WRITTEN PUBLIC
COMMENTS RECEIVED
July 16, 2026
City Council Members of Beverly Hills
Regarding: Proposed Construction at 232 South Tower Drive Dear Sirs and Madams,
I am a tenant at , Beverly Hills. The proposed
construction of an eight story building with 55 rental units on our quiet street guarantees to unleash complete chaos, not only during construction but once the apartments are rented. There are no buildings on this street higher than 3 levels. How can this small area of Tower Drive accommodate such a mammoth structure and so many new people squeezed into this small space? The new building will violate not only the aesthetics and peaceful atmosphere of this street and the streets nearby, but it will also incur traffic and parking havoc. Currently every single space on this street is occupied by cars every single day, and the new construction plans on having 13 parking places for 55 apartments. Discounting the noise and dust that we will have to endure for months while the construction goes on, the overcrowded conditions that will result forever afterward will crush the quality of life for all who live here.
A more logical location for this building would be Wilshire Blvd or a comparable street that is used to accommodating tall buildings with large populations. Why would the city planners of Beverly Hills permit this violation to occur? I will have to move and I imagine other tenants on the street will have to move as well. I understand there is a housing shortage, but it might be more helpful if rents were lowered and more people could afford to live in the places that already exist.
Please reconsider your decision. The new building will completely destroy the livability of this neighborhood.
Yours truly and the soon to be displaced,
Candace Moore
,
From: Marcela B.
To: City Clerk
Subject: 232 S Tower Dr. Beverly Hills 90211 / No to building proposal Date: Tuesday, July 21, 2026 6:22:50 PM
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Hello City Clerk,
I hope you are well. I have been a resident at , Beverly Hills , 90211 for a little over 23 years, I would like to express my opinion on the 232 S Tower Dr., Beverly Hills 90211 proposal that will tear down this building only to construct an 8 story , 55 unit & 13 parking replacement. Please know residents are already stressed with lack of parking. The 8 story building is not a proper fit for this neighborhood, this monster of a building will block the love we get from the sun and will change this beautiful community not for the better. I ask that you please say no to this project. Please save Tower Drive.
Best Regards,
Marcela Beltran
90211
Increased traffic on a heavily foot-trafficked residential corridor.
Years of construction immediately adjacent to existing residents.
Loss of privacy for neighboring apartments due to the building’s height.
Reduced natural light and increased shadowing on nearby properties.
Increased noise, both during construction and after occupancy.
Additional strain on local infrastructure and public services.
I understand that this proposal is being considered under California’s Builder’s Remedy provisions, and I recognize that the City’s options may be limited. However, I respectfully ask that every effort be made to ensure that any approved project is compatible with the surrounding neighborhood and does not create unnecessary burdens for existing residents.
If a project of this size ultimately moves forward, I strongly encourage the City to require substantially more on-site parking so that the surrounding neighborhood is not forced to absorb the overflow. Residents should not lose access to already limited parking because a development was approved without adequately accommodating its own tenants.
For the past decade, Tower Drive has been my home. It is a beautiful, walkable neighborhood that balances residential living with thoughtful development. I hope that same balance can be maintained as Beverly Hills continues to grow.
Thank you for your time, your service, and your consideration of my comments.
Respectfully,
Sarah Croce
Resident,
Beverly Hills, CA
Although I am unable to attend the meeting in person, I would greatly appreciate the opportunity to participate remotely if that is still possible. If remote participation can still be arranged, I would be grateful if you could provide the necessary instructions. If it is too late to participate remotely, I respectfully request that this letter be entered into the public record and considered by the City Council during tonight’s hearing.
I would also appreciate being kept informed of the Council’s decision and of any future hearings, proceedings, or opportunities for public participation related to this project.
Thank you for your time, your service to our community, and your careful consideration of my concerns.
Respectfully,
Sonia Dollero
Beverly Hills, CA 90211
From: Lexie Newell
To: Maribel Mena
Cc: City Clerk
Subject: Re: comment on 232 tower dr proposal
Date: Thursday, July 23, 2026 4:46:59 PM
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extremely disappointed in the decision and the fact that reps who did have a say in this still voted it through but then complained to the papers. do better. i would love to know where you plan to put over 55 cars when already there isn’t any parking. and it’s even worse on street sweeping days! seriously do so much better you let us down tremendously. i will be moving as soon as construction begins you have ruined the neighborhood.
Sent from my iPhone
> On Jul 21, 2026, at 11:59 AM, Maribel Mena <[email protected]> wrote:
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> Confirming receipt.
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> Maribel Mena
> Assistant City Clerk
> City of Beverly Hills | City Clerk’s Office
> Office (310) 285-2400 | Direct (310) 285-1094
>
>
> -----Original Message-----
> From: Lexie Newell
> Sent: Monday, July 20, 2026 7:58 PM
> To: City Clerk <[email protected]>
> Subject: comment on 232 tower dr proposal
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> I am a resident on tower dr. A massive apartment complex such as this is not only a threat to our neighborhood but also our daily lives. none of us want this. we have been through much construction already in the last few years on wilshire, gregory way, and nearby and every time we the residents suffer. trash gets left behind everywhere, my vehicle has been blocked in by construction workers who have laughed at me when i asked them to please move, and all of our parking spots disappear. there is already almost no street parking for residents i cannot imagine how much worse it will be with construction and with 55+ new cars on the street. 13 new spaces is not nearly enough. i cannot fathom why such a massive building is even allowed in the middle of our sweet quiet street. it would be an eyesore and stick out over the entire neighborhood. it also would be a significant safety hazard to have so much activity on our small street. there are many young children who play at the park nearby and outside on the street i worry for their safety with more construction. don’t destroy our street we just want peace and quiet. >
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From: Anita Prasad
To: City Clerk
Subject: Fwd: Opposed to Development Project at 232 S Tower Drive Date: Tuesday, July 21, 2026 7:07:40 AM
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Hi,
I am writing to notify you that I am against the development of a 8 story building at 232 S Tower Drive.
A building this size is too big for a small street as Tower Drive and will only create more traffic, noise pollution and parking issues for the tenants who are already struggling with these issues.
Please feel free to contact me if you need additional information.
Thank you,
Anita Prasad
e
633 West Fifth Street
64th Floor
Los Angeles, CA 90071
213.557.7222
www.rpnllp.com
Dave Rand
213.557.7224
[email protected]
July 20, 2026
VIA EMAIL
City of Beverly Hills
Honorable Mayor and City Council
[email protected]
Re: 232 Tower Drive – Development Plan Review (PL2400129) Response to Appeal
Dear Honorable Mayor and City Council:
Our firm represents Beachside Suites LLC and Oak Investment Company LLC (the “Applicant”) in connection with the proposed multi-family residential development project at 232 Tower Drive (“Site”) in the City of Beverly Hills (“City”), assigned case number PL2400129 (the “Project”). The City’s Planning Commission approved the Project on October 23, 2025, with a unanimous vote (4-0, with Chair Wolfe recused). Kenneth Dusick, on behalf of Carthay Beverly Hills Neighbors (“Appellant”), has filed an appeal of the Planning Commission’s approval of the Project (“Appeal”), and the City Council will consider the Appeal at its meeting on July 21, 2026. Kenneth Dusick has also submitted supplemental arguments through public comment in support of the Appeal. This letter responds to each of the points in the Appeal and responds to Mr. Dusick’s written public comments.
A. Background
The Applicant submitted an SB 330 preliminary application for the Project on October 5, 2023.
As of the date of the Preliminary Application submittal, the City of Beverly Hills lacked a substantially compliant Housing Element, and therefore the Builder’s Remedy was available for qualifying affordable housing projects. The Project is a qualifying affordable housing project because it designates 20 percent of the total number of units (or 11 units) for lower-income households.
B. Grounds for Appeal
1. “The Project Poses Specific Adverse Impacts”
One of the limited grounds for denying a Builder’s Remedy project under the Housing Accountability Act (“HAA”) (Gov. Code Section 65589.5) is a finding, based upon a preponderance of the evidence in the record, that the project “would have a specific, adverse impact upon the public health or City of Bevery Hills
July 20, 2026
safety, and there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact.”1 “Specific, adverse impact” is defined as:
a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.2
For purposes of this provision, the Project application was deemed complete on the date the preliminary application was submitted – October 5, 2023.3 Finally, the legislature has clearly stated an intent that “the conditions that would have a specific, adverse impact upon the public health and safety … arise infrequently.”4 (a) Traffic and Pedestrian Safety
The Appellant claims the Project will have a specific, adverse impact on health and safety because it will “generate significant vehicular traffic on residential streets unable to handle its generated volume,” and will pose risks to child safety because there is a park and multiple schools in the vicinity, including along Gregory Way where parents pick up their children from the park. Appellant further argues that these impacts must be considered cumulatively with the impacts of similar projects pending before the City.
Response: Appellant does not identify any objective, written public health or safety standard demonstrating that increased vehicle traffic near a park or a school creates “significant, quantifiable, direct, and unavoidable impacts” to health and safety that cannot be mitigated. Furthermore, considering unsubstantiated impacts cumulatively does not result in a specific, adverse impact.
Based on the City Council staff report: “The project is expected to generate 14 net new vehicle trips (3 inbound trips and 11 outbound trips) during the weekday AM peak hour. During the weekday PM peak hour, the project is expected to generate 14 net new vehicle trips (8 inbound trips and 6 outbound trips).”
As further described in the City Council staff report, construction-related closures of the public right-of-way surrounding the Site would require City approval of a detailed Construction Management Plan to minimize associated impacts. The Applicant will submit a detailed Construction Management Plan, as required.
Finally, the draft resolution, based on staff’s analysis of all the evidence in the record, concludes that “the Project will not create any significantly adverse traffic impacts, traffic safety hazards, pedestrian-vehicles conflicts, or pedestrian safety hazard.” 1 Government Code Section 65589.5(d)(2).
2 Id.
3 Government Code Section 65589.5(h)(5).
4 Government Code Section 65589.5(a)(3).
City of Bevery Hills
July 20, 2026
(b) Parking Deficiency
The Appellant claims the Project will have a specific, adverse impact on health and safety because it does not provide sufficient on-site parking spaces and will therefore result in “spillover parking onto adjacent residential streets, creating circulation conflicts, emergency vehicle access concerns, and quality-of-life degradation for existing residents.” Response: Again, Appellant does not identify any objective, written public health or safety standard demonstrating that allegedly insufficient on-site parking creates “significant, quantifiable, direct, and unavoidable impacts” to health and safety that cannot be mitigated. Appellants stated “conflicts” and “concerns” do not amount to quantifiable evidence of impacts based on written standards.
Notably, even if this Project were not a Builder’s Remedy project, the City could not impose any minimum parking space requirements on the Project under State law (AB 2097) as the site is located within one-half mile of a major transit stop, namely, the Wilshire/La Cienega D Line Metro Station at the intersection of Wilshire Boulevard and North La Cienega Boulevard.5 This is confirmed in the City Council staff report.
(c) Emergency Access
The Appellant claims the Project will have a specific, adverse impact on health and safety because inadequate parking and increased density will “create … risks” to emergency response times, and the Project’s reduced setbacks will “create obstructions to the visibility of emergency vehicle operators.”
Response: Again, Appellant does not identify any objective, written public health or safety standard demonstrating that the Project’s parking, density, or setbacks will create “significant, quantifiable, direct, and unavoidable impacts” to health and safety that cannot be mitigated. The Appellant’s claims about impacts on emergency access are purely speculative and completely unsupported. The draft resolution, based on staff’s analysis of all the evidence in the record, concludes that “The Project is also not anticipated to have adverse impacts to … emergency access, either during construction or once the Project is in operation.”
(d) Aesthetics
The Appellant claims the Project will have a specific, adverse impact on health and safety because it “will result in the irreputable degradation of established community aesthetics, privacy, lighting, and air circulation.”
Response: Again, Appellant does not identify any objective, written public health or safety standard demonstrating that Project’s aesthetics will create “significant, quantifiable, direct, and unavoidable impacts” to health and safety that cannot be mitigated. 5 Government Code Section 65863.2 (AB 2097).
City of Bevery Hills
July 20, 2026
(e) Summary
In summary, Appellant’s allegations on this point fail to meet the very high bar required to demonstrate that the Project will have a “specific, adverse impact,” as defined in the HAA.
Response to Public Comments: Mr. Dusick’s supplemental public comments reiterate several of the same arguments about alleged “specific, adverse impacts,” which are all subject to the same fatal flaws as the Appeal – specifically, Mr. Dusick does not identify any objective, written public health or safety standard demonstrating that the Project will create “significant, quantifiable, direct, and unavoidable impacts” to health and safety that cannot be mitigated. Simply claiming that an impact is “objective” or “quantifiable” does not make it so.
2. “The Legally Required Findings Under Beverly Hills Municipal Code (“BHMC”) §10-3- 3100 Cannot Be Made with Supporting Substantial Evidence” (a) Development Standards
The Appellant makes multiple arguments in this section of the Appeal. First, the Appellant argues that the City can impose development standards on the Project. This is incorrect. Forcing a proposed project to change its development standards (height, setbacks, etc.) is the same as disapproving the proposed project, because it means the project, as proposed by the applicant, cannot be built. Subsection (d) of the HAA lists the only legal grounds for disapproving a “housing development project for very low, low-, or moderate-income households” – which includes the Project.6 Failure to comply with development standards is not one of them, unless the City had a compliant Housing Element when the application was deemed complete. Because the City did not have a compliant Housing Element when the Project application was deemed complete, the City cannot disapprove the Project for failure to comply with the City’s development standards. And consequently, the City cannot impose its development standards on the Project.
(b) Least Cost Zoning Law
The Appeal includes the following claim: “The Least Cost Zoning Law, which was enacted as a companion to the Housing Element Law, provides that a city shall not be required to zone any parcel in an urbanized, residential area for ‘densities that exceed those on adjoining residential parcels by more than 100%.’ (Gov’t. Code § 65913.1(b).) This is clearly an implied limitation on the density of a Builder’s Remedy project.”
There is no foundation for this claim. First, the approval of the Project would not require the City to rezone any parcel, so parameters related to zoning actions are irrelevant. Moreover, there is no reference to the HAA – the source of the Builder’s Remedy – in the Least Cost Zoning Law, nor is there any reference to the Least Cost Zoning Law in the HAA. Finally, the Least Cost Zoning Law and the HAA 6 20% of the Project’s units are restricted for low-income households.
City of Bevery Hills
July 20, 2026
are in completely different chapters of the Government Code, further undercutting any argument that there is some kind of implied relationship between them.7 (c) Mullin Density
The Appeal also claims that the “Mullin” density – 30 units per acre – is an implied limit on density. This, again, has no foundation in law. The Mullin density is a minimum density that a city can assume to be sufficient for a parcel that is included in the city’s Housing Element sites inventory as a site that can accommodate lower-income households.
8 The City is not being asked to take any action
related to its Housing Element. Consequently, the Mullin density is completely irrelevant to the question of whether the City must approve the Project.
3. Failure to Comply with CEQA
The Appeal argues that the AB 130 CEQA exemption (Public Resources Code Section 21080.66) is not available for the Project because the Applicant filed a preliminary application prior to the date the AB 130 CEQA exemption became law. This argument fundamentally misunderstands the impact of filing a preliminary application.
The HAA states that “a housing development project shall be subject only to the ordinances, policies, and standards adopted and in effect when a preliminary application … was submitted.”9 “Ordinances, policies, and standards” is a defined term that means:
General plan, community plan, specific plan, zoning, design review standards and criteria, subdivision standards and criteria, and any other rules, regulations, requirements, and policies of a local agency, as defined in Section 66000, including those relating to development impact fees, capacity or connection fees or charges, permit or processing fees, and other exactions.
The purpose of a preliminary application is to allow an applicant to lock in the local standards applicable to a project at an early stage in the development process. However, preliminary applications do not lock in state law.
A CEQA determination must be made at the time a project is approved, 10 and the CEQA
determination is subject to the state laws in place at the time of the approval. Although the AB 130 exemption was not in effect at the time the preliminary application was submitted, it was in effect when the Planning Commission approved the Project, and it is still in effect now. 7 The HAA is in Title 7, Division 1, Chapter 3, Article 10.6 of the Government Code. The Least Cost Zoning Law is in Title 7, Division 1, Chapter 4.2 of the Government Code. 8 Government Code Section 65583.2(c)(3)(B).
9 Government Code Section 65589.5(o)(1).
10 CEQA Guidelines Section 15004(a).
City of Bevery Hills
July 20, 2026
Finally, the City’s planning staff has thoroughly examined the Project’s eligibility for the AB 130 CEQA exemption and has correctly determined that the Project is eligible for this exemption.
Consequently, no further CEQA analysis is required.
Response to Public Comments: Mr. Dusick’s supplemental public comments also focus heavily on the CEQA argument in the Appeal. However, the erroneous conflation of state and local law, and the misunderstanding of the impact of filing a preliminary application discussed above, undercut Mr.
Dusick’s entire argument. Mr. Dusick also calls the AB 130 exemption a “categorical” exemption and cites some exceptions to categorical exemptions that he believes apply to this Project. However, the AB 130 exemption is a statutory exemption, not a categorical exemption, and is not subject to any exceptions. Consequently, Mr. Dusick’s discussion of cumulative impacts and the apparently forthcoming Traffic & Parking Review analysis by MAT Engineering regarding the “transportation impacts of this Project, when taken cumulatively,” are completely irrelevant.
4. Project Approval Violates the Constitution
The Appeal argues that the Builder’s Remedy, and by extension the approval of the Project, violate the state and federal constitutions by denying the Appellants’ due process rights, abrogating the City’s zoning authority, and effecting a taking. Appellants fail to establish a legal basis for any of these claims.
Regarding due process, the Appellants have had the opportunity to participate – and have participated – in an open, public process relating to the review and approval of the Project, including the filing of this Appeal.
Furthermore, the City’s zoning authority is not sacrosanct or somehow exempt from state law.
The California legislature and state courts have declared and determined repeatedly that there is a housing crisis in California and that provision of adequate housing is a matter of statewide concern, allowing state housing laws to override the land use authority of local governments (including charter cities).
11 Finally, in discussing the Takings Clause, the Appeal speaks of the need for regulations to balance goals, provide public benefits, and protect public welfare. However, the Appeal’s discussion of these issues is completely one-sided and lacks any acknowledgement that the Project would provide housing for 55 households, including 11 lower-income households. These are clear public benefits that promote the public welfare, and are appropriately given substantial weight in the state legislature’s balance of policy goals.
Response to Public Comments: Mr. Dusick reiterates these arguments in his supplemental public comments. In doing so, he suggests that the “Legislature likely never contemplated” a scenario where a project in one city could have impacts in a different city. This does not give the Legislatures enough credit. Anyone familiar with California geography understands that urban cities fit together like puzzle 11 From the HAA, subsection (g): “This section shall be applicable to charter cities because the Legislature finds that the lack of housing, including emergency shelter, is a critical statewide problem.” City of Bevery Hills
July 20, 2026
pieces and that it is common for parcels separated by only a property line or a street to lie within different jurisdictions.
Furthermore, Mr. Dusick portrays the Builder’s Remedy as a form of punishment and alleges that the application of the Builder’s Remedy to this Project is irrational because it will punish the adjacent homeowners in Los Angeles rather than punishing the City. However, Mr. Dusick’s argument misconstrues the fundamental purpose of the Builder’s Remedy, which is to ensure that sufficient housing will be approved to meet the regional housing need even if a local jurisdiction fails to timely adopt a compliant Housing Element. Here, the Builder’s Remedy is doing just that – allowing the approval of a housing project that will provide much needed housing, including affordable housing, in a region with a significant housing shortage.
Finally, Mr. Dusick’s supplemental comments add an equal protection argument but fail to develop the argument with any legal support.
C. Conclusion
For the foregoing reasons, the Appeal lacks merit and should be denied. We therefore respectfully request that the City Council comply with state law and approve the Project.
Sincerely,
Dave Rand
Dave Rand
Partner
of RAND PASTER & NELSON, LLP
From:
To: City Clerk
Subject: 232 Tower Drive
Date: Tuesday, July 21, 2026 6:24:21 PM
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Hello! I’m writing to voice my concern regarding the possible new building planned for 232 Tower drive. I am a tenant on this street and I strongly object to this enormous project. A building with 55 units and only 13 parking spaces is going to create so much congestion on our street and surrounding streets. I’m am pleading with the city to save the existing building at 232 Tower drive for all of us that live in this street but especially for the current tenants of the building.
Thank you!
Jessica Tarazona
Sent from my iPhone=
Jul 21, 2026
City of Beverly Hills
455 North Rexford Drive, Room 280A
Beverly Hills, California 90210
Re: Proposed Housing Development Project at 232 Tower Drive To: [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Dear Beverly Hills City Council,
The California Housing Defense Fund (CalHDF) writes regarding item F1 on the agenda for the July 21, 2026 Council meeting: permit approvals for a proposed 55-unit housing development project at 232 Tower Drive, which includes 11 low-income units. We urge the City to approve the project, as is required by law.
Under the HAA,1 a city may not disapprove a qualifying affordable housing project (i.e., a housing development project that provides a certain percent of the total units to lower-income households, as defined by Health and Safety Code Section 50079.5) on the grounds it does not comply with the city’s zoning and general plan if the developer submitted either a statutorily defined "preliminary application" or a "complete development application" while the city's housing element was not in substantial compliance with state law. (See Gov. Code, § 65589.5, subds. (d)(5), (h)(5), (o)(1).2) This statutory provision temporarily suspends the power of non-compliant municipalities to enforce their zoning rules against qualifying affordable housing projects. (See, e.g., California Housing Defense Fund v. City of La Cañada Flintridge, Case Number: 23STCP02614 (attached), for a recent court decision affirming the plain language of the statute in this regard.) The City’s Housing Element was 2 These code section numbers correspond to the HAA as it existed when the preliminary application for the project at issue was submitted (i.e. before AB 1893 went into effect). 1 AB 1893, effective January 1, 2025, has amended the “Builder’s Remedy” provisions of the HAA.
However, the AB 1893 allows for vested Builder’s Remedy applications to proceed under the previous version of the law or the new version of the law.
2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
not in substantial compliance with state law when the preliminary application under SB 330 was submitted. The City must therefore allow the project to be developed as proposed.
The project is eligible for an exemption from the provisions of the California Environmental Quality Act (CEQA) pursuant to AB 130. (Pub. Resources Code, § 21080.66.) Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 911.) We urge the City to reject the baseless appeal and approve the project, as is required by law.
CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org.
Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
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