe that your team can lead by example because the truth is, we have a state-wide crisis and we need all jurisdictions to do their part to eradicate poverty & to provide stable safe, clean, and affordable Reply all | Delete Junk |
8/17/22, 11:06 PM Public Hearing General Comment; May, 19, 2022 (Los Angeles Housing Element amendments) https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 3/3 housing. "A Right to Housing" already exists under international law (Thank You to the person CC'd on this email for letting me know that)!
I'd recommend establishing a trust fund account for community-owned housing to maintain the quality of the community. I know the NIMBYS & some of our elected officials are going to do everything that they can to drop all of us off in the desert, but we can't allow that! This land belongs to all of us so says the Lord! NIMBYS can keep their SFH's if they want, but they do not own all the land around the SFH. --
Best,
Tieira
https://htwws.org/santamonicaairport/
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 HUEMANS life does NOT need to be a drive away. Reply all | Delete Junk |
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 1/11
HOW THE WEST WAS SAVED
"In the future when it's asked how the west was saved, the story will be that the people of the west saved themselves from ongoing systematic violence"
THE PROGRESSIVE SPACE
When The Santa Monica Airport Closes…
By Bear Writer On 05/30/2021
Update: A Letter from HCD (Department of Housing & Community development) to Santa Monica City’s planning team regarding the upcoming housing element. How The West Was Saved (Tieira R.), Our current direction is not left
or right, but forward towards
progress.
How The West Was Saved is an
open space for discussions on
progressive solutions to the
Western world. Our team is
currently focused on solutions
to affordable housing in the
Greater Los Angeles area. We
are committed to progress, we
are committed to change for
the betterment of everyone in
society.
Follow Us
Petition:
Close the
incorrectly
zoned Santa
Monica
airport and
build housing
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 2/11
along with some other wonderful housing advocates were mentioned as consideration for the comments that HCD gave to Santa Monica regarding a compliant housing element. Thank You HCD for rejecting Santa Monica’s non-compliant housing element, we must hold cities accountable for housing production so that residents can finally have the housing that they are owed!
https://www.smgov.net/
When the incorrectly zoned Santa Monica airport closes, a closure that should be happening in this upcoming housing element cycle (2021-2022), a walkable community that includes
majority affordable housing should be developed. The
location is perfect for a community-owned, walkable/bike-friendly residential neighborhood that includes a variety of housing types for working-class residents on the westside, students, seniors, those living with disabilities, and many others in need of affordable housing.
(Author does not
own the rights to
all of the photos
attached, via
social media. All
rights reserved to
original owners)
Taras Grescoe
@grescoe
“I’ve been living my life wrong.”
—literally everyone in North America.
6:23 AM · Aug 30, 2021
1.4K Reply Share
Read 26 replies
CONTACT HTWWS
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Your email
Subject
Your message (optional)
Submit
Target: To The
CA State
Attorney General
Rob Bonta & To
The California
Housing Authority
(HCD)
SIGN THIS
PETITION
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2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 3/11
To be clear, this community would include both communityowned rental and homeownership options. This pro-housing advocacy effort should be led by a housing advocate that understands the needs of the local community, someone that likely falls within the working class and has the best interest of the local community in mind. When it comes to renting, rent should never exceed 20-30% of a resident’s total income after
taxes. Please keep in mind, the average worker in LA makes about $39,000 a year, this rental housing would be catered to those workers but the community itself would be mixedincome meaning it would also include market-rate units (still cheaper usually than private market-rate housing).
Along with market-rate rentals & homeownership opportunities, business placements would be considered throughout the
community.
Housing proposal for the Santa Monica airport
(Please note that Penmar golf course is also being requested for this project.
The exact community plans would need to be confirmed & this is just a proposed housing plan for the vacant land space. The proposal was created by Tieira R.)
Affordable Homeownership;
1. Affordable, reasonably priced homeownership for working-class residents, priority for long-term residents living or working in the Santa Monica, Venice, & Mar Vista zip codes.
2. Consider a set number of market-rate “for-sale” homes.
3. A variety of home types should be considered for development but especially multi-family housing such as plexes, condos, townhomes, and apartments. Consider co-op ownership.
4. Priority consideration should also go to first-time
homeowners in LA County, my recommendation is residents that have lived/worked at least 10 years in LA County.
5. Priority consideration for historically displaced residents from supposed marginalized communities. Consider a 30-40% “right to return”, “right to housing” for ADOS families (African
descendants of Survivors), & for other residents impacted by systematic housing violence. (Google the history of displaced Black families in Santa Monica, Venice, and/or Manhattan Beach if you need more info.)
6. The millennial generation should also receive a percentage of priority consideration, they currently own a measly 18% of the homes in Los Angeles. “Equity is defined as “the state, quality or ideal of being just, impartial and fair.” The concept of equity is synonymous with fairness and
justice.”
DONATE TO HTWWS
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2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 4/11
7. At no time would a small or large equity firm be granted permission to purchase a home within the community nor would an option be granted to purchase the community as a whole.
8. My recommendation on income qualifications for residents that are first-time buyers is; working-class residents making between $30,000-$130,000.
9. If potential owners require financing, ownership could be subject to credit union or bank approval. Consider public, city-owned bank.
10. The actual cost of homes should match that of the actual average wage of what most working-class residents make. There would likely be re-sell requirements as affordability would be protected by a trust.
Affordable Rental Housing;
1. Community-owned rental housing in mixed-income
developments.
2. The recommended height for apartment buildings is 6-7 stories.
3. Set an “affordable rental rate” based on what the average person from the working class makes. At this moment, most workers in LA make about $39,000 a year. Affordability is usually priced for residents in the $17,000-$70,000 range.
4. Community-owned market-rate rentals to be included, most likely still cheaper than the private market-rate rental housing.
5. No income restrictions once residents are housed.
https://www.nhlp.org/resources/lihtc-admissions-rentsgrievance-procedures/
6. Reserve a portion of the housing for limited to no-income residents. Consider the following; subsidize with HUD and/or new digital voucher program; subsidize low to no income residents with market-rate apartment & business rentals; consider HCID/HACLA westside chapter. Social services for housing, food, and health care should be ONE efficient program.
7. Affordable bachelors, studios, 1, 2, and 3 bedrooms.
8. As with affordable homeownership, the rental units & placements would be for various types of community members but especially keeping in mind our core working class which includes
the essential workforce, students, seniors, veterans, those living with disabilities, etc. etc.
9. Student apartments would be bachelor-sized apartments with smaller fridges and MUST have a kitchen area sink and a small area to put a hot plate (or something similar) so they can cook if needed. (Similar to this https://urbanize.city/la/post/micro-unitapartment-building) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 5/11
More info on the proposed community as a whole;
1. priority consideration for business placements within the community.
2. Open park space, recreation center within the walkable community. Cars can exist on the outside of the community, not within.
3. Consider the possible need to build new schools.
4. Consider a quality westside public transit system especially for college students between SMC and/or UCLA. (cut down on car traffic congestion because students wouldn’t need to drive)
5. College student housing should have its own small park area that has a WIFI and outdoor/indoor workspace for them.
6. Consider large home space for displaced minors within the community aka a “group home” to provide stability.
7. Request consideration for golf course closure(s) as well as other vacant land plots and buildings that have
potential use for affordable housing that is communityowned and suits apartments, condos, townhomes, small and/or tiny homes for locals. Request more interim housing and healthcare sites on the westside for residents with long-term behavioral health needs.
The overall progressive housing goal is to adopt a similar social housing policy for each city in California (all of the U.S) with prohousing community advocates from said cities leading the efforts.
The private market can obviously always exist but it can’t compete against itself, forcing residents to beg for housing that is priced much higher than most can afford. That doesn’t sound like freedom to me!
California’s Housing Crisis
The current CA housing crisis is literally wiping out and pushing the blue-collar working class, students, senior citizens, and many other residents into poverty! In the last 10 years, rent has gone up well over 65% in the city of Los Angeles, in that same amount of time the number of unhoused residents increased by at least 50%! There are currently 60,000+
unhoused residents in LA County and the median income can no longer afford a rent-controlled studio in cities like Santa Monica!
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 6/11
It’s time to return ownership to the residents of Los
Angeles, our right to clean, safe, and affordable housing is being denied!
Side Notes:
Walkable communities are
essential
https://planning.lacity.org/plans-policies/housing-element (LA City Housing Element)
What is a community land trust?
“Starting at about $600 per month for a studio, rents in the Los Angeles Eco-Village are less than half the price of some comparable apartments nearby, and prices aren’t raised unless community members agree to it. That’s possible because the land beneath the co-op is owned by the Beverly/Vermont Community Land Trust, which has pledged to make the land permanently affordable regardless of rising housing prices.”
Renters need to earn $95,000 to afford rent-controlled
studio in Santa Monica, new report says
A household earning the Los Angeles area’s median income cannot afford a rentcontrolled studio in Santa Monica, according to a new report from the city’s Rent Control Board. By U.S. Department of Housing and Urban Development affordability standards, a family would need an income of at least $95,429 to afford a studio, which is about … Continue reading
Santa Monica Daily Press 1
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 7/11
https://laist.com/2021/02/02/community-land-trusts-los-angelesaffordable.php An email from the Santa Monica planning team regarding
use of the airport in this upcoming housing element
“Hi , Thanks for sharing your proposal and thoughts for the airport. Please note that since the airport is slated to close at the end of 2028 and conversion to any other use would take time, the airport is not realistically being considered in the planning for the 6 cycle Housing Element Update
(October 2021 – July 2029). It will most certainly be a consideration in the following housing element cycle
(beyond 2029). However, to get to that point, there will need to be a public process around the future of the airport given the significant community interest and varying views on its future use so I hope you will continue on to be engaged in that separate effort.”
Quotes from an LA Times article regarding the Santa
Monica airport
“The opening of a the 227-acre site on the Westside — in close proximity to jobs, good schools and transit — is a once-in-ageneration opportunity. Housing has to be a part of the equation. “Since the 1980s, Santa Monica has approved the construction of millions of square feet of office space, transforming it into a hub for both the tech and entertainment industries, with a daytime population that swells by more than 150,000 people. But this explosive job growth has not been accompanied by a proportional increase in housing units.” “Santa Monica’s estimated population of 92,478 residents in 2019 was only a blip above what it was in 1970, when 88,289 people called the city home. This growing imbalance between jobs and housing has created a massive influx of daily commuters into Santa Monica (even well-compensated tech employees) who either can’t find or can’t afford housing near these job centers. Meanwhile, population in neighboring jurisdictions has swelled, displacing lower-income residents. The result is more and more commuters crowding the freeways from increasingly distant parts of Southern California.”
The plan to turn Santa Monica Airport into a park is irresponsible.
The Westside needs housing
th
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 1/11
HOW THE WEST WAS SAVED
"In the future when it's asked how the west was saved, the story will be that the people of the west saved themselves from ongoing systematic violence"
THE PROGRESSIVE SPACE
When The Santa Monica Airport Closes…
By Bear Writer On 05/30/2021
Update: A Letter from HCD (Department of Housing & Community development) to Santa Monica City’s planning team regarding the upcoming housing element. How The West Was Saved (Tieira R.), Our current direction is not left
or right, but forward towards
progress.
How The West Was Saved is an
open space for discussions on
progressive solutions to the
Western world. Our team is
currently focused on solutions
to affordable housing in the
Greater Los Angeles area. We
are committed to progress, we
are committed to change for
the betterment of everyone in
society.
Follow Us
Petition:
Close the
incorrectly
zoned Santa
Monica
airport and
build housing
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 2/11
along with some other wonderful housing advocates were mentioned as consideration for the comments that HCD gave to Santa Monica regarding a compliant housing element. Thank You HCD for rejecting Santa Monica’s non-compliant housing element, we must hold cities accountable for housing production so that residents can finally have the housing that they are owed!
https://www.smgov.net/
When the incorrectly zoned Santa Monica airport closes, a closure that should be happening in this upcoming housing element cycle (2021-2022), a walkable community that includes
majority affordable housing should be developed. The
location is perfect for a community-owned, walkable/bike-friendly residential neighborhood that includes a variety of housing types for working-class residents on the westside, students, seniors, those living with disabilities, and many others in need of affordable housing.
(Author does not
own the rights to
all of the photos
attached, via
social media. All
rights reserved to
original owners)
Taras Grescoe
@grescoe
“I’ve been living my life wrong.”
—literally everyone in North America.
6:23 AM · Aug 30, 2021
1.4K Reply Share
Read 26 replies
CONTACT HTWWS
Your name
Your email
Subject
Your message (optional)
Submit
Target: To The
CA State
Attorney General
Rob Bonta & To
The California
Housing Authority
(HCD)
SIGN THIS
PETITION
Welcome back,
Tieira!
Not Tieira? Click here.
Comments
ADD YOUR NA M E
Opt in to email updates
from Tieira Ryder
Action by: Tieira Ryder
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 3/11
To be clear, this community would include both communityowned rental and homeownership options. This pro-housing advocacy effort should be led by a housing advocate that understands the needs of the local community, someone that likely falls within the working class and has the best interest of the local community in mind. When it comes to renting, rent should never exceed 20-30% of a resident’s total income after
taxes. Please keep in mind, the average worker in LA makes about $39,000 a year, this rental housing would be catered to those workers but the community itself would be mixedincome meaning it would also include market-rate units (still cheaper usually than private market-rate housing).
Along with market-rate rentals & homeownership opportunities, business placements would be considered throughout the
community.
Housing proposal for the Santa Monica airport
(Please note that Penmar golf course is also being requested for this project.
The exact community plans would need to be confirmed & this is just a proposed housing plan for the vacant land space. The proposal was created by Tieira R.)
Affordable Homeownership;
1. Affordable, reasonably priced homeownership for working-class residents, priority for long-term residents living or working in the Santa Monica, Venice, & Mar Vista zip codes.
2. Consider a set number of market-rate “for-sale” homes.
3. A variety of home types should be considered for development but especially multi-family housing such as plexes, condos, townhomes, and apartments. Consider co-op ownership.
4. Priority consideration should also go to first-time
homeowners in LA County, my recommendation is residents that have lived/worked at least 10 years in LA County.
5. Priority consideration for historically displaced residents from supposed marginalized communities. Consider a 30-40% “right to return”, “right to housing” for ADOS families (African
descendants of Survivors), & for other residents impacted by systematic housing violence. (Google the history of displaced Black families in Santa Monica, Venice, and/or Manhattan Beach if you need more info.)
6. The millennial generation should also receive a percentage of priority consideration, they currently own a measly 18% of the homes in Los Angeles. “Equity is defined as “the state, quality or ideal of being just, impartial and fair.” The concept of equity is synonymous with fairness and
justice.”
DONATE TO HTWWS
Cashapp Me
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 4/11
7. At no time would a small or large equity firm be granted permission to purchase a home within the community nor would an option be granted to purchase the community as a whole.
8. My recommendation on income qualifications for residents that are first-time buyers is; working-class residents making between $30,000-$130,000.
9. If potential owners require financing, ownership could be subject to credit union or bank approval. Consider public, city-owned bank.
10. The actual cost of homes should match that of the actual average wage of what most working-class residents make. There would likely be re-sell requirements as affordability would be protected by a trust.
Affordable Rental Housing;
1. Community-owned rental housing in mixed-income
developments.
2. The recommended height for apartment buildings is 6-7 stories.
3. Set an “affordable rental rate” based on what the average person from the working class makes. At this moment, most workers in LA make about $39,000 a year. Affordability is usually priced for residents in the $17,000-$70,000 range.
4. Community-owned market-rate rentals to be included, most likely still cheaper than the private market-rate rental housing.
5. No income restrictions once residents are housed.
https://www.nhlp.org/resources/lihtc-admissions-rentsgrievance-procedures/
6. Reserve a portion of the housing for limited to no-income residents. Consider the following; subsidize with HUD and/or new digital voucher program; subsidize low to no income residents with market-rate apartment & business rentals; consider HCID/HACLA westside chapter. Social services for housing, food, and health care should be ONE efficient program.
7. Affordable bachelors, studios, 1, 2, and 3 bedrooms.
8. As with affordable homeownership, the rental units & placements would be for various types of community members but especially keeping in mind our core working class which includes
the essential workforce, students, seniors, veterans, those living with disabilities, etc. etc.
9. Student apartments would be bachelor-sized apartments with smaller fridges and MUST have a kitchen area sink and a small area to put a hot plate (or something similar) so they can cook if needed. (Similar to this https://urbanize.city/la/post/micro-unitapartment-building) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 5/11
More info on the proposed community as a whole;
1. priority consideration for business placements within the community.
2. Open park space, recreation center within the walkable community. Cars can exist on the outside of the community, not within.
3. Consider the possible need to build new schools.
4. Consider a quality westside public transit system especially for college students between SMC and/or UCLA. (cut down on car traffic congestion because students wouldn’t need to drive)
5. College student housing should have its own small park area that has a WIFI and outdoor/indoor workspace for them.
6. Consider large home space for displaced minors within the community aka a “group home” to provide stability.
7. Request consideration for golf course closure(s) as well as other vacant land plots and buildings that have
potential use for affordable housing that is communityowned and suits apartments, condos, townhomes, small and/or tiny homes for locals. Request more interim housing and healthcare sites on the westside for residents with long-term behavioral health needs.
The overall progressive housing goal is to adopt a similar social housing policy for each city in California (all of the U.S) with prohousing community advocates from said cities leading the efforts.
The private market can obviously always exist but it can’t compete against itself, forcing residents to beg for housing that is priced much higher than most can afford. That doesn’t sound like freedom to me!
California’s Housing Crisis
The current CA housing crisis is literally wiping out and pushing the blue-collar working class, students, senior citizens, and many other residents into poverty! In the last 10 years, rent has gone up well over 65% in the city of Los Angeles, in that same amount of time the number of unhoused residents increased by at least 50%! There are currently 60,000+
unhoused residents in LA County and the median income can no longer afford a rent-controlled studio in cities like Santa Monica!
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 6/11
It’s time to return ownership to the residents of Los
Angeles, our right to clean, safe, and affordable housing is being denied!
Side Notes:
Walkable communities are
essential
https://planning.lacity.org/plans-policies/housing-element (LA City Housing Element)
What is a community land trust?
“Starting at about $600 per month for a studio, rents in the Los Angeles Eco-Village are less than half the price of some comparable apartments nearby, and prices aren’t raised unless community members agree to it. That’s possible because the land beneath the co-op is owned by the Beverly/Vermont Community Land Trust, which has pledged to make the land permanently affordable regardless of rising housing prices.”
Renters need to earn $95,000 to afford rent-controlled
studio in Santa Monica, new report says
A household earning the Los Angeles area’s median income cannot afford a rentcontrolled studio in Santa Monica, according to a new report from the city’s Rent Control Board. By U.S. Department of Housing and Urban Development affordability standards, a family would need an income of at least $95,429 to afford a studio, which is about … Continue reading
Santa Monica Daily Press 1
2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 7/11
https://laist.com/2021/02/02/community-land-trusts-los-angelesaffordable.php An email from the Santa Monica planning team regarding
use of the airport in this upcoming housing element
“Hi , Thanks for sharing your proposal and thoughts for the airport. Please note that since the airport is slated to close at the end of 2028 and conversion to any other use would take time, the airport is not realistically being considered in the planning for the 6 cycle Housing Element Update
(October 2021 – July 2029). It will most certainly be a consideration in the following housing element cycle
(beyond 2029). However, to get to that point, there will need to be a public process around the future of the airport given the significant community interest and varying views on its future use so I hope you will continue on to be engaged in that separate effort.”
Quotes from an LA Times article regarding the Santa
Monica airport
“The opening of a the 227-acre site on the Westside — in close proximity to jobs, good schools and transit — is a once-in-ageneration opportunity. Housing has to be a part of the equation. “Since the 1980s, Santa Monica has approved the construction of millions of square feet of office space, transforming it into a hub for both the tech and entertainment industries, with a daytime population that swells by more than 150,000 people. But this explosive job growth has not been accompanied by a proportional increase in housing units.” “Santa Monica’s estimated population of 92,478 residents in 2019 was only a blip above what it was in 1970, when 88,289 people called the city home. This growing imbalance between jobs and housing has created a massive influx of daily commuters into Santa Monica (even well-compensated tech employees) who either can’t find or can’t afford housing near these job centers. Meanwhile, population in neighboring jurisdictions has swelled, displacing lower-income residents. The result is more and more commuters crowding the freeways from increasingly distant parts of Southern California.”
The plan to turn Santa Monica Airport into a park is irresponsible.
The Westside needs housing
th
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 qualified 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 difficulties in fulfilling LAHSA's mission without "fundamental shifts". In her resignation letter, 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-profit 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 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, affordable, & market-rate housing: Social Housing Agencies in each county in CA (ONE SOCIAL HOUSING AGENCY with selected progressive civil peers (community advocates) assigned to offices in each part of the county (likely NSEW & Mid-City, TBD); a group of progressive housing civil peers that implements & develops new community-owned affordable, 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 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 specific projects.
Agency works with HUD to implement new guidelines for affordable homeownership for the blue-collar working class. Agency maintains ONE website/database that has a list of AVAILABLE community-owned affordable, market-rate, and PS rental housing. List of AVAILABLE affordable & market-rate homeownership opportunities.
Affordable 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 traffic 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 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, affordable & market-rate rentals, affordable & 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-profits 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-profits, grassroots teams, etc.).
PSH shouldn’t feel carceral (jail-prison like).
4 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-profit 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-profit 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 find 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 The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-Owned affordable & market-rate Housing; residents are self-sufficient, can pass a criminal background check likely just need assistance securing an affordable or market-rate unit. Will work with residents with a prior eviction. Community-owned affordable & market-rate rental housing that is always affordable. Rent shouldn’t take more than 20-30% of a resident's total income after taxes. Establish an affordable rental market-rate price for the blue-collar working class. The affordable 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 affordable 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-profits, social service teams an extension of the one agency. Social workers, field 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, affordable & market-rate rentals, affordable & 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 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/staff 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 are seeing 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 affordable 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 field. HIGHER pay for workers in these fields! 7 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 The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) 9 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 affordable, 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, affordable, 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 affordable & 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 affordable housing.
10 The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Affordable homeownership- full proposal coming soon, introduce co-ops, CLT’s, and resell requirements. The primary focus is blue-collar workers (affordable 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 audited by 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 CA taxpayers giving in federal dollars to other states using the money for social services (TBD). 11 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 nonprofits to build affordable housing should mean that that housing cannot be sold to a corporation. How and why are some non-profits that received Gov’t/Taxpayer money able to sell affordable buildings after a set number of years to private corporations? Housing would go back to the social agency OR TOPA if the non-profit 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 common is a form of co-ownership of property in which each party owns an undivided interest that passes to his or her heirs at death. The interest is undivided 12 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 tenancy is the joint ownership of property by 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 causing violence 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 affordable housing development by requiring the prioritization of affordable housing when selling or leasing public lands no longer necessary for agency use.
-"Feb. 5, 1866: Thaddeus Stevens Proposes Land Distribution Amendment" https://www.zinnedproject.org/news/tdih/thaddeus-stevens-freedmens-bill/ 13 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 The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -representcal.org, why a constitutional convention is 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 affordable & 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 8/17/22, 11:02 PM Social Housing Authority- Los Angeles https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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Hello HCD,
My name is Tieira Ryder and I'm a Los Angeles based housing advocate that is currently working with other community members that have the hopes of bringing forward a Social Housing Authority. We have too many moving parts of the "housing and no home services" in Los Angeles county and we must create a streamlined housing system that is going to work for all LA residents. Further, we cannot continue to allow the private housing market to be the only system of housing available to the people of LA that have varying housing needs, a private market that has proved very unreliable by the way.
Under the social housing authority, we would have one county-led housing system that operates in each part of LA (NSEW + unincorporated). We would have teams working to develop new social housing for mixed-income residents, new housing developments for PSH, affordable housing homeownership options for LA residents, and rehabs of existing/empty buildings across LA. Further, we would establish ONE housing trust account where all money meant for housing and homeless services would go into. I'm also looking into asking working-class residents to front their loans for ownership developments and asking blue-collar workers to leave a portion of their tax dollars into Social Housing Authority- Los Angeles
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8/17/22, 11:02 PM Social Housing Authority- Los Angeles https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/2 the trust account, to withhold a portion of federal/state taxes until we have the housing that is necessary for all of LA.
The social housing team would work in collaboration with the planning4LA team while overriding all other authorities. Our primary focus would be social housing and public land use. I'm asking that the state step in and override local jurisdictions like Beverly Hills, Santa Monica, & others to give the people access to the PUBLIC land that they need. We were promised affordable housing 10 years ago and we still don't have it.
We've waited long enough and we cannot wait any longer.
Attached, you will find my proposal for social housing. Along with community ownership of rental properties, I'd like the social housing teams to handle CLT's, co-ops, and TOP. Thank You for your attention regarding the matter of housing that was promised generations ago but still hasn't come.
One last story before I go, in 2016 I worked for a tech company in Santa Monica. I was there for 2-3 years or so and during that time I applied for affordable housing in Santa Monica. I sent the information that was needed. Since that time I have been displaced from the Westside and I was laid off from that tech position. Even though I applied for housing at that time, Santa Monica City is now saying that they don't have the information that is needed to get affordable housing under whatever "guidelines" they've created. I worked in the city for a period of time and was not able to secure housing in that time and the city has mysteriously lost the information that I provided to them. How can we continue with a non-functioning housing system like this? Santa Monica brought tech jobs into the city and now refuses to provide housing for workers.
The 10FWY easy during the morning rush is a testament to bad housing policy, it's climate arson against the Earth.
Please let me know a time when you're available to speak. I'm looking forward to hearing from you!
Best,
Tieira
https://htwws.org/santamonicaairport/
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 HUEMANS life does NOT need to be a drive away. Reply all | Delete Junk |
8/17/22, 11:07 PM HCD's Position on Intensity of Land Use & SB 9 https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 1/2 CAUTION: External Sender
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To whom it may concern,
The California Department of Housing & Community Development (HCD) recently published a letter in response to Temple City’s implementation of Senate Bill 9 (SB 9) which has sweeping implications for other jurisdictions in this process. The letter focuses on the city’s ill-founded attempt to reduce the intensity of land use for SB 9 projects without any attempt to concurrently increase intensity elsewhere, as required by the Housing Crisis Act of 2019 (HCA). Any change in intensity of units or size without counterbalancing affects feasibility. HCD has found this violates state law.
Temple City’s SB 9 ordinance—and HCD’s response—also contains a laundry list of don'ts which may affect a jurisdiction’s Housing Element compliance. Specifically, the letter called out Temple City’s use of square footage restrictions, height and story restrictions, courtyard requirements, parking limitations, LEED standards, underground requirements, and even affordability deed restrictions. All told, such requirements for SB 9-related projects which go beyond standards for other projects may be construed as governmental constraints. Jurisdictions will have to identify and justify such constraints in their Housing Elements.
Lastly, the letter stresses that a jurisdiction’s implementation of SB 9 is covered by state laws other than the HCA and State Housing Element Law. This includes, but is not exclusive to, State ADU Law, AFFH, and Anti-Discrimination in Land Use Law.
HCD's Position on Intensity of Land Use & SB 9
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8/17/22, 11:07 PM HCD's Position on Intensity of Land Use & SB 9 https://mail.beverlyhills.org/owa/[email protected]/projection.aspx 2/2 How a city implements SB 9 has wide-reaching considerations. Jurisdictions should be fully aware that SB 9-related projects are not separate nor exempt from their ordinary zoning laws and instead should be included within existing codes. The point of SB 9 is to give homeowners the means to increase the density of their properties. It is not a dead-end in state law.
Attached to this email is HCD's letter to Temple City for reference.
Sincerely,
Davis White
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Davis White he/him
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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
April 29, 2022
Scott Reimers
City of Temple City
Community Development Director
9701 Las Tunas Drive
Temple City, CA 91780
Dear Scott Reimers:
RE: City of Temple City – Housing Crisis Act, Letter of Technical Assistance The purpose of this letter is to provide technical assistance to the City of Temple City (City) regarding the relationship between its recently adopted Senate Bill (SB) 9 implementation ordinance (Ordinance Nos. 21-1058 U, 21-1059) (“Ordinance”) and the Housing Crisis Act of 2019 (Gov. Code, § 66300), among other relevant state housing laws. The California Department of Housing and Community Development (HCD) received a complaint in which concerns were raised that certain provisions of the Ordinance may violate state law. HCD subsequently reviewed the adopted ordinance and other publicly available materials. This letter identifies several concerning provisions of the Ordinance and describes the ways in which these provisions likely violate the Housing Crisis Act of 2019 (HCA).
This letter also identifies provisions of the Ordinance that raise concerns under other housing laws, such as State Housing Element Law (Gov. Code, § 65580 et seq.), Accessory Dwelling Unit (ADU) Law (Gov. Code, § 65852.2), Affirmatively Furthering Fair Housing (AFFH) (Gov. Code, § 8899.50), and Anti-Discrimination in Land Use Law (Gov. Code, § 65008). These additional concerns are addressed briefly in anticipation of the forthcoming 6th Cycle Temple City Housing Element review letter.
Housing Crisis Act of 2019 (Gov. Code, § 66300)
The HCA limits the ability of a local agency to reduce the intensity of land use anywhere where housing is an allowable use without concurrently increasing the intensity of land use elsewhere to compensate for the loss of residential development capacity. The HCA defines reductions in the intensity of land use to include the addition or modification of development standards. Specifically, the law provides the following:
Changing the general plan land use designation, specific plan land use Scott Reimers, Community Development Director