Proposition R (1990) and the Affordable Housing Production Program Proposition R was passed in 1990 by the voters, and requires that 30% of all new multifamily housing in the City be affordable to low- and moderate-income households. The Affordable Housing Production Program (AHPP) implements Proposition R, making the creation of affordable housing mandatory as part of the development of market-rate apartment and condominium buildings. Developers of new multifamily buildings are required to contribute to affordable housing in Santa Monica, including :
• Constructing inclusionary affordable residences onsite in a development. • Constructing affordable residences offsite in another development. • Paying an affordable housing fee that is used by the City to subsidize affordable housing developments and are deposited into the Citywide Housing Trust Fund.
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The City continues to comply with the Proposition R affordable housing production mandate of 30% affordability in the long-term; between fiscal year 1996-97 through FY 2018-19, 38% of all multifamily housing constructed (5,346 total), pursuant to Proposition R, is affordable. The City has exceeded the goals of Proposition R, with 40 percent of all new housing built over the past 20 years being deedrestricted for occupancy by low- and moderate-income households. The City’s Affordable Housing Production Program has produced more than 800 units.
Housing Trust Fund
Additionally, the City has a Housing Trust Fund. Funds come primarily from redevelopment loan repayments and the stream of ongoing revenue provided by the voter-approved sales tax, Measures GS/GSH. The Housing Trust Funds has supported the production of over 1,200 very low and low-income affordable units over the same time period in addition to acquisition and rehabilitation of existing units and rental subsidies to help keep Santa Monicans housed.
Section 8 Housing Choice Voucher Program
Santa Monica also has made considerable investments into expanding new housing choice and opportunities for low-income households. The Santa Monica Housing Authority operates the Section 8 Housing Choice Voucher program, which provides rental housing vouchers to extremely low- and very low-income households with rent subsidies to bridge the gap between what the household can afford and market rents. Further, the City has been active in preserving affordable housing for seniors through Project-Based vouchers that fund the rehab of affordable units and prevent them from becoming market rate units.
Santa Monica’s Approach to Addressing Homelessness
Santa Monica also has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. The City’s homeless service system has evolved significantly over 40 years and is nationally recognized as an innovative model that addresses the complex issues that contribute to long and repeated episodes of homelessness. On March 26, 2019, the City introduced the Four “Pillars” upon which the City’s homeless strategies are built:
• Preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities;
• Addressing the behavioral health needs of vulnerable residents; • Maintaining equitable access to safe, fun, and healthy open spaces; and • Strengthening regional capacity to address homelessness.
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These strategies have been implemented through interdepartmental and community partnerships that contributed to a sustained reduction in homelessness in the downtown and beach areas, as well as an overall 8% reduction in the City’s 2020 Point-In-Time homeless count. In February 2021, in response to the economic and housing challenges brought on by the COVID19 pandemic, the City reaffirmed its commitment to addressing homelessness. In addition to continuing the multi-disciplinary street teams and the Reed Park Ambassador program through June 2023, Council prioritized the following additional strategies for consideration during the forthcoming biennial budget process. • Extended Emergency Rental Assistance to prevent residents from falling into homelessness.
• An alternative non-congregate shelter on City property. • A behavioral health triage center.
• Low acuity crisis response unit in the Santa Monica Fire Department.
Even with the City’s residential protections, programs, and incentives at addressing fair housing issues, the lack of affordable housing to meet the housing needs of low- and moderate income residents, especially for people of color, continue to remain a challenge.
Pilot Right to Return Program
Most recently on July 13, 2021, Santa Monica City Council made changes to Santa Monica’s Affordable Housing Production Program and Housing Trust Fund to address past urban renewal policies that displaced many households of color. Specifically, the City’s affordable housing waitlist priority will be modified to include those former residents who were displaced by the creation of the Civic Auditorium in the Belmar Triangle neighborhood and I-10 freeway in the Pico neighborhood in the 1950s and 1960s. The pilot program is part of the City’s commitment to equity and inclusion.
2. Future Actions
This Housing Element includes policies and programs further outlining the City’s commitment to remedying the legacy of past housing discrimination practices, breaking down the patterns of segregation , and ensuring fair housing opportunities to all. Chapter 5 of this Housing Element includes programs that provide address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization, and displacement protection These programs are described briefly below :
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Enhancing Housing Mobility
Housing Mobility Strategies consist of removing barriers to housing in areas of opportunity and strategically enhancing access. This Housing Element sets forth the following programs that will enhance housing mobility:
• Program 1.C – Incentivize Housing Development On Surface Parking Lots In Residential Zones That Are Associated With Existing Commercial Uses Under Program 1.C, the existing zoning barriers to housing on surface parking lots in the R1 and multiunit residential zones would be removed. Specifically, current zoning restricts the development of surface parking lots that are located in the residential zones. Current zoning limits where vehicular access can be taken on these parcels and also caps the number of residential units that could be developed (e..g, density cap of 4, 5, or 6 units), Program 1.C would remove these existing land use and zoning constraints to housing and adopt new standards to encourage housing projects on surface parking lots. This program would promote access to multifamily housing in the high opportunity areas of R1 and the multiunit residential (R2, R3, R4, OP2, OP3, and OP4) neighborhoods. • Program 3.B - Develop Tenant and Landlord Programs to Address State and Federal Legislation Mandated Regarding Anti-Discrimination
Under program 3.B, the City shall continue to implement programs, including tenant and landlord education/outreach, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts. Currently, the City has several progressive legal protection programs, such as just-cause eviction protections and a new 2-year pilot Right to Counsel program to assist tenants facing evictions. • Program 3.C- Facilitate the Conservation of Restricted and Non-Restricted At-Risk Housing Under Program 3.C the City will continue to provide information on maintaining long-term affordability and assist federally-funded housing properties with seeking funding assistance by applying for allocations of housing vouchers from the federal government to maintain housing affordability.
• Program 6.A - Maintain Rental Housing Voucher Programs And Expand To Assist All Persons With Disabilities
Under Program 6.A, the City will continue to:
• Maintain and operate the Section 8, Housing Choice Voucher Program • Maintain a City-wide list of affordable rental vacancies in partnership with Community Corporation of Santa Monica
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• Program 6.D - Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources
Under Program 6.D, the City will continue to:
• Provide education and outreach to tenants and landlords to increase awareness about federal and local housing programs, including Section 8 housing voucher programs
• Provide education and outreach to tenants and landlords to increase awareness about federal and local housing rights and legal obligations, including antidiscrimination regarding source of income • Enforce the Affirmative Marketing Policies that are required as part of HOMEassisted rental development Providing New Housing Choices and Affordability in High Opportunity Areas Housing choice strategies promote the housing supply, choices and affordability in areas of high opportunity and outside of areas of concentrated poverty. This Housing Element sets forth the following programs that will provide new housing choices and affordability in high opportunity areas:
• Program 1.C - Incentivize Housing Development On Surface Parking Lots In Residential Zones That Are Associated With Existing Commercial Uses As discussed previously, current zoning restricts the development of surface parking lots that are located in the residential zones. Program 1.C would remove these existing land use and zoning constraints to increase housing in the high opportunity areas of R1 and the multiunit (R2, R3, R4, OP2, OP3, and OP4) neighborhoods. • Program 1.J - Revise Development Standards To Ensure Housing Projects are Feasible Incentivized Over Commercial Development.
In some areas of the City, such as the Neighborhood Commercial districts of Main Street and Montana Avenue, housing is a permitted use. However, due to a number of factors including zoning code limitations on development, housing has not traditionally occurred in these areas. Furthermore, a financial analysis on residential development standards Programs to enhance housing mobility also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing:
• Impediments to mobility
• Lack of access to opportunity due to high housing costs • Lack of affordable, accessible housing in a range of unit sizes • Land use and zoning laws
• Private Discrimination
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prepared for the City indicate that housing projects are unlikely to occur in the remaining mixed-use areas of the City such as the boulevards, and Bergamot Area due to land use and zoning restrictions on height and floor area ratios. To incentive housing, Program 4.B would rezone and modify the development standards in all the mixed-use and commercial zoning districts to allow housing projects to have greater density and height than commercial projects. This program would incentivize housing over commercial and create new housing choice.
• Program 4.C - Provide New Housing Choices And Affordability In High Opportunity Areas Through Incentives For Additional ADUs In R1-Zone Neighborhoods The construction of new ADUs in recent years has increased housing opportunities in single -family zones, areas which have traditionally been out of reach for renters. The vast majority of new ADUs constructed or under development in the past 3 years have been in R1 neighborhoods, providing a valuable source of rental housing access in otherwise, high cost neighborhoods. Under State law, properties are permitted to have one ADU and one JADU. This program will further allow one more ADU on single-unit dwelling parcels with the requirement that the additional third ADU be restricted to permanent rental housing.
This program will incentivize the production of ADUs thus providing new housing choice and affordability in the high opportunity areas of the R1 neighborhoods. • Program 2.A - Establish a 100% Moderate Income Housing Overlay Moderate Income housing projects currently have no dedicated funding source or incentives under local or State law. Since AB 1763 only applies to projects up to 80% AMI and the City’s Zoning Ordinance similarly defines 100% affordable housing as only including projects up to 80% AMI, there are no incentives for moderate income housing projects (serving households up to 120% AMI). In the 5th Cycle Housing Element, Santa Monica did not meet its RHNA targets for moderate income units. Moderate-income housing units serve an important segment of Santa Monica workers and residents that do not qualify for lower-income affordable units yet cannot afford market rents. Program 2.A would create a new zoning overlay to incentivize moderate income housing projects in the targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th St station. 100% Moderate Income housing projects would be incentivized through special standards such as additional height (at least 33 feet additionally), density bonus, and reduced parking requirements. This program will incentivize the production of moderate-income housing thus providing new housing choice and affordability in the high opportunity areas around the Metro E transit stations.
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• Program 2.C Update the City’s Affordable Housing Production Program (AHPP) to Incentivize Housing Production at All Income Levels
The City’s long established AHPP program has produced over 800 affordable units – expanding housing choice and affordability for many Santa Monica residents. Despite the success of the AHPP, there is still a significant gap between the housing needs of low-income households and the availability of affordable units. To further incentivize the production of affordable units at various income levels, Program 2.C would establish a new base affordability percentage of 15% for with the inclusionary units provided equally among very low-, low- and moderate-income levels. Program 2.C would also establish new more flexible requirements for in-lieu fees and off-site affordable housing. • Program 4.A - Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Nonresidential Zones Where Not Currently Permitted
Currently, multi-unit residential is not permitted in certain commercial areas of the City; namely, the Industrial Conservation District, Office Campus, Creative Arts Center, and Conservation Creative Sector. Residential uses are not permitted in these zones, even though there may be existing residential uses that were developed in the past. Furthermore, areas within some of these zoning districts have significant housing potential with access to residential amenities, such as transit, commercial uses, parks, schools, and infrastructure.
Program 4.A would add housing as a permitted use in these zones, creating new housing choices and affordability.
• Program 4.B - Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses
Parking lots of religious congregations are largely located in multi-unit residential zones presenting a unique opportunity to expand housing choice in these areas. During the Housing Element outreach process, the City met with a variety of religious congregations through the Westside Interfaith Council. A handful of congregations have expressed strong interest in developing affordable housing on the parking lots of their sites. This program would adopt special standards in the Zoning Ordinance to support the production of affordable housing on surface parking lots owned by community assembly uses, which include religious congregations, including allowing some, but not more than 50%, marketrate units to support the affordable housing. With this program, properties associated with religious congregations and other community assembly uses in the multi-unit residential zones would be opened to new housing opportunities.
• Program 6.H - Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing
In the 2015 Zoning Ordinance update, Santa Monica adapted reasonable accommodation procedures (SMMC Chapter 9.49) that specify the applicability of eligible applicants and
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requests, application requirements, reviewing authority and procedures, findings and decisions, appeal process, and the duration limits of the accommodation. The City will maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws.
Place-based Strategies to Encourage Community Conservation and Revitalization:
These strategies involve approaches that are focused on conserving and improving assets in areas of lower opportunity and concentrated poverty such as targeted investment in neighborhood revitalization, preserving or rehabilitating existing affordable housing, improving infrastructure, schools, employment, parks, transportation and other community amenities.
As a compact city of 8.3 square miles with a costly housing market, the City doesn’t have the same level of distinct lower opportunity and concentrated poverty areas as other cities in the Region, such as the City of Los Angeles. This is evidenced by the fact that the entire City is considered to be a high opportunity area. Even so, some census tracts particularly adjacent to the I-10 freeway may have slightly less resources and opportunity than others. Therefore, this Housing Element sets forth the following programs that will provide promote community conservation and revitalization:
• Program 3.C - Facilitate The Conservation Of Restricted And Non-Restricted At-Risk Housing.
The City monitors the status of at-risk projects within the City, advise tenants in advance of potential conversion dates, and assist in answering questions from residents of at risk housing. The City will continue these actions and exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units.
• Program 3.D - Maintain An Acquisition And Rehabilitation Program The City provides Housing Trust Fund loans to nonprofit housing providers to assist with the purchase and rehabilitation of existing rental properties occupied primarily by low-income households. As resources are available, the City will continue to provide loan assistance to nonprofit affordable housing providers and work with providers to identify new funding sources.
Programs to enhance housing choice in high opportunity areas also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing:
• Impediments to mobility
• High housing cost
• Lack of access to opportunity due to high housing costs • Lack of affordable, accessible housing in a range of unit sizes • Land use and zoning laws
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• Program 3.E - Maintain A Low Income Residential Repair Program The City implements the Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants; and the Owner-Occupied Rehabilitation Program for low- and moderate-income owners. Minor home modifications improve physical access for people with disabilities and seniors that assist with independent living. The City will continue to implement this program. • Program 3.F - Enhance Code Enforcement Response To Housing-Related Violations The City’s Code Enforcement and Building and Safety Divisions respond to residential building code violation complaints. The City will continue this program and will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies.
• Program 3.H - Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units
The City will continue to provide additional education and outreach to multi-unit property owners on available City programs and support continued rehabilitation, maintenance, repairs, and upgrades of their housing units.
• Program 6.B - Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of Displacement
The City will continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance to the extent feasible. • Program 6.C - Maintain And Expand The Preserving Our Diversity (POD) Program The City will continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible.
Programs to encourage community conservation and revitalization also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing:
• Displacement of Residents due to Economic Pressures
• High housing cost
• Lack of affordable, accessible housing in a range of unit sizes
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Displacement Protection
As discussed previously, while the City already implements a number of programs and actions aimed at keeping residents housed, the inevitable economic pressures of the housing market have resulted in the displacement of residents. A fundamental guiding principle of the Housing Element is the preservation of existing housing stock. The primary reason why the existing multi-unit zones (R2, R3, R4, OP2, OP3, and OP4) are not being proposed for rezoning is due to the fact that most of the City’s rent control housing stock are located in these areas.
Map 2-24: Zoning and Rent Control Units
These rent control units play an important role in keeping housing affordable to existing residents and helping to ensure their long-term tenancy. Any proposed increase to density in the multi-unit residential zones would make these units vulnerable to redevelopment, potentially forcing Santa Monica renters out of their homes. Therefore, this Housing Element does not propose any zone changes in the multi-unit residential zones. In addition to this community preservation approach, this Housing Element also sets forth the following programs to further provide displacement protection for existing residents:
• Program 2.B - Right of First Offer Ordinance for Nonprofit Affordable Housing Providers The City will adopt a Right of First Offer Ordinance that would require that qualified nonprofit organizations would be offered the right of first offer/refusal to purchase private properties
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offered for sale in the City. This program would provide existing residents the opportunity to maintain their housing at an affordable level and minimize overall tenant displacement. • Program 3.A - Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are Replaced
The City will amend the Municipal Code to adopt local requirements that require housing projects replace existing and former residential units in the past 5 years consistent with the requirements set forth in Government Code Section 65915(c)(3). • Program 3.B. - Develop Programs To Address State And Federal Legislative Mandates The City will continue to implement programs, including tenant and landlord education/ outreach, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing. • Program 3.G - Maintain A Mandatory Seismic Retrofit Program In March 2017, the City Council adopted a Seismic Retrofit Ordinance and the City implemented the Seismic Retrofit Program that proactively seeks to strengthen existing earthquake-vulnerable buildings and enhance the safety and security of their occupants.
The City will continue to implement this seismic retrofit program to minimize potential displacement of residents due to seismic risks.
• Program 3.I - Right To Counsel Program
The City in April 2021 began a two-year pilot Right to Counsel program to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic.
This program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. Program 7.C will continue this program to support tenants facing eviction. • Program 4.E - Right to Return Program
The City will implement a Right to Return Pilot Program for households that were historically Programs to protect tentants from displacement also address the following high priority factors identified in the City’s 2020 Assessment of Fair Housing:
• Displacement of Residents due to Economic Pressures
• High housing cost
• Lack of affordable, accessible housing in a range of unit sizes • Private Discrimination
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Goals and Policies
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Chapter 3: Goals and Policies
The Housing Element includes seven goals that create the framework for how the City of Santa Monica will address the community’s housing needs over the next eight years. These goals were reviewed as part of the community process for this Housing Element update. The policy goals of this Housing Element focus on:
Affordable Housing Production: Prioritize affordable housing on City-owned sites and remove barriers to affordable housing production in all areas of the City.
Market-Rate Housing Production: Continue to support the production of new market-rate housing around major transit stops and along major corridors.
Affirmatively Furthering Fair Housing: Decisions regarding distribution of new development are viewed through the lens of providing equitable housing access to all neighborhoods.
Housing Assistance: Continue to prevent displacement of existing households by providing financial and technical assistance for the provision of housing for all income groups and household types including families with children, seniors, persons with disabilities, and others with special needs.
Address Homelessness: Prevent housed Santa Monicans from becoming homeless and continue to address the special
need to provide housing and supportive services for the homeless in the community with an emphasis on the
most chronic and vulnerable individuals.
Balancing Housing with Other City Goals: Incorporate
other community goals related to economic
sustainability and environmental objectives with
the production, conservation, and protection of
housing. These include encouraging a balance
between housing and economic development,
sustainable development, providing supportive
services, and increasing walkability and nonmotorized forms of transportation.
Assuring Equal Housing Opportunities: Continue to
assure equal access to housing for all.
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GOAL 1
Production of new housing that is sustainable, innovative, safe and resilient, appropriate with the surrounding neighborhood, offers opportunities for active and healthy living, including walking and biking, and increases equitable housing opportunities.
In Santa Monica, the demand for
housing greatly exceeds the supply.
This has resulted in Santa Monica
being one of the most expensive
places to live in the country. The City
is required by the State to address this
housing shortage by planning for its
Regional Housing Needs Allocation
(RHNA). In the past eight years,
the City produced 3,643 units, well
exceeding its established 5th Cycle
RHNA of 1,674 units. The City’s target
for this 6th cycle Housing Element
is 8,895 units, an average of about
1,100 housing units annually. This
number is more than 5 times larger
than the allocation required in the
prior Housing Element cycle. Meeting
this housing target will be challenging
and will require the enactment of
new policies and programs to
bolster housing production.
Since then, the City adopted the
Land Use and Circulation Element
in 2010, updated the Sustainable City
Plan in 2014, updated the Urban Forest
Master Plan in 2017, and adopted a
Climate Action and Adaptation Plan in 2019. All of these plans provide the foundation for the creation of sustainable and healthy communities. New housing plays an important role in achieving the City’s goals to reduce vehicle miles traveled, reduce greenhouse gas emissions, expand the tree canopy, and promote environmental justice.
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POLICIES
Policy 1.1 Adequate Land for Housing. Provide adequately zoned sites for all types of housing, particularly multi-unit housing in locations near major transportation hubs and services that promote active living in addition to areas that have historically excluded diverse housing opportunities.
Policy 1.2 Housing Production Incentives. Encourage and provide adequate development standards and incentives for the production of housing, particularly affordable housing.
Policy 1.3 Adaptive Reuse. Encourage and provide incentives for adaptive reuse of existing commercial buildings for housing.
Policy 1.4 Design of Housing. Ensure that the design of new housing development is responsive to the surrounding context.
Policy 1.5 Innovative and Sustainable Housing Design. Ensure that local regulations support:
sustainable construction techniques and materials to the extent technically feasible, environmental justice that protects public health, open space, and expansion of the tree canopy.
Policy 1.6 Housing for Special Needs. Maintain development standards that promote the development of special needs housing, such as affordable senior, accessible, and family housing.
Policy 1.7 Review of Housing Constraints. Periodically review City taxes, fees, and regulations to ensure that they do not constrain housing development.
Policy 1.8 Streamlined Housing Process. Continue to evaluate and provide an expedited and coordinated permitting process and design review, particularly for housing projects, including those using innovative and sustainable construction techniques and materials.
Policy 1.9 Partner with School District and Community College District for Housing. The City shall seek opportunities to work with the School District and Community College District to facilitate housing development.
Policy 1.10 Funding for Affordable Housing on City-Owned Sites. Pursue grant funding opportunities to facilitate affordable housing on City-owned sites
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GOAL 2
Housing production for all income categories including for the community’s workforce and most vulnerable communities.
While it is generally recognized that
Californians pay more for housing
than the average American, Santa
Monica’s housing costs are among
the highest in the nation. There
are a variety of negative effects
caused by a lack of affordable
housing. With a greater share
of household incomes spent on
housing costs, households are left
with less money available to spend
on basic necessities. Having less
money available for non-housing
costs often means that low income
households will have less savings
in the bank, putting them at risk for
poverty or preventing them from
rising out of it.
The City’s economy is supported by
a diverse variety of industry sectors
but remains heavily dependent
on the food/accommodation and
retail trade sectors. This sector employs approximately 25% of the workforce but has generally lower wages than other sectors. With lower income jobs also in other major employment sectors such as education and healthcare, 91% of workers cannot afford to live in Santa Monica. Additionally, the artist community of Santa Monica is a unique sector that should be preserved and uplifted through housing opportunities. Artist special housing needs, like live-work units, should also be considered.
Affordable housing in Santa Monica has been produced from two sources: market-rate housing and public assistance such as the City’s Housing Trust Fund. Market-rate housing is required to provide affordable housing or pay an in-lieu fee through the Affordable Housing Production Program (AHPP).
In the last eight years, the City has constructed 982 affordable housing units, which represents 27% of the total units produced. As part of this Housing Element update, the City of Santa Monica must
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adequately plan for and accommodate a total of 6,168 new affordable housing units, which represents 69% of the City’s overall RHNA.
While the City generally provides several process and development incentives in support of 100% affordable housing projects, the major barriers to the production of affordable housing include:
• Lack of funding
• Land costs
• Insufficient height and density standards necessary to produce units • Commercial prevailing wage requirements for buildings 5 stories and above. • Neighborhood opposition
The City has worked to overcome these barriers over the past 40 years by supporting 100% affordable housing on city-owned land resulting in the production of 770 units of affordable housing. The long-term affordability of these units has been guaranteed through recorded deed restrictions or in the case of property sale, the City has negotiated for right of first option to purchase for a low, fixed amount in the event of future sale. As such the City has a demonstrated history of continuously leveraged public land to produce affordable housing for the benefit of the community.
POLICIES
Policy 2.1 Affordable Housing Financing. Encourage innovative private sector and governmental programs to promote the financing and development of housing for extremely low-, very low–, and low-income persons and for moderate income families.
Policy 2.2 Local Assistance for Affordable Housing. Focus available resources (including City-owned land and Housing Trust Funds) to assist for- profit and nonprofit housing providers to develop housing for extremely low–, very low–, and low-income households.
Policy 2.3 Advocacy for Legislative Changes. Support the enactment of federal, state, and local legislation to provide funding and incentives for the preservation and development of housing that is affordable to very low–, low–, and moderate-income households, and to accommodate special needs.
Policy 2.4 Local Incentives and Streamlining for Affordable Housing. Continue to encourage and provide development opportunities and incentives, expedited permit review, and reduced planning fees to increase the production of affordable housing including extremely low-, low-, very- low, and moderate-income households.
Policy 2.5 Homeownership Opportunities. Explore ways to encourage the development of ownership housing for affordable to moderate-income households and the City’s workforce, including opportunities for employer- provided permanent housing.
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Policy 2.6 New Funding Sources. Work with local nonprofit community organizations to tap into new funding sources and support local capacity to develop affordable housing on an ongoing basis. Explore private arts funding for artist housing.
Policy 2.7 Support for Senior Housing. Encourage and support development of senior housing and facilities to meet the needs of seniors, particularly for the oldest senior cohort, including consideration of a preference for “aging in place” along with the need for more congregate housing and residential care facilities.
Policy 2.8 Support for Special Needs Housing. Consider incentives and requirements to ensure that new residential development accommodates a mix of household types and sizes that include a person(s) with special needs.
Policy 2.9 New Housing Models. Encourage proposals for new housing types, such as co-housing, and assess their feasibility and benefits on a case-by-case basis.
Policy 2.6 Maintenance, Improvement and Development of Housing for Persons with Disabilities. Explore alignment with the Voluntary Compliance Agreement (VCA) between the City of Los Angeles and HUD for, Santa Monica to potentially require at least 15% of total units in all newly constructed multi-family developments receiving public funds where City funds are leveraged with Low-Income Housing Tax Credits to be accessible to persons with mobility disabilities and at least 4% of total units to be accessible for persons with hearing and/or vision disabilities.
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GOAL 3
Preservation of the existing supply of housing and prevent displacement of existing tenants.
In 2020, Santa Monica’s total housing stock consisted of approximately 52,629 total units, 11,572 of which are single-unit residences and 40,853 of which are within multi-unit residential structures.
Although there are over 11,000 single-unit dwellings, there are only around 6,500 parcels zoned R1, meaning many are located within multi-unit zones. The total housing stock includes affordable housing units and rent-controlled units, which are valuable assets to the City as they provide housing opportunities to low and moderate-income households.
There are currently 3,902 publicly-assisted affordable units located within the City of Santa Monica.1 An estimated 770 units are at-risk of converting to market rate by 2031. In addition, as of December 31, 2020, there were 27,429 rent-controlled units in the City.2 Rent controlled units help ensure that rental costs do not outpace existing wages, and therefore, play a crucial role in keeping existing residents housed.
Figure 3-1: Age of Housing Stock
0%
2%
4%
6%
8%
10%
12%
14%
16%
18%
20%
981
2014
or later
880
2010-
2013
3,280
2000-
2009
2,838
1990-
1999
4,426
1980-
1989
10,227
1970-
1979
9,018
1960-
1969
7,116
1950-
1959
4,901
1940-
1949
7,457
1939
or earlier
Deed-restricted affordable housing and rent- controlled units contribute significantly to the City’s housing affordability. Preserving and rehabilitating existing housing stock is a key anti-displacement tool that prevents existing households from becoming unhoused. The vast majority of the City’s housing stock was built before 1980, see Figure 3-1 above. As these units age, they will be at risk of being demolished due to deteriorating conditions if not properly maintained. Some of the City’s existing housing stock will be protected as a result of SB330, which prohibits a project that will demolish 1 These include units produced with federal funding assistance, federal/state tax credits, redevelopment tax increment, City housing trust funds, City Multi-family Earthquake Repair Loan (MERL) Program Assistance and Los Angeles County Housing Authority owned units.
2 City of Santa Monica, Rent Control 2020 Annual Report
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existing residential units and would not replace, at a minimum, the same number of new residential units. This will address existing multi-unit housing properties of five units or less that are particularly vulnerable to redevelopment and replacement. Additionally, the new allowance for ADUs on existing multi-unit properties not only creates more housing opportunities but may also encourage property owners to retain their rental properties. However, there remains existing multi-unit housing properties in the City that have fewer units than maximum allowable density and as such, could be at risk for demolition and redevelopment by a housing project that proposes a higher number of new units.
POLICIES
Policy 3.1 Support the City’s Rent Control Law. Ameliorate the effects of the Costa- Hawkins vacancy de-control regulation on the affordable housing stock.
Policy 3.2 Preservation of Naturally Occurring and Deed Restricted Affordable Rental Housing. Explore strategies to preserve naturally occurring, rent-controlled, and restricted affordable rental housing.
Policy 3.3 Protection of Rental Units. The City shall continue to protect rental housing by restricting the conversion of rental units to ownership units or for uses other than permanent rental housing.
Policy 3.4 Replacement of Demolished Multi-Unit Housing. The City shall ensure the reasonable replacement of multi-unit housing that is demolished.
Policy 3.5 Availability of Affordable Housing. The City shall ensure the continued availability and affordability of housing for very low-, low-, and moderate-income households.
Policy 3.6 Rehabilitation Assistance. Provide rehabilitation assistance to maintain, improve, and extend the use and livability of the City’s aging residential buildings. Explore expansion of existing and new rehabilitation programs that may also result in short-term and longterm deed-restricted affordable units.
Policy 3.7 Public and Private Funding for Rehabilitation and Preservation. Encourage and promote the use of public and private funding to provide rehabilitation, home improvement, and maintenance loans and grants with priority given to affordable units at risk of conversion, and multi-unit rental housing.
Policy 3.8 Continued Maintenance of Existing Housing. Ensure continued maintenance of existing housing and that property owners are made aware of City programs to promote capital improvements to rental housing. Consider property owner incentives to encourage continued maintenance, repairs, and upgrades to housing that addresses the health and safety needs of the residents while respecting the character of the structure.
Policy 3.9 Legal Support for Residents. Continue to provide and strengthen anti-discrimination legal assistance and support for tenants facing harassment or eviction in efforts to prevent displacement of existing tenants.
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GOAL 4
A community that provides equitable housing access to all neighborhoods.
The City of Santa Monica is generally more
homogenous than the County as a whole. The
majority of the City’s residential population is White, followed by Hispanics and Asians, respectively.
Blacks represent 4% of the population. One of the
likely barriers to living in the City for non-Whites
is the high cost of housing. Hispanics and Black
households have the lowest median income in the
City and County as a whole, and as a result, are
often priced out of housing opportunities in the City.
For those households of color that can afford to live
in Santa Monica, many of them are concentrated
in neighborhood pockets of the City along the I-10
Freeway, and within the Pico, Downtown and MidCity neighborhoods.
These patterns of segregation are largely the result
of decades of structural racism deeply rooted in
Federal, State, and local housing policies. This
includes the adoption of exclusionary zoning,
which was used primarily as a way to economically
separate the wealthier Whites from Blacks/African
Americans and other people of color. Since many
Blacks/African Americans could not afford or
were unable to receive mortgages to purchase
homes, they were effectively driven out of singlefamily zoned neighborhoods. The federal policy of “redlining” that arose during the New Deal era
(1930s) also have contributed to the patterns of segregated neighborhoods. This discriminatory practice of determining who could qualify for home mortgages based on skin color led to widespread segregated communities across the country and prevented Blacks/African Americans from buying homes. In Santa Monica, areas that were redlined included the Pico Neighborhood, portions of the Mid- City neighborhood south of Santa Monica Boulevard, and Ocean Park. The pattern of redlined areas directly correlate with the areas where the non-White population, lower income households, and renter households are concentrated.
Redlining
The term “redlining” refers to the
discriminatory policy instituted by the
federal government to create colorcoded maps of every metropolitan area in the country to indicate where
it was safe to insure mortgage.
These maps were based on racial
composition, quality of housing stock,
access to amenities, etc. and were
color coded to identify best (green
“A” grade), still desirable (blue “B”
grade), definitely declining (yellow “C”
grade), and hazardous (red “D” grade)
neighborhoods. Areas of the City that
were predominantly commercial/
industrial were not color coded.
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Figure 3-2: Santa Monica Population by Race, 2019
65%
White
10%
Asian
4%
Black or
African
American
15%
Hispanic
or Latino
5%
Two or
more races
1%
Other
POLICIES
Policy 4.1 Access to Opportunities. Promote access to environmentally healthy neighborhoods that offer transportation services, jobs, high performing schools, parks, and residential amenities – particularly in areas that have historically excluded certain segments of the population.
Policy 4.2 Equitable Distribution of Housing for All Income Levels. Encourage fair distribution throughout the City of all housing types for extremely low–, very low-, low-, and moderate-income persons including the most vulnerable communities and the housing insecure.
Policy 4.3 Targeted Investments. Strategically target housing creation and preservation strategies (e.g., public funding, incentives, infrastructure investments, etc.) and diverse housing types in locations that will help overcome historic patterns of segregation as well as programs and measures such as a “Right to Return” program that will help support historically displaced families and individuals in Santa Monica with housing.
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GOAL 5
Housing for persons experiencing homelessness.
Even prior to the COVID- 19
pandemic, homelessness was
and continues to remain a
regional and local challenge.
Homelessness is driven by a
multitude of factors, including:
inadequate housing supply at all
affordability levels, rising rents that
have outpaced stagnant wages,
and discriminatory housing and
employment policies that have
kept low-income populations and
people of color in poverty. These
challenges are compounded
by insufficient and inconsistent
access to medical and behavioral
healthcare, as well as other
essential supportive services.
Up until 2020, City staff and volunteers had conducted annual point-in-time counts to approximate the number of homeless individuals within the City borders, along with a count of shelter use that same night. The last recent count took place on the night of January 22, 2020 with a total of 907 individuals counted outside on the streets, in cars and encampments, and in shelters and institutions within the City.
While this number represented a decrease from 2017, the situation is expected to worsen due to the economic recession caused by the COVID-19 Pandemic, especially once the City’s eviction protection moratoriums expire.
The City’s unhoused population includes veterans, women, persons with disabilities, older adults, and other vulnerable groups. A disproportionate number of Blacks/African Americans experience homelessness in Los Angeles County while the proportion of other racial and ethnic groups are either under or equal to their prevalence in the general population, making it clear that homelessness is also a social justice issue.
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Figure 3-3: Homeless Count, 2015 - 2020
City of Santa Monica Service Planning
Area 5 - Westside Los Angeles County
2015 738 4276 41174
2016 728 4659 43854
2017 921 5411 52442
2018 957 4401 49955
2019 985 5262 56257
2020 907 6009 66436
Source: Los Angeles Homeless Services Authority, https://www.lahsa.org/homeless-count/
POLICIES
Policy 5.1 Regional Fair Share Approach. Encourage a regional fair share approach to providing housing opportunities and assistance to homeless, extremely low-, very low-, and lowincome households, and households with special needs.
Policy 5.2 Housing and Supportive Services for the Homeless. Match housing and supportive service resources to the needs of priority homeless populations: Santa Monica’s chronically homeless; those whose last permanent address was in Santa Monica; and vulnerable members of Santa Monica’s workforce.
Policy 5.3 Removal of Barriers to Supportive Housing. Remove barriers to the provision of low barrier navigation centers, emergency shelters, and supportive/transitional housing.
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GOAL 6
Provision of housing assistance and supportive programs and services to extremely low-, very low-, low-, and moderate-income households and households with special needs, families, seniors, and the homeless.
Certain segments of the population may have greater difficulty in finding decent, affordable housing due to special circumstances. Populations requiring housing assistance and supportive programs include low-income households, the elderly, persons with disabilities, families, persons in need of emergency shelter, and persons with developmental disabilities.
In 2017, 15.4% of the City’s total households were Extremely Low Income (0% to 30% AMI), 8.8% were Very Low Income (31% to 50% AMI), 11.6% were Low Income (51% to 80% AMI), and 7.0% were Moderate Income (80% to 100% AMI). Income disparity by racial group is apparent at the City level. Households of colors are more likely to have lower income levels than White households.
Many lower-income families are considered housing cost-burdened - spending more than 30 percent of their monthly income for housing costs, leaving very little left for other basic needs like healthcare, food, and transportation. Others are forced into overcrowded or substandard housing conditions or join the increasingly large population of people experiencing homelessness.
The elderly population, large families, families with children, and individuals with disabilities also require support, as they may have specific housing requirements that are necessary for access and enjoyment of their residence.
Figure 3-4: Household Affordability Level by Race
Households Total
Households
Extremely Low
(less than
30% AMI)
Very Low
Incomes
(30-50% AMI)
Low Income
(51-80% AMI)
Moderate
(80-120% AM)
White 33,400 .6% 7.6% 10.7% 7.2%
Hispanic 5,705 20.7% 13.4% 18.0% 7.5%
Asian 4,245 15.1% 4.8% 9.1% 4.8%
Black/African
American 1,508 12.7% 28.4% 15.7% 6.4%
Other 1,495 14.9% 9.9% 12.6% 8.6%
All Households 46,353 15.4% 8.8% 11.6% 7.0%
Source: CHAS HUD Data, 2017.
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POLICIES
Policy 6.1 Financial Assistance for Residents; Rental Assistance Programs. The City shall provide support in rental assistance programs for extremely low-, very low-, and low-income households and household types including seniors, families with children, persons with disabilities, and others with special needs. Explore funding strategies and identify additional funding sources to provide continued support with rental assistance programs.
Policy 6.2 Technical Housing Assistance. The City shall provide information and assistance to extremely low-, very low-, and low-income households and households with special needs and landlords to educate and increase awareness of, and provide oversight on federal and local housing and supportive programs and to assist residents in locating appropriate housing. Address housing barriers and resident challenges in securing and maintaining housing.
Policy 6.3 Funding for Supportive Services. Target funds to ensure a broad array of supportive services to extremely low-, very low-, and low-income persons to ensure their continued maintenance of housing once obtained. Ensure funding that supports emergency housing for the homeless.
Policy 6.4 Consider Expanding the Preserving Our Diversity (POD) Program. Evaluate expansion of the POD program to other rent burdened households including but not limited to additional seniors, families, and persons with disabilities and special needs.
Policy 6.5 Reasonable Accommodations. Provide regulatory relief to enable housing access designed to meet the needs for persons with disabilities to ensure equal housing opportunities, consistent with fair housing laws.
Policy 6.6 Resident Protections During Rehabilitation. The City shall provide resident protections including a temporary relocation program with oversight to minimize resident disruption and ensure that rehabilitation of existing units does not negatively impact or result in permanent displacement of existing residents.
Policy 6.7 Explore Programs with the County of Los Angeles. The City shall explore the possibility of entering into contracts with the County for project-based vouchers including, but not limited to, programs administered by the County of Los Angeles.
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GOAL 7
Eliminate housing discrimination on the basis of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, national origin, ancestry, familial status, income level, source of income, disability, veteran or military status, genetic information, or other such characteristics.
Pursuant to the California Fair Employment and Housing Act [Government Code Section 12921 (a)], the opportunity to seek, obtain, and hold housing cannot be determined by an individual’s “race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, genetic information, or any other basis prohibited by Section 51 of the Civil Code.” Fair housing issues that may arise in Santa Monica (or any jurisdiction) include but are not limited to:
• Failure to make reasonable accommodations or modifications to make a dwelling unit accessible to an individual with a disability;
• Discrimination in the sale or rental of a dwelling unit against an individual based on race, national origin, familial status, disability, religion, sex, or other characteristic; and • Tenant harassment because of race, color, religion, sex, disability, familial status, or national origin
A multi-unit housing development that provides accommodations for persons with a physical disability
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The City of Santa Monica takes fair housing laws seriously and has enacted a number of local laws in support of fair housing including:
• Chapter 4.28 of SMMC, addressing fair housing for families with children, disability, and source of income discrimination
• Chapter 4.40 of SMMC, addressing fair housing regardless of sexual orientation or domestic partnership
• Chapter 4.52 of SMMC, addressing fair housing for persons living with HIV/AIDS • Chapter 9.49 of SMMC, addressing reasonable accommodations for persons with disabilities The Public Rights Division (PRD)
of the City Attorney’s Office
enforces Fair Housing Laws,
including investigation of fair
housing complaints and litigation
if necessary. The PRD also hosts an
annual fair housing workshop and
regularly publishes articles about
fair housing in the Santa Monica
Daily Press. The COVID-19 pandemic has highlighted the importance of housing rights, as many Santa Monicans (especially families and people of color) are facing evictions. The rise in hate crimes against all protected classes has also made the issue of fair housing paramount.
POLICIES
Policy 7.1 Enforce Fair Housing Laws. Continue to enforce fair housing laws including but not limited to, prohibiting arbitrary discrimination in the building, financing, selling, or renting of housing, on the basis of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, national origin, ancestry, familial status, income level, source of income, disability, veteran or military status, or genetic information, and to promote racial diversity and equality in housing distribution.
Policy 7.2 Legal Support for Residents. Continue to provide and strengthen anti-discrimination legal assistance and support for tenants facing harassment or eviction.
Policy 7.3 Fair Housing Community Outreach. Continue to work with local organizations and partners to engage in community outreach strategies that provide information on fair housing laws, including community workshops and public awareness campaigns.
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Summary of
Land Available
for Housing
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A. Regional Housing Needs Allocation
The Regional Housing Needs Allocation (RHNA)
is a state-mandated process that determines
the amount of future housing growth each
city and county must plan for in its Housing
Element. This “fair share” allocation concept
seeks to ensure that each jurisdiction accepts
responsibility for the housing needs of not
only its resident population, but also for the
jurisdiction’s projected share of regional
housing growth across all income categories.
The RHNA process begins with the California
Department of Housing and Community
Development’s (HCD) projection of future
statewide housing growth need, and the
apportionment of this need to regional
councils of government throughout the
state. The Southern California Association of
Governments (SCAG) then determines the
share to be allocated to each city and county
within its region based on its approved Final
RHNA methodology.
On March 4, 2021, SCAG adopted the final
RHNA allocation for all jurisdictions within its region. Figure 4-1 shows Santa Monica’s allocation in the Final Regional Housing Needs Allocation Plan—the planning period of October 2021 through October 2029. Approximately 69% of the units are allocated for households earning less than 120% of the Area Median Income (AMI).
The RHNA represents the minimum number of housing units for which each community is required to provide “adequate sites” through zoning and is one of the primary threshold criteria necessary to achieve State approval of the Housing Element.
Chapter 4: Summary of Land Available
for Housing
On March 4, 2020, SCAG approved the
Final RHNA methodology for determining
each jurisdiction’s RHNA within the SCAG
region. The methodology utilized a threestep process:
1. Determine the jurisdiction’s
projected housing need using
regional projected household growth
and calculate a future vacancy need
by applying a healthy vacancy rate
to owner and renter households.
Assign a replacement need based
on local survey results.
2. Determine the jurisdiction’s
existing housing need based on a
jurisdiction’s proximity to transit and
jobs.
3. Add the projected and existing
housing need together to get a total
and apply social equity adjustment
factors to determine the four RHNA
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Figure 4-1: Santa Monica’s 2021-2029 Regional Housing Needs Assessment Income Level % of AMI* Units % of RHNA
Allocation
Very Low 31-50% 2,794 31%
Low 51-80% 1,672 19%
Moderate 81-120% 1,702 19%
Above Moderate 120%+ 2,727 31%
Total 8,895 100%
1. Extremely Low Income Housing Needs
The RHNA does not include the income level of extremely low-income units (ELI). However, state law (AB 2634) requires Housing Elements to include the projected number of extremely low income housing needs, and the City’s AHPP requires the production of ELI units. HCD indicates that local agencies may calculate the projected housing need for ELI households by applying one of the following two methodologies to the RHNA for very low-income (VLI) households:
• Use available Census data to calculate the percentages of ELI and VLI households and apply these percentages; or
• Assume 50 percent of the VLI units would qualify as ELI.
Applying the first methodology, approximately 7,124 extremely low-income and 4,089 very lowincome households were identified in Santa Monica as detailed further in Appendix B. This equates to 64 percent and 36 percent respectively, of the total ELI and VLI households (Figure 4-2). These percentages suggest that of Santa Monica’s RHNA share of 2,794 RHNA very low income units, a minimum of 1,788 units should be available for extremely low-income households and 1,008 units for very low-income households.
Figure 4-2: Low Income Housing Needs
Existing # of
Households
% RHNA Projected
Need
Extremely Low 71,24 64% 2,794 1,788
Very Low 4,089 36% 1,006
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B. Suitable Sites Inventory
The Regional Housing Needs Allocation (RHNA) is a state-mandated process that determines the amount of future housing growth each city and county must plan for in its Housing Element. This “fair share” allocation concept seeks to ensure that each jurisdiction accepts responsibility for the housing needs of not only its resident population, but also for the jurisdiction’s projected share of regional housing growth across all income categories.
Government Code Section 65583(a)(3) requires local governments to prepare an inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites. This inventory of land suitable for residential development, otherwise known as the Suitable Sites Inventory (SSI), is used to demonstrate that there is sufficient land at appropriate densities and development standards to accommodate the RHNA at the income levels specified within the planning period. For the 6th Cycle 2021-2029 Housing Element, the City’s RHNA is 8,895 units, of which 69% must be provided at affordable levels.
The SSI for the City of Santa Monica’s 6th Cycle Housing Element was prepared in accordance with State Housing Element law and HCD’s Housing Element Sites Inventory Guidebook. Appendix F provides a report of the methodology used to prepare the SSI.
Map 4-1: Suitable Sites
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To prepare the SSI, the City’s land use inventory was comprehensively reviewed to identify sites that are available for housing development within the Housing Element planning period, 2021-2029. The SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning, general characteristics such as historic and land use designations, and market factors. City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. The City focused the inventory to underutilized commercial sites since these sites are most likely to be redeveloped based on evidence of past development trends. Based on the assessment of sites using the above factors and methodology, there are 138 parcels that have approved and pending projects for residential development and 180 non-vacant commercial/mixed use zoned parcels in the City identified to have high potential for residential redevelopment. In addition, 22 residentially zoned sites that are developed as parking lots have been identified as having high potential to be redeveloped for housing.
Approximately 340 sites have been identified that have the highest potential to accommodate housing. These are shown on Map 4-1. Sites may be viewed interactively on the City’s Housing Element Update webpage at: https://www.santamonica.gov/housing-element-update. The sites in the SSI are categorized according to Figure 4-3.
Accommodating for Very Low and Low Income Housing
The State uses the density allowed on a site as a “proxy” for determining whether a site can accommodate housing at lower-income levels.
• Very Low and Low Income. State law establishes a “default density standard” of 30 units per acre for low-income units in the City of Santa Monica. This means that if a site’s zoning allows for a density that is greater than 30 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households.
The City’s Zoning Ordinance uses FAR rather than the density factor of units/acre. Therefore, to determine how many units per acre are possible on each site in the SSI, the number of units possible was calculated based on the allowable FARs established in Programs 1.F and 1.J. The number of units was then translated into units/acre based on the parcel size of each site. These calculations indicate that with the rezoning in Programs 1.F and 1.J, all the non-vacant, commercially zoned sites in the SSI can accommodate housing at greater densities than the “default density” of 30 units/acre. Therefore, per HCD, all sites can be identified as having the capacity and density to accommodate lower-income units.
• Moderate-income. Since all the identified SSI sites can accommodate lower-income units, the City has also determined that each site can accommodate moderate-income housing since units affordable to lower-income households would also be affordable to moderate-income households.
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Figure 4-3: Suitable Sites Prioritization Categories
# Category Description
1 Approved and Pending
Housing Projects
Santa Monica has a number of pipeline housing projects that have been approved or are pursuing entitlements. These units are expected to be constructed in the next eight years and would count toward the City’s 6th Cycle RHNA.
2 Prior SSI Sites 83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have undergone entitlements but the remaining have not. 3 DCP Buildout As part of the Downtown Community Plan that was adopted in 2017, sites in the Downtown were identified for potential redevelopment. 4 City-Owned Sites An important strategy for the City to meet its RHNA targets is the utilization of existing City-owned sites for housing, particularly affordable housing. All City-owned sites that are not currently developed with open space/parks, community centers, civic uses, utilities, etc. are categorized as Category 4 sites.
5 Parking Lots A handful of sites in the City are parking lots, or parking structures. Parking lots are very underutilized and represent the greatest opportunity for new housing without displacement of existing uses.
6 Auto Storage Lots These are parcels currently being utilized almost entirely as auto inventory surface lots for auto dealerships. Auto dealerships have indicated interest in turning over these large surface lots into redevelopment opportunities as they are rethinking their sales operations.
7 Parcels with recent/active
sales
Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites (such as Loopnet), a number of properties have recently sold between 2019-2021 or have active sales listing. 8 Underutilized Sites (20,000
excess sf development
potential)
Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to have a net new development potential of 20,000 sf or greater (based on their existing built sf compared against their currently allowable maximum floor area).
9 Large Parcels (15,000 sf+) Most parcels in the City are 7,500 sf. Large parcels that are 15,000 sf have greater potential for redevelopment.
10 Remaining Sites with less
than 0.5 ILR
All remaining City sites with an improvements to land value ratio (ILR) of 0.5 or less have the highest likelihood of redevelopment.
11 Religious Institutions AB 1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. A number of religious institutions with large surface parking lots are located throughout the City. 12 A-Lots and Residentially
Zone Parking Lots
“A-Lots” are residentially zoned (R1/R2/R3/R4) parcels with an “A” Off-Street Parking Overlay. Within the City, there are 42 A-lots. In addition, there are numerous residentially zoned parking lots that serve the parking needs of boulevard-fronting commercial uses.
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City owned parking lot off of Main Street.
1. Approved and Pending Housing Projects
The City has a significant number of housing projects in the pipeline that if constructed will count toward the City’s 6th Cycle RHNA. As of May 2022, there were approximately 2,594 approved units (of which 637 are affordable) and 2,550 pending units on 137 parcels. The list of approved and pending projects is provided in Appendix F. A review of the past 5th Cycle Housing Element shows that 10% of approved and pending projects were withdrawn and/or have had permit approvals expire. It is not possible for City staff to predict how many and which specific approved and pending projects could be withdrawn or ultimately not developed. Doing so would be arbitrary and speculative. Therefore, a 10% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 2,205 approved units and 2,168 pending units that are projected to count towards the 6th Cycle Housing Element.
2. Prior SSI Sites
The SSI identifies 24 sites that were in the last (5th) Cycle Housing Element with the capacity for approximately 1,500 units. According to Government Code Section 65583.2, if the SSI contains sites that were used in a prior housing element planning period, the City must allow by-right a development that includes at least 20% of the units as affordable. Sites where zoning already permits residential “use by right” as set forth in Government Code section 65583.2 (i), at the beginning of the planning period would be considered to meet this requirement. The City currently allows by-right housing projects through an interim zoning ordinance.
In order for the reused sites identified in the SSI to qualify for inclusion, this Housing Element includes Program 1.A to amend the Zoning Ordinance to establish a permanent by-right approval process for qualifying housing projects, including housing projects providing 20% of units as lower income affordable units.
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3. City-Owned Sites
Achieving the number of affordable housing units for
the 6th Cycle RHNA will be challenging, especially
given limited public funding and high land costs
in the City. The City recognizes that Cityowned land can play an important role in producing significant housing, particularly
affordable housing, and therefore, has
made a commitment to prioritizing such
land for 100% affordable housing within this
Housing Element. Program 2.E. commits
City-owned sites for the development
of affordable housing through a public
process that would maximize the amount
of affordable housing that could be feasibly
developed. The City-owned sites in the SSI are:
Public Parking lots 7, 8, and 12 Parking Structure
3, 4th & Arizona, Bergamot Arts Center, and Main
Street parking lots. With consideration to existing
constraints (such as lease terms, financial resources, etc.), City-owned sites have the potential for accommodating 1,880 units. Program 2.E commits the City to plan for a minimum of 1,880 affordable housing units across available City-owned sites, which may include but shall not be limited to rezoning actions.
4. Community Assebly Sites (Including Religious Congregations) A number of religious congregations with large surface parking lots are located throughout the City.
State law has made it easier to develop housing on religious institutional properties by removing parking as a barrier to development. During the outreach process of the Housing Element, many of these religious congregation leaders have expressed interest in developing housing on their properties and indicated that the provision of affordable housing on these sites would be aligned with their core mission. With Program 4.B to amend the Zoning Ordinance to facilitate the development of housing on surface parking lots owned by community assembly uses, these sites could accommodate 257 units.
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5. All Remaining Sites
The remaining sites in the inventory include parking lots, underutilized sites with low-scale buildings, recently sold/active sales sites, and large sites.
Mixed-Use Zones
Many of the SSI sites are located in the City’s commercial and mixed-use zones (MUBL, MUB, GC, NC). Changes in the Downtown Community Plan and Zoning Ordinance as specified in Programs 1.F and 1.J will be required to support multi-unit housing and the production of inclusionary, affordable housing units in compliance with the City’s Affordable Housing Production Program. In particular, the new increases in density and height would increase the likelihood of housing units to be developed in the NC zone (where housing has traditionally not occurred).
Office Campus/Industrial Conservation/Creative Conservation Sector Sites in the OC, IC, and CCS zones are typically developed for office, business park, warehousing, light industrial, and other commercial uses. A number of sites in these zones have been determined to be compatible for residential uses. The Housing Element includes Program 4.A to amend the Zoning Ordinance to allow multi-unit residential in non-residential zones where housing is currently prohibited.
6. Capacity to Accommodate the RHNA by Income Levels
Per Government Code Section 65583.2(c), the SSI must include a calculation of the realistic residential development capacity of the sites. To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, HCD recommends that a jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA.
With the programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate at least 13,600 units providing a 53 percent buffer above the City’s RHNA of 8,895 units. This number is based on the application of new development standards for housing projects as established in Programs 1.F and 1.J. The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing. The land inventory includes capacity for 521 extremely low, 2,819 very low income, 2,703 low income, and 1,901 moderate income units. Figure 4-4 breaks down the summary of the SSI capacity based on category and income levels.
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Figure 4-4: Suitable Sites Capacity Summary Table – Base Tier 1 Housing Total
Capacity Capacity for Affordable Units
# Units
#
Affordable
Units
ELI VLI LI Moderate
Category 1 Approved 2,205 637 127 177 185 148
Category 1 Pending 2,168 420 24 321 34 41
Category 4 City Sites 1,880 1,880 627 627 627 -
Category 11
Religious Sites
257 130 32 32 32 34
Category 12
Parking Lots
96 9 - - 9 -
All Remaining
Categories 6,619 6,619 1,655 1,655 1,655 1,655
ADUs 376 249 56 8 162 23
Total 13,600 9,944 2,521 2,819 2,703 1,901
RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702
Buffer +4,705 +3,776 +1,124 +1,422 +1,031 +199
53%
C. Accessory Dwelling Units
Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs) play an important role in the production of housing, particularly within single-unit residential zoning districts where historically only one unit is permitted. In recognition of this, over the past four years, the State has enacted several laws to help spur the production of housing through the development of ADUs and JADUs. On September 8, 2020, City Council approved an ordinance incorporating State law ADU requirements into a new ADU/JADU Section of the Zoning Ordinance, SMMC Section 9.31.025 Accessory Dwelling Units and Junior Accessory Dwelling Units. The ordinance further expands upon the new requirements by exempting all ADUs and JADUs from parcel coverage or floor area calculations, providing more permissive development of ADUs. Figure 4-5 and Map 4-2 summarize ADU development and locations within the City since 2018, the start of when State law began to focus on incentivizing ADUs. However, it is important to note that the vast majority of these numbers are from ADU construction on R1 (Single-Unit Residential) zoned parcels. The City is just now starting to see property owners take advantage of the new ability to establish sometimes multiple ADUs with existing multiple-unit residential and mixed-use developments.
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Figure 4-5: Santa Monica ADU Production
Building
Permit Year Permits Issued Total
2018 23 56
2019 60 83
2020 41 115
2021 102 27
TOTAL 226 281
Average
2018-2020 (23+6+41+102)/4=56.5 units per year
Source: Building permit data as of May 31, 2022.
Map 4-2: ADU Locations
Sources: Esri, Airbus DS, USGS, NGA, NASA, CGIAR, N Robinson, NCEAS, NLS, OS, NMA, Geodatastyrelsen, Rijkswaterstaat, GSA, Geoland, FEMA, Intermap and the GIS user community, Sources: Esri, HERE, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community ADU Locations
Zoning
R1: Single-Unit Residential (188)
R2: Low Density Residential (23)
R3: Medium Density Residential (6)
OP1: Ocean Park Single-Unit Residential (2)
OP2: Ocean Park Low Density Residential (7)
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Per State law, a projection of the number of ADUs expected to be built within the 8-year planning period can be counted towards the RHNA. However, this projection must be based on the following factors:
• The number of ADUs or JADUs developed in the prior planning period; • Community need and demand for these types of housing units; • The resources and/or incentives available that will encourage the development of ADUs;
• The availability of ADUs and JADUs for occupancy;
• The unit must meet the Census definition of a housing unit and be reported to the Department of Finance as part of the annual City and County Housing Unit Change Survey; and
• The anticipated affordability of these units.
In order to project the increased potential of ADU development, HCD recommends the following options:
• Use the trends in ADU construction since January 2018 to estimate new production. • Assume an average increase of five times the previous planning period construction trends prior to 2018.
• Use trends from regional production of ADUs.
• Include programs that aggressively promote and incentivize ADU and JADU construction.
As shown in the Figure 4-5 based on ADU building permit data between 2018 and 2021, Santa Monica averaged 56 ADUs per year. However, given that 36
of the ADUs (approximately 16%) were located on
parcels with existing multi-unit dwellings, which are
less typical applicants for ADUs, the average annual
production estimate has been reduced by 16% to
approximately 47 ADUs per year. Therefore, it can
be expected that over the next eight-year Housing
Element cycle, approximately 376 ADUs will be built
and can be used towards our RHNA. This estimate is
conservative, as it accounts for a potential progressive decline in available land for ADU within single-unit
zones. As noted, this forecast also does not account
for possible future interest in ADUs to be incorporated into existing multiple-unit residential and mixed-use
developments, which the City has only just started
seeing very recently as the new law permitting this
only took effect January 1, 2020.
In order to determine assumptions of ADU affordability
in the Southern California region, SCAG conducted
a regional analysis of existing ADU rents. Figure 4-6
shows assumptions for ADU affordability based on the SCAG assumptions.
Determining ADU Income
Levels
SCAG conducted a regional
analysis of current market rents
that can be used to obtain credit
towards each income category
in the RHNA. SCAG’s analysis
was pre-certified by HCD and
allows cities to assume that the
total anticipated ADU production
would be assigned to the
following income categories:
• Extremely Low – 15%
• Very Low – 2%
• Low – 43%
• Moderate – 6%
• Above Moderate – 34%
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Figure 4-6: Estimated Affordability of Projected ADUs 2021-2029 Income Level Percent of ADUsa Projected # of ADUs
Extremely Low Income 15% 56
Very Low 2% 8
Low 43% 162
Moderate 6% 23
Above Moderate 34% 128
a Based on SCAG Survey of ADU Affordability
D. Adequate Sites Alternative - Rehabilitation and Conversion of Existing Units
Government Code Section 65583.1(c) allows for use of existing units to address up to 25 percent of the lower income RHNA by counting existing units made available or preserved through the provision of “committed assistance” to low- and very low-income households at affordable housing costs or affordable rents. This option is referred to as “Alternative Adequate Sites”. However, there are limited parameters under which substantial rehabilitation, conversion, or preservation of units can be counted and the Housing Element would be required to identify exactly how the city will guarantee compliance in order to grant the credit. The units must be:
• Substantially rehabilitated and at imminent risk of loss to the housing stock • In a multi-unit rental or ownership housing complex of three or more units that are converted from non-affordable to affordable rental
• Preserved at levels affordable to low- or very low-income households where the local government has provided those units with continued assistance The City has a history of dedicating revenues to support the rehabilitation of substandard housing units. From 2005 onward, the City provided Housing Trust Fund loans to nonprofit developers for acquisition, rehabilitation, and deed restriction. The City also provides housing assistance to existing residents through a number of programs and has a demonstrated history of working with willing property owners and tenants to grant project-based housing vouchers that might allow some units to qualify towards the RHNA. Further, the Housing Element includes Program 2.C allowing market-rate projects to comply with the AHPP through the acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. Based on past performance, it is expected that the City will continue to preserve the existing at risk housing stock through the acquisition and rehabilitation of existing low-income units. However, it would be difficult to predict how many rehabilitated units could be counted towards the RHNA.
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Implementation
Programs
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The City is committed to implementing the goals and policies in Chapter 3 through the programs in this chapter. These programs have been developed through extensive community engagement and with consideration for actions necessary to achieve a compliant Housing Element. The programs reflect what realistically could be completed in the eight-year planning period. Each program includes background, a description of the program action, timeframe by which the action will be completed, and the City agencies responsible for oversight of the program. The City will be reporting on each of these programs as part of its Annual Progress Report to the California Department of Housing and Community Development.
GOAL 1
Production of new housing that is sustainable, innovative, safe and resilient, appropriate with the surrounding neighborhood, offers opportunities for active and healthy living, including walking and biking, and increases equitable housing opportunities.
Program 1.A By-Right Approvals For Housing Projects
The City shall make permanent amendments to the Zoning Ordinance that are currently interim and make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to allow, at a minimum: 1) 100% affordable housing projects; 2) non-Downtown housing projects that are code-compliant or are granted specified modifications/waivers to be established in the Zoning Ordinance; 3) Downtown housing projects that do not exceed Tier 2 maximums and are code-compliant or are granted specified modifications and waivers to be established in the Zoning Ordinance; and 4) housing projects that include at least 20% of units on-site as affordable to lower-income households [Government Code Section 65583.2(c)], to be reviewed through a by-right process. The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. Such by-right projects shall still be subject to design review, provided that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code.
The City shall extend interim zoning amendments for process thresholds pending the full implementation of this program.
Chapter 5: Implementation Programs
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The City shall also develop written procedures to implement the streamlined review process for eligible projects under SB35.
The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process.
Program Background:
Based on consultation with both affordable
and market-rate housing providers, the
uncertainty presented by a discretionary
approval process is a factor in whether
to move forward with housing projects in
light of other risks that are out of the City’s
control including land costs, construction
costs, and lender requirements. On March
10, 2020, in efforts to streamline the process
for housing production, the City Council
adopted changes to the LUCE, DCP and BAP
as well as an emergency interim ordinance
to allow 100% affordable housing projects
and housing projects up to Tier 2 maximums that are subject to the protections of the HAA to be reviewed through a by-right administrative process. The emergency interim ordinance expires December 31, 2021, unless extended by the City Council.
Additionally, according to Government Code Section 65583.2, if the Suitable Sites Inventory (SSI) contains sites that were used in a prior housing element planning period, the City must allow by-right a development on those sites if the project includes at least 20% of the units as affordable. Therefore, in order for the 5th Cycle Housing Element sites identified in the SSI to qualify for inclusion, the by-right process must be included in the LUCE, Zoning Ordinance, DCP and BAP, as applicable. • Timeframe: by October 15, 2022
• Responsibility: City Planning Division; City Attorney Office • Objective: Allow a ministerial approval process based on objective standards for 100% affordable housing projects and housing projects that do not exceed Tier 2 maximums and are subject to the Housing Accountability Act.
LUCE Tier System
The LUCE created a tiered land use
system based on increments of
height and floor area ratio (FAR). Tier 1
establishes a base height and FAR while
Tier 2 establishes additional height and
FAR that can be requested if community
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Program 1.B Streamline the Architectural Review Process and Ensure Design Review Objectivity for Housing Projects
The City shall adopt new streamlining procedures to allow staff level design review for smaller housing projects and expedited design review of larger housing projects by shifting the design review process to before or concurrently with entitlement issuance. This will reduce processing timelines and increase certainty for housing providers. These procedural changes would involve amending the Municipal Code to assure that design review cannot unreasonably delay a housing project approval by, for example, placing limits on number of hearings and maximum time limits for design review. The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency with SB35.
Program Background:
Santa Monica Municipal Code Chapter 9.55 establishes the Architectural Review Board (ARB), and, along with certain provisions of the City’s Zoning Ordinance, sets forth the City’s design review processes. For all new construction, additions or remodel of an existing building, in all zones except R1 (single-unit), the ARB must make findings in its design review of development including compatibility with surroundings and design that is expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity and individuality. While the findings, which have been in place since the 1970s, are not objective, the design review process occurs after project entitlements and focuses only on project design; as a result, the ARB’s review cannot be used to deny or reduce the density of a housing project.
Additionally, while the City is currently not subject to SB 35 under the 5th Cycle Housing Element reporting period (2013-2021) because the City has regularly met its RHNA targets, it is anticipated that the City with be subject to SB 35 in the coming 6th Cycle Housing Element reporting period (2021- 2029), and will therefore be limited to use of objective design standards when reviewing housing projects eligible for SB 35’s expedited review process. • Timeframe: Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Streamlined housing approvals.
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Program 1.C Incentivize Housing Development On Surface Parking Lots In Residential Zones
In order to provide new housing choices and affordability in high opportunity areas, the City shall adopt standards that incentivize housing production on surface parking lots in residential zones associated with existing commercial uses, including, but not limited to, removing density caps and commercial parking replacement restrictions, lot consolidation, street access to the project, and restoring underlying maximum allowable density.
The City shall also adopt standards that incentivize housing production on surface parking lots associated with existing residential uses as long as the existing residential use is not removed.
Program Background:
There are approximately 108 residentially-zoned surface parking lots associated with an adjacent commercial use. Of those parking lots, 32 are identified as high or medium-high potential for housing in the SSI. The parking lots serve the adjacent boulevard-facing commercial uses. The existing multiunit residential zones have density caps of 4-6 units regardless of the size of the property, which limits their capacity for housing potential.
• Timeframe: by August 1,2023
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Incentivize housing production on underutilized sites that would not displace existing residential tenants.
A typical “A-Lot” in Santa Monica. The residentially-zoned surface parking lot in the foreground with the associate commercial use in the background.
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Program 1.D Reduce Minimum Parking Requirements For Housing Projects
The City shall reduce minimum parking requirements for all housing projects by applying Parking Overlay 1 rates.
Program Background:
Analysis of total development costs for housing projects have shown that stringent parking requirements add significantly to the cost of housing construction. In 2017, the City eliminated parking minimums in the Downtown as part of the adoption of the Downtown Community Plan. Eliminating and/or reducing minimum parking requirements would allow a housing developer to choose the “right-size” supply of parking to meet demand as necessary, and would significantly reduce the cost of housing construction.
• Timeframe: by October 15, 2022
• Responsibility: City Planning Division; Mobility Division; City Attorney’s Office • Objective: Lower the cost of housing production.
The Downtown Community Plan eliminated parking minimum requirements in an effort to reduce construction costs.
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Program 1.E Revise The Design Standards In The Bergamot Area Plan (BAP) For Easier Understanding And To Support Housing
Production
The City shall modify the design guidelines in the BAP to establish objective standards to support housing production by increasing certainty for housing providers. The revisions to design standards will address at minimum: building modulation, ground floor uses, street frontages/pedestrian orientation, open space, reduction in parking minimums, live/work artist and commercial living situations, etc.
The standards shall be user-friendly with improved clarity to support housing production. The BAP should also consider the special housing needs of artists, such as live-work units, to promote artist residents in the Bergamot area.
Program Background:
The BAP was initiated to transition 142.5 acres of former industrial land into a walkable, sustainable, and innovative complete neighborhood. The BAP encourages affordable/market-rate housing to enable employees to live in the area and offer new lifestyle choices connected to transit. However, the design standards in the Plan are complex, unclear, onerous, and do not incentivize housing. As a result, since its adoption in 2013, only three housing projects have been proposed in the Bergamot area. • Timeframe: by June 30, 2023
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Provide clarity in the regulatory environment for housing and incentivize housing production in the Bergamot area.
The Bergamot Area Plan was adopted in September of 2013, and covers 142.5 acres of former industrial land as well as the Beergamot Arts Center
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Program 1.F Revise The Downtown Community Plan Development (DCP) Standards To Support Housing Projects
The City shall modify the development standards in the DCP to ensure they are set at levels that can support the minimum AHPP requirements and to support feasible housing projects. The City shall also amend the development standards and AHPP requirements to ensure Tier 2 and Tier 3 Downtown housing projects are feasible.
The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. Any changes will promote housing and ensure that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR and height shown in the table below. The off-site affordability requirement will be greater than the on-site requirement.
Zone
Approx.
Acres
to be
Rezoned
Current
Tier 1
FAR/
Height
Minimum
Tier 1
FAR/
Height
with
Rezoning
Current
Tier 2
FAR/
Height
Minimum
Tier 2 FAR/
Height
with
Rezoning
Curent
Tier 3
FAR/
Height
Minimum
Tier 3
FAR/
Height
with
Rezoning
LT (East) 12 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft - - LT (West) 11 1.50/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft - - NV 31 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft - 4.0/84 ft BC
(Promenade) 12 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft - - BC (2nd/4th) 25 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft - - TA 52 2.25/39 ft 2.75/60 ft 3.50/60 ft 3.50/70 ft 4.0/84 ft 4.0/84 ft OT 15 2.25/39 ft 2.75/60 ft 2.75/60 ft 3.0/65 ft - -
WT 6 1.50/39 ft 2.75/60 ft 2.25/50 ft 3.0/65 ft - -
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The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation.
In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees, unit mix, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods.
Program Background:
The DCP was adopted in 2017 with a primary focus on producing thousands of new housing units at a range of sizes and affordability levels. The DCP provided both development and process incentives for housing projects through greater FARs relative to commercial development, no minimum parking requirements, and a ministerial approval process for typical mixed-use housing projects. In exchange for these strong incentives, Downtown housing projects are required to provide additional affordable housing and augmented fees for the portion of the floor area above Tier 1 maximums. Since DCP adoption, approximately 1,133 units have been approved in the Downtown with a lesser amount that have moved ahead into building permits. Of those 1,133 approved units, the vast majority were projects that pre-dated the DCP’s inclusionary housing requirements. The current FARs and heights allowed in the DCP are shown below:
• Timeframe: by October 15, 2022
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Continue to encourage housing production in Downtown area.
The Downtown Community Plan was adopted in July of 2017, and covers the Downtown area between Wilshire Blvd and the I-10 from Lincoln Blvd west to Ocean Ave.
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Program 1.G Incentivize And Facilitate The Development Of Accessory Dwelling Units (ADUs) Through An Adu Accelerator
Program
The City shall develop an Accessory Dwelling Unit Accelerator Program that will simplify the ADU process by providing property owners interested in constructing ADUs throughout all neighborhoods with a handbook detailing all ADU standards and review procedures, and pre-approved ADU plans that can be selected to reduce time and costs associated with ADU development. The program will further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year.
Additionally, the City will review and update its locally adopted ADU Ordinance for consistency with State law.
Program Background:
An effective strategy to increasing the housing supply is facilitating the construction of Accessory Dwelling Units (ADUs), particularly in single-unit residential districts. Due to their smaller size and relatively lower cost of construction, ADUs can provide lower-cost housing opportunities within single-unit neighborhoods that are less accessible due to high housing costs.
In 2020, the City approved an ADU Ordinance (SMMC Section 9.31.025) to incorporate State law requirements for ADUs and Junior Accessory Dwelling Units (JADUs). The ordinance further encourages the production of ADUs/JADUs by exempting them from parcel coverage or floor area calculations and provides for a ministerial approval process for all ADUs and JADUs. Since implementation of these new State laws, the City has seen an increase in ADU production and interest each year. • Timeframe: by June 30, 2023
• Responsibility: City Planning Division
• Objective: Streamline approvals and facilitate development of ADUs.
Program 1.H Adaptive Reuse Of Existing Commercial Buildings For Permanent Residential Use
As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to incentivize the adaptive reuse of existing commercial tenant spaces citywide, for permanent residential use and also allow adaptive reuse of existing ground floor commercial space for artists and live-work use. Changes to incentivize the conversion of existing commercial tenant space to residential use include but are not limited to, relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements.
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Program Background:
The COVID-19 pandemic has had a dramatic impact on the City’s commercial real estate market.
Even prior to the pandemic, the retail industry had been struggling to compete with online retailers and the office market had started to trend downward. Empty storefronts and partially-occupied office buildings are not an uncommon sight in the City. With the downturn of retail and office real estate accelerated by the pandemic, the concept of converting commercial into residential has gained significant interest as another avenue to increase the supply of housing in the City. • Timeframe: by December 31, 2024
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Increase flexibility for reuse of vacant commercial space to residential use.
Program 1.I Ensure That Local Regulations Support Innovations In Construction Technology To The Extent Technically
Feasible
The City shall support innovative lower-cost, efficient, and environmentally sustainable construction techniques for housing. Program shall implement a streamlined building permit review process for housing projects utilizing innovative construction methods and technology, and project-based outcome-oriented permitting benchmarks.
Program Background:
New innovations in building and construction technology could help decrease both the time and cost of housing construction. This includes the use of modular/pre-fabricated (prefab) construction or the use of cross laminated timber. Prefab construction involves producing standardized components of a structure in an offsite factory, then assembling them onsite. When prefab construction is done at economies of scale, it can result in significant reduction in housing cost. Cross laminated timber (CLT) has recently started gaining traction in North America as a viable type of construction. In addition to being more sustainable, CLT can significantly reduce the time and labor costs for construction. • Timeframe: by December 31, 2024
• Responsibility: City Planning Division; Building and Safety Division • Objective: Remove impediments to innovation in housing construction.
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Program 1.J Rezoning By Revising Development Standards To Ensure That Housing Projects Are Feasible And Incentivized Over Commercial Development
The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI inventory are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.0 to 3.25 with heights ranging from 55 feet to 65 feet. Any changes will promote housing to ensure overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR and height shown in the tables below. The off-site affordability requirement will be greater than the onsite requirement.
Zone
Approx.
Acres to be
Rezoned
Current Tier 1
FAR/Height
Current Tier 2
FAR/Height
Minimum
FAR/
Height with
Rezoning
MUBL – N of I-10 107 1.50/36 ft 1.75/36 ft 3.25/70 ft
MUBL – Pico 15 1.50/36 ft 1.75/36 ft 2.00/45 ft
MUBL – Pico (West of Lincoln) 4 1.50/36 ft 1.75/36 ft 2.50/55 ft MUBL – Main St 10 1.50/36 ft 1.75/36 ft 2.50/55 ft
MUBL - Lincoln 107 1.50/36 ft 1.75/36 ft 2.50/55 ft
MUB 59 1.50/39 ft 2.25/50 ft 3.25/70 ft
GC (SMB) 24 1.25/ - 1.50/35 ft 3.25/70 ft
GC (Lincoln) 19 1.50/36 ft 2.00/36 ft 2.50/55 ft
GC (Pico) 4 1.50/36 ft 2.00/36 ft 2.00/45 ft
NC 27 1.50/32 ft N/A 2.25/50 ft
NC (Main) 14 1.00/27 ft N/A 2.50/55 ft
NC (Ocean Park) 15 1.00/32 ft N/A 2.50/55 ft
NC (Montana) 15 1.00/32 ft N/A 2.50/55 ft
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IC 77 N/A N/A 3.00/65 ft
OC 88 N/A N/A 2.75/60 ft
HMU 39 1.50/45 ft 2.50/70 ft 2.50/70 ft
Bergamot Area
# Acres
to be
Rezoned
Current
Tier 1 FAR/
Height
Current
Tier 2 FAR/
Height
Current
Tier 3 FAR/
Height
Minimum
FAR/
Height
with
Rezoning
BTV 35 1.75/32 ft 2.00/60 ft 2.50/75 ft 4.0/84 ft
MUC – North of Pennsylvania
Avenue parcel line between
Stewart and Stanford; South
of Expo Bike Path
31 1.50/32 ft 1.70/47 ft 2.20/57 ft 3.25/70 ft
MUC - Remainder 36 1.50/32 ft 1.70/47 ft 2.20/57 ft 4.0/84 ft CCS 8 1.50/32 ft N/A N/A 2.50/55 ft
CAC 17 1.00/32 ft 1.00/60 ft 1.00/75 ft 2.50/55 ft
The City shall consider opportunities, including rezoning or the creation of new zoning districts, as necessary, to facilitate advancement of housing goals and/or historic preservation.
In addition to FAR and height, the City shall review and mofify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix requirements, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods.
Program Background:
When the LUCE was adopted in 2010, its core strategy was to capitalize on the City’s extensive transportation system including the Metro Expo Light Rail and to protect the City’s residential neighborhoods with an emphasis on policies that discourage tenant displacement. This growth strategy has resulted in significant new housing production in the Downtown, but it has also perpetuated the historic patterns of housing segregation that remains to this day. Although all of Santa Monica is considered a high or highest resource area, there remain a handful of areas where housing would not be likely to develop due to FARs that are not high enough to support the City’s regulatory requirements.
The current FARs and heights allowed in the Zoning Ordinance are shown below:
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• Timeframe: by October 15, 2022
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Support the production of affordable housing and encourage the equitable production of housing across the City.
Program 1.K Adequate Sites Program
To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower income units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing 100 percent residential use and requiring residential use to occupy at least 50 percent of the floor area.
Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City complies with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations.
Program Background:
Government Code section 65583(f) and Government Code section 65583.2(h) states that where the inventory of sites does not identify adequate sites to accommodate the RHNA for lower income households, a program must be included to identify sites that can be developed for housing within the planning period. As the City will be accommodating more than 50 percent of the low- and very low-income regional housing shortfall on City-owned sites, the City must allow these sites in the inventory to accommodate 100 percent residential use and require residential use to occupy at least 50 percent of the floor area in a mixed-use project.
• Timeframe: by June 30, 2023
• Responsibility: City Planning Division
• Objective: Create opportunity to accommodate the City’s lower-income RHNA targets.
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GOAL 2
Housing production for all income categories including for the community’s workforce and most vulnerable communities.
Program 2.A Establish A Moderate-Income Affordable Housing Zoning Overlay
The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in at least three targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th Street/Santa Monica College Expo station. The moderate-income affordable housing overlay would allow a height increase of up to three additional stories or 33 feet, 50% density bonus, up to four incentives and concessions, no minimum parking requirements, and flexibility in unit size/unit mix in exchange for additional common area amenities.
Program Background:
AB 1763 amended State density bonus law (Government Code Section 65915) to allow 100% affordable housing projects unlimited density and up to 3 stories or 33 feet above maximum height limits within 1/2 mile of transit. The changes also provide relief from minimum parking requirements and allow requests for up to four incentives/concessions from local development standards.
State Density Bonus law incentives for 100% affordable housing projects only applies to projects up to 80% AMI. The City’s Zoning Ordinance similarly defines 100% affordable housing as only including projects up to 80% AMI. As a result, there are no incentives for moderate income housing projects (serving households up to 120% AMI) even though the City has received a RHNA allocation for moderate income units. In the 5th Cycle Housing Element, the City did not meet its RHNA targets for moderate-income units. In addition, funding sources for 100% affordable projects generally focus on households earning up to 80% AMI and do not provide funding for moderate-income projects.
Moderate-income housing units serve an important segment of Santa Monica workers and residents that do not qualify for lower-income affordable units yet cannot afford market rents. • Timeframe: by June 30, 2023
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Provide significant incentives for 100% affordable housing including moderate income households.
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Program 2.B Right Of First Offer Ordinance For Nonprofit Affordable Housing Providers
Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, the City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making non-profit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildings through this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable.
Program Background:
Acquisition and rehabilitation of existing housing and conversion to affordable units can preserve naturally occurring affordable housing while also providing existing residents the opportunity to maintain their housing at an affordable level and minimize overall tenant displacement. • Timeframe: by December 31, 2024
• Responsibility: City Planning Division; Housing and Human Services Division; City Attorney’s Office
• Objective: Support 100% affordable housing by assisting nonprofit affordable housing providers to be competitive in the land acquisition market.
Program 2.C Update The City’s Affordable Housing Production Program To Increase The Number Of Affordable Housing Units At All Income Levels
In order to increase the number of affordable housing units at all income levels such that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to maximize the contributions of the AHPP to achieving the RHNA affordable housing allocation and advancing the City’s affordable housing goals. Areas to be considered may include, but not be limited to:
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• Increase the threshold (to at least 6 units) at which projects are required to provide onsite or off-site affordable units. • Eliminate the current “menu” option of affordability requirements and instead establish a new base affordability percentage
• Re-evaluate the in-lieu fee option for applicants to pay a fee instead of constructing affordable units to ensure that the fee supports the funding and construction of new affordable housing throughout the City; and
• Evaluate the possibility of a mixed-compliance option that would provide applicants more flexibility in meeting AHPP requirements
• Increase the minimum percentage of required off-site affordable units to be higher than the on-site option;
• Allow projects to locate off-site affordable housing anywhere in the City that is not a disadvantaged area as defined by SB535, which includes socioeconomic and environmental metrics
• Allow market-rate projects to comply with AHPP off-site option through acquisition and rehabilitation of existing rental units and converting those to deed-restricted units.
Program Background:
In 1990, Santa Monica voters adopted Proposition R,
which requires 30% of all multi-family residential
housing that is newly constructed in the City
to be affordable for at least 55 years to and
occupied by low- and moderate-income
households. In July 1998, the City Council
enacted an Affordable Housing Production
Program (AHPP), requiring developers of
market-rate apartment and condominium
projects to contribute to affordable housing
production and thereby help the City
meet its affordable housing need. The
current AHPP requires market-rate housing
developers to select from a “menu” of options
for the production of affordable housing (see
table below). However, in 2013, the menu option
of the AHPP was amended to add the extremely
low-income option, and since that time, the menu
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had the effect of producing many affordable units at the extremely low-income level at the cost of production of other income levels, with particular shortages happening at the 80% to 120% AMI income levels. In response, Option 1 (the extremely-low income option) was temporarily removed by adoption of Ordinance 26059(CCS) by the City Council on April 9, 2019 until November 26, 2019, which has since been extended by the City Council until February 28, 2022. This temporary elimination of the extremely low-income “menu” option had the effect of increasing the minimum inclusionary requirement to 10% of total units for Tier 1 projects, and 15% of Tier 2 and 3 projects affordable to 50% AMI households.
AHPP Menu Option Tier 1 Tier 2/3
1 5% of the total units at 30% AMI 7.5% of the total units at 30% AMI 2 10% of the total units at 50% AMI 15% of the total units at 50% AMI 3 20% of the total units at 80% AMI 30% of the total units at 80% AMI 4 100% of the total units at 120% AMI Not applicable
The AHPP also currently allows developers to fulfill their affordable obligation by providing units off-site or, in limited circumstances, paying an in-lieu fee. However, if a developer elects to provide affordable units off site, the units are required to be located within ¼ mile of the market-rate project, except that within the Downtown Community Plan area, developers of Tier 2 or Tier 3 housing project have the flexibility to locate the off-site housing anywhere within the Downtown. • Timeframe: by April 30, 2023
• Responsibility: Housing and Human Services Division; Economic Development Division; City Attorney’s Office
• Objective: Ensure that the AHPP provides housing developers viable options for compliance.
Program 2.D Update Density Bonus Ordinance To Ensure Consistency With State Law And Integration Into The City’s Land Use System
The City shall update the density bonus ordinance, Santa Monica Municipal Code Chapter 9.22, to ensure consistency with State Density Bonus Law and integration with the City’s land use system, including the AHPP. The ordinance will clarify how to apply State density bonus law in the City’s commercial and mixed-use districts that do not have maximum density controls, including application of State density bonuses to floor area dedicated to residential uses. The amendments to the Municipal Code shall also set forth a voluntary by-right menu of incentives & concessions that do not require following the
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process under Government Code Section 65915(d) for approval. Requests for “off-menu” incentives and concessions may be requested pursuant to Government Code Section 65915(d).
Program Background:
On August 25, 2020, the City Council updated Santa Monica Municipal Code Chapter 9.22 which implements State density bonus law, to incorporate updates to the State Density Bonus Law for 100% affordable housing projects. At the time of the update in 2020, the City deferred amendments that would clarify how to apply State Density Bonus Law to the City’s commercial and mixed-use districts, pending further study, which has been ongoing since December 2019.
After the August 2020 update, Assembly Bill 2345 took effect on January 1, 2021, which expanded and enhanced development incentives for market rate projects that provide affordable housing. AB 2345 increases the maximum density bonus from thirty-five percent (35%) to fifty percent (50%).
To be eligible for the maximum bonus of 50%, a project must set aside at least (i) fifteen percent (15%) of total units for very low-income households, (ii) twenty-four percent (24%) of total units for low-income households, or (iii) forty-four percent (44%) of for-sale units for moderate income households. Levels of bonus density between thirty-five percent (35%) and fifty percent (50%) are granted on a sliding scale
• Timeframe: by October 15, 2022
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Ensure consistency with State Law.
Program 2.E Commit To The Production Of Affordable Housing On CityOwned/Publicly- Owned Land The City shall commit City-owned sites for the production of 100% affordable housing, with consideration of other community-serving purposes, including, but not limited, to green space, place making, and/ or community-serving commercial and revenue generating uses.
The City shall plan for a minimum of 1,880 affordable housing units across available City-owned sites, which are located throughout the city, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders. At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first RFP for a city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as
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existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months.
As has been done in the past, the City will use a variety of tools to facilitate 100% affordable housing development including but not limited to:
•Facilitate appropriate zoning and process to support 100% affordable housing •Substantially reduced or free ground rent
•Providing funding through local housing trust fund
•Support applications for other funding sources for affordable housing (e.g. low-incomehousing tax credits, grants, State funding, Federal funding) • Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Further, the City will continue to assess appropriate City-owned properties for the development of affordable housing, or in some cases may consider the most appropriate disposition of City properties to nonprofit developers for the development of affordable housing.
Program Background:
As a built-out community, the City of Santa Monica has few remaining vacant sites for residential development. This shortage of vacant land necessitates the use of alternative mechanisms for providing sites for housing. In the past, the City has used such mechanisms as long-term leases of City-owned or publicly-owned land. City-owned land is subject to the same development standards as privately-owned land, but may benefit from additional flexibility in order to maximize the development potential for 100% affordable housing.
An RFP to redevelop Parking Structure 3 located on the Third Street Promenade as affordable housing was issued in August 15, 2019 and a developer partner was selected. The Parking Structure 3 RFP required that proposals including a significant commitment to permanent supportive housing for people experiencing homelessness and established parameters for affordable housing including long-term income eligibility and affordability covenants, tenant selection from the City’s belowmarket-rate list, and allowance to target other populations such as working families, seniors, and artist live/work housing.
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• Timeframe: RFPs issued by June 30, 2023; June 30, 2025; June 30, 2027 • Responsibility: Housing Division: City Planning Division; Economic Development Division
• Objective: Prioritize affordable housing production on city-owned land.
Program 2.F New Affordable Housing Finance Programs To Enable Continued Provision Of Technical And Financial Assistance For Housing Production
The City shall leverage its commitment to use of City-owned land for affordable housing with advocacy for new sources of state, federal, and philanthropic funding that may be used for housing. Once appropriate funding sources are identified, the City will take the necessary steps to move forward.
The City has adopted policy on prioritizing our local funding through a Housing Trust Fund plan that includes spending commitments for affordable housing production and preservation for special needs and ELI households, including exploring new funding for conversion to deed-restricted, multi-unit developments in areas of affluence. The plan outlines a funding strategy for ELI households including seniors and persons living with disabilities. The City will continue to implement the policy and execute funding commitments to produce housing targeted to persons experiencing homelessness or at-risk of homelessness. Local funding through the Housing Trust Fund will also help support the production of at leats 1,880 affordable housing units on City-owned/publicly owned land in accordance with Program 2E. On an ongoing basis, the City will continue to communicate with local affordable housing providers on potential housing projects based on funding availability.
Financial and technical assistance shall be provided when resources are available and committed to nonprofit housing providers to the greatest extent possible to support the development of affordable housing, including special needs housing and arts housing. The City will research creative financing tools like a regional housing trust fund and infrastructure financing plans to learn how they are used elsewhere and how the City might best leverage these tools to support the construction of affordable housing
Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Program Background:
The City has historically provided technical and financial support to a variety of nonprofit housing providers to support affordable housing development through the local Housing Trust Fund. Since the dissolution of the City of Santa Monica’s Redevelopment Agency (RDA), the main funding source for the Housing Trust Fund comes from a 0.5% sales tax passed by the voters in 2016. Remaining funding sources, such as the affordable housing commercial linkage fee and the affordable housing in-lieu
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fee, and contributions from negotiated development agreements, do not provide sufficient funding to fill the gap left from the loss of RDA funds. The City continues to work with nonprofit partners to seek out and apply for federal and state funding, as it has done in the past, which resulted in numerous successful funding efforts by nonprofit affordable housing providers.
Santa Monica has been awarded a total of $10 million from the Local Housing Trust Fund (LHTF) program for the 2020 and 2021 funding rounds and is also eligible to receive an estimated $3.285 million from the first five years of the Permanent Local Housing Allocation (PLHA) entitlement program.
The awarded State grants, as well as future State grants, are essential to Santa Monica’s ability to create affordable housing on City-owned land and further the goals of the City’s Housing Element.
In the current environment, the City will need to think creatively and support efforts at the state and federal level to create new funding opportunities for affordable housing in order to maintain current productivity levels. This Housing Element commits City-owned land for 100% affordable housing.
Because land acquisition is typically the largest cost driver for affordable housing, it is anticipated that use of City land will alleviate the impact of land cost on the feasibility of an affordable housing project and allow limited funding resources to be used more effectively in producing affordable housing. • Timeframe: Annual Ongoing
• Responsibility: City Planning Division; Housing and Human Services Division • Objective: Seek innovative affordable housing financing tools to increase production.
Program 2.G Expand Housing Choice By Facilitating The Development And Maintenance Of Special Needs Housing
The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle. This includes the provision of new programs, services, infrastructure and amenities that can help seniors who choose to live independently remain in their homes as long as possible.
Within legal constraints, encourage or require housing providers to assign affordable housing units designed for persons with disabilities, including physical or developmental disabilities, for use by those who require those features. The City shall encourage barrier-free construction and adaptation.
Through the 5-year Consolidated Plan process, the City shall continue to identify housing and supportive service gaps for various special needs groups and propose policy and priorities based on the analysis.
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Program Background:
Santa Monica has a significant residential population in classes protected by California State housing law, which include the elderly, Individuals with mental, physical, and developmental disabilities, large families, female-headed households, and homeless individuals and families without permanent housing. Finding access to resources and adequate, affordable housing is often challenging for individuals and families under such circumstances. Housing for seniors and those with disabilities should incorporate features that contribute to a barrier-free environment, ensuring that anyone who uses a wheelchair or other mobility device is able to visit a building, and accessibility to transit and services.
• Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division; Building and Safety Division • Objective: Housing for individuals with special needs.
Program 2.H Maintain Proposition I Monitoring
The City shall monitor utilization of Proposition I authority through annual reporting of new “low renthousing projects.
Program Background:
Article 34 of the State Constitution requires that any low rent housing project developed, constructed, or acquired by a public agency must first be approved by a majority of the voters living in that jurisdiction. In compliance with this article, the City of Santa Monica put a referendum (Proposition N) before the voters in 1978 in order to win approval to “develop, finance, or rehabilitate, but not own or operate within the city, housing for rental to low- and moderate-income persons, no less than 50% of which shall be reserved for persons age 60 or older, not to exceed in total throughout the city, 1% of the dwelling units in the city.” On November 3, 1998, Santa Monica’s voters approved Proposition I, which provides the City with an annual authorization to develop, construct, acquire, and finance low- income housing units, including senior housing. The City’s annual authorization is equal to onehalf of 1% of the total dwelling units existing in the city at the end of the prior fiscal year. This annual authorization may be carried over the three years.
• Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division
• Objective: Ensure the City continues to report on compliance with Proposition I.
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Program 2.I Zoning For A Variety Of Housing Types Including Special Needs Housing And Housing Access For Persons With
Disabilities
The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law regarding special needs housing types and residential land use classifications.
Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty.
Program Background:
Since the 2015 Zoning Ordinance update, the State has passed various laws that have removed barriers for special needs housing types, such as emergency shelters, group residential, and supportive/ transitional, as well as other residential land uses. These laws have been put into place to ensure that cities zone for a variety of housing types.
• Timeframe: by December 31, 2023 and Annual Ongoing
• Responsibility: City Planning Division; City Attorney’s Office; Housing and Human Services Division
• Objective: Ensure the City is compliant with all State laws for special needs housing types and residential land uses.
Program 2.J Prioritize Water And Sewer Service To Housing Projects With On-Site Affordable Units
The City shall establish written procedures to grant priority to developments with on-site units affordable to lower-income households if availability of service is limited.
Program Background:
Government Code Section 65589.7 requires water and sewer service providers to establish procedures that grant priority water and sewer service to developments that include units affordable to lowerincome households. • Timeframe: by December 31, 2023
• Responsibility: Public Works Department
• Objective: Prioritize infrastructure service to developments with lower income units to support the production of affordable housing throughout the City.
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GOAL 3
Preservation of the existing supply of housing and prevent displacement of existing tenants.
Program 3.A Restrict The Removal Of Existing Rental Units For Site Redevelopment And Require That Protected Units Are
Replaced
The City shall amend the Municipal Code to adopt local requirements that make permanent and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced.
As required by Government Code Section 65583.2(g)(3), the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity’s valid exercise of its police power (approximately 27,484 units), or (3) within the past five years were occupied by low or very low income households, shall be required to replace all of those units as affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth Government Code Section 65915(c)(3).
Program Background:
SB 330 (effective 01/01/21 through 01/01/25) and SB 8 (extended SB330 through 01/01/30) enacted a program that establishes unit replacement requirements and tenant protections for new housing projects proposing the demolition or removal of “protected units”, generally defined as units subject to any form of rent restrictions or price control. These “protected units” include rent-controlled units that must be replaced as part of a new housing project until SB330 sunsets in 2030. • Timeframe: by June 30, 2023
• Responsibility: City Planning Division
• Objective: Protect existing residents by preserving existing rental housing stock; no net loss of units.
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Program 3.B Develop Tenant And Landlord Programs To Address State And Federal Legislative Mandates Regarding AntiDiscrimination The City shall continue to implement programs throughout the City, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues, that strive to protect tenants against landlord discrimination and cancellation of existing Section 8 contracts (including City and/or private foundation-funded subsidy) to enable tenants to remain and pay the maximum allowable rent (MAR). The City will continue to fund the acquisition and rehabilitation of existing rental units and continue to investigate new, innovative ways to increase the affordability of housing in light of the loss of formerly affordable units due to vacancy de-control and Ellis withdrawals. The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles Program Background:
Residents of Santa Monica adopted the City’s rent control law in 1979. Passage of the Costa-Hawkins Rental Housing Act in 1995 by the State Legislature gradually required vacancy de- control/re-control in apartments, and de-control of houses and most condominiums by January 1999; this enables apartment building landlords to raise the price of rent-controlled apartments to market rate when the unit is vacated and is to be rented to a new tenant, establishing a new base rent for the unit. This has allowed 74% of the rent-control housing stock to reset to market rents.
Even with Santa Monica’s exception to the HUD payment standard granted in 2016, the vast majority of Santa Monica’s existing housing supply is out of reach for lower income households. With limited federal funding resources being allocated to cities, the demand for housing assistance outpaces available resources.
The City’s progressive legal protections, such as the just-cause eviction protections in rent-controlled units, have contributed to keeping rent-controlled units affordable to current low- and very low– income tenants. In addition, to help reduce the impact of Costa-Hawkins, the City has developed an Housing Anti-Discrimination ordinance (Santa Monica Municipal Code chapter 4.28), which prohibits various types of housing discrimination—such as refusal to rent, differential treatment, discriminatory statements--on the basis of disability, age, source of income, parenthood, pregnancy, or the potential or actual occupancy of a minor child. In 2015, as an affordable housing measure, the City added Source of Income as a protected class and then added an extra layer of protection with a pioneering definition for Source of Income. For the first time in Santa Monica and in California, the fair housing law expressly protected recipients of rental assistance such as Section 8.
Furthermore, the City has launched a 2-year pilot Right to Counsel program to assist tenants facing eviction. The City also provides one-time homeless prevention grants to households in danger of losing their housing.
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• Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division (lead); Rent Control Board • Objective: Develop programs to address State and Federal housing mandates.
Program 3.C Facilitate The Conservation Of Restricted And NonRestricted At-Risk Housing There are approximately 770 affordable, deed-restricted units that are at-risk of conversion to market rate in the next 10 years. The City will continue to monitor over this Housing Element cycle the status of the approximately 770 affordable deed-restricted at-risk units throughout the City, ensure that required notice is given to tenants, advise property owners and tenants in advance of potential conversion dates, and assist in answering questions from residents of at-risk housing. As a part of the ongoing monitoring, the City will continue to provide information on maintaining longterm affordability and assist federally-funded housing properties with seeking funding assistance in applying for allocations of housing vouchers from the federal government to maintain housing affordability. On an ongoing basis, the City will continue to communicate with local affordable housing providers on conserving housing projects .
The City will exercise its right of first refusal to purchase properties if necessary and financially feasible to ensure the continued availability of affordable housing units. Additionally, the City shall continue to report annually on non-covenant residential units such as the approximately 27,484 rent-controlled units.
Program Background:
The City has a variety of affordable housing projects, consisting of 3,902 deed-restricted residences that are currently serving the community. Publicly-assisted housing units with federal rental assistance subsidies are protected by covenants. Those units with covenants nearing expiration are considered “at-risk” of potential conversion to market-rate housing. According to the City’s local data, a total of 770 publicly-assisted housing units protected by covenants that are due to expire in the next 10 years. They are, therefore, at risk of potential conversion to market rate. These units serve seniors or persons with special needs, with one property serving families.
In addition to the federal covenants, the affordability of the units in these projects is further protected through additional requirements or incentives that the City placed on their loans when they were constructed. Some units are considered to have a lowered risk of conversion to market rate because they are owned and operated by nonprofits whose mission is to create and maintain affordable housing. As the cost of conserving existing deed-restricted affordable units is far less than the cost of producing new ones, and the need for affordable units remains strong, efforts should be directed at ensuring the long-term affordability of these units for low-income households.
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• Timeframe: Annually: staff will identify funds and work with nonprofits as necessary to secure at-risk units, where appropriate and feasible; Ongoing:
Monitoring
• Responsibility: Housing and Human Services Division
• Objective: The City proactively monitors units at risk of conversion due to expiring covenants and takes actions to ensure their long-term affordability.
Program 3.D Maintain An Acquisition And Rehabilitation Program As resources are available, the City shall continue to provide loan assistance to nonprofit affordable housing providers and work with providers to identify new funding sources for acquisition and rehabilitation throughout the city. As outlined in Program 2.B, the City shall adopt a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer to acquire existing private properties as they become available for purchase.
Program Background:
The City provides Housing Trust Fund loans to nonprofit housing providers to assist with the purchase and rehabilitation of existing rental properties occupied primarily by low-income households. The acquisition and rehabilitation of existing housing and conversion to affordable rental units preserve naturally occurring affordable housing while also ensuring housing stability for existing tenants by allowing them to remain in their units at deed-restricted affordable rents. • Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division; Santa Monica Housing Authority
• Objective: Protect existing residents by acquiring and rehabilitating existing housing.
Program 3.E Maintain A Low-Income Residential Repair Program The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the City.
Program Background:
The City implements the Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants; and the Owner-Occupied Rehabilitation Program for low- and moderate-income owners.
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Minor home modifications improve physical access for people with disabilities and seniors that assist with independent living. Modifications are funded through the City’s Human Services Grants Program using Community Development Block Grant (CDBG) funds. • Timeframe: by 2024
• Responsibility: Housing and Human Services Division; Santa Monica Housing Authority
• Objective: Rehabilitate 38 multi-unit dwellings and provide 20 minor home repairs.
Program 3.F Enhance Code Enforcement Response To Housing-Related Violations
The City shall continue to respond to residential building code violation complaints throughout the City. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day.
Program Background:
The Code Enforcement Division responds to complaints of violations of City building codes and in coordination with the Building and Safety Division, provides inspections and notices to property owners to bring their units into compliance. In the case of a residential building code violations that do not affect habitability, the City provides up to 30-days to correct the violation. If the work necessitates a building permit, the City provides up to 180 days to correct the violation (the life of the permit). In the case of substandard housing that affects habitability, the City requires the landlord to promptly commence the work to restore the unit(s) to a habitable condition and return tenants to their units through the Habitability Determination Form and Relocation Order and provide tenant protections (temporary relocation).
• Timeframe: Annual Ongoing
• Responsibility: Building and Safety Division, Code Enforcement Division, Housing and Human Services Division
• Objective: Require property owners to respond to Building Code violations and complete routine maintenance on their residential buildings.
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Program 3.G Maintain A Mandatory Seismic Retrofit Program The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle.
Program Background:
In March 2017, the City Council adopted a Seismic Retrofit Ordinance and the City implemented the Seismic Retrofit Program that proactively seeks to strengthen existing earthquake-vulnerable buildings and enhance the safety and security of their occupants. Nearly 2,000 commercial and residential buildings in the City were identified as potentially seismically vulnerable in need of possible structural improvement and are required to comply with the Program within established timeframes based on building types (20-year program overall). Ongoing seismic retrofit improvements to existing multi-unit residential buildings will help maintain the safety and structural integrity of the City’s aging housing stock. • Timeframe: Annual Ongoing
• Responsibility: Building and Safety Division
• Objective: Protect existing residents by ensuring the safety and structural integrity of existing residential buildings.
Program 3.H Information And Outreach For Property Owners Regarding Rehabilitation And Maintenance Of Housing Units
The City shall provide additional education and outreach to multi-unit property owners on available City programs to support continued rehabilitation, maintenance, repairs, and upgrades of their housing units. Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties.
Program Background:
Tenants in rent-controlled units who allege that their rental units need repairs or maintenance, or that their housing services have been reduced, may petition to have their monthly rent decreased.
In 2019, eighty decrease petitions were filed. Both the City and Rent Control Board co-sponsor an annual Maintenance of Residential Rental Property seminar and coordinate regarding relocation disputes, use of withdrawn properties, and maintenance and enforcement issues. Annual tenant and landlord forums also educate both groups on their rights and responsibilities including but not limited to available programs, resident qualifications, and benefits of program participation.
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• Timeframe: Annual Ongoing
• Responsibility: Rent Control Board
• Objective: Inform property owners regarding proper maintenance of residential units.
Program 3.I Right To Counsel Program
The City shall continue to implement a Right to Counsel pilot program and evaluate its overall effectiveness, program capacity, and long-term feasibility.
Program Background:
In April 2021, the City initiated a two-year pilot Right to Counsel program, an initiative to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This pilot program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. The program includes a contract with the Legal Aid Foundation of Los Angeles (LAFLA), the nonprofit law firm for low-income residents, to provide full-scope eviction defense services in which LAFLA attorneys will represent tenants in court. This partnership seeks to provide emergency support to low-income tenants in need of legal assistance. Under the City’s pilot program and Los Angeles County’s parallel program, StayHousedLA, LAFLA has already helped 40 Santa Monica tenants facing eviction obtain full-scope legal representation. Another 42 have received limited scope services. • Timeframe: Ongoing
• Responsibility: City Attorney’s Office
• Objective: Prevent the displacement of tenants by providing access to legal assistance and support for tenants facing eviction.
Program 3.J Restrict Conversion Of Existing Rental Housing To Condominiums
The City shall continue to regulate condominium conversions pursuant to SMMC Section 9.24.040.
The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory. Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data.
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Program Background:
Displacement of residents due to
economic pressure is one of the
main contributing factors to housing
segregation. Displacement and
gentrification are widespread in
Santa Monica with the Ellis Act and
Costa-Hawkins Rental Housing Act
allowing owners to either exit the rental
business and evict all tenants or raise
the rents of vacated rent-controlled
units. Restrictions on condominium
conversions are in place to ensure
that required noticing is provided to
tenants and that conversions can
only occur if there is a surplus of rental
housing inventory in the immediate
period before approval of a conversion.
Condominium conversions are currently regulated by SMMC Section 9.24.040. The Condominium Conversion ordinance sets out the conditions under which a condo conversion could be approved including:
1. Rent Control Board approval to remove units from the rental market
2. Tenants have been given required notice of intent to convert and to seek alternative housing
3. Preparation of a conversion report by City staff
4. Notice of any public hearings
5. Structural, electrical, fire and life safety, and plumbing systems are in good repair and maintenance
6. Findings as required by the Planning Commission including finding that the vacancy factor of rental housing units exceeds 5 percent of the total rental housing inventory for a period of 90 days prior to the date of approval.
• Timeframe: Ongoing
• Responsibility: City Planning Division
• Objective: Restrict loss of rental housing units to condominium conversions.
Conversion restrictions will continue to protect and retain older
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GOAL 4
A community that provides equitable housing access to all neighborhoods.
Program 4.A Zoning Ordinance Amendment To Permit Multiple-Unit Housing In Non-Residential Zones Where Not Currently
Permitted
The City shall amend the Zoning Ordinance, LUCE, and associated specific and area plans to add multi-unit housing as a permitted use in non-residential zones where housing is currently prohibited.
To promote the fair and equitable distribution of new housing opportunities across the City, land use regulations shall be amended to add multi-unit housing as a permitted use in areas where housing is currently prohibited. Land use regulations, FAR, and height (as indicated in Program 1.J) will be revised to allow housing in the three zones that currently do not allow housing such as the Office Campus, Industrial Conservation, and Creative Conservation Sector zones.
To promote fair and equitable housing opportunities throughout the City, the City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) including in areas that have historically not permitted or accommodated housing, to allow for higher maximum allowable FAR and height in the NC, IC, and OC zoning districts.
For the purposes of addressing environmental health considerations, the City shall amend the Zoning Ordinance to specify locations in the City where housing projects are required to conduct an air quality assessment and implement recommendations from the assessment.
Program Background:
When the LUCE was adopted in 2010, its core growth strategy was to encourage housing in close proximity to major transportation systems, such as the Metro Expo Light Rail and transit corridors, and to protect the City’s residential neighborhoods by discouraging development that would result in displacement of tenants. The housing incentives were balanced with a plan to support the City’s economic base by incentivizing retention of existing commercial and industrial space in select areas of the City to support existing and growing businesses. This growth strategy has resulted in new housing production largely in the Downtown and some limited areas on the boulevards, but it has also perpetuated the historic patterns of housing segregation that remain to this day. Although all of Santa Monica is considered a “high resource” area based on maps produced by the California Tax Credit Allocation Committee, there remain a handful of areas that provide little to no housing opportunities.
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• Timeframe: by October 15, 2022
• Responsibility: City Planning Division; City Attorney’s Office • Objective: Support the production of affordable housing and encourage the equitable production of housing across the City.
Program 4.B Facilitate The Development Of Housing On Surface Parking Lots Owned By Community Assembly Uses
In order to Affirmatively Further Fair Housing, the City shall adopt standards that support the production of affordable housing on surface parking lots owned by community assembly uses, including religious congregations, including allowing not more than 50% market-rate units to support the affordable housing, unlimited, density, no minimum parking requirements, an additional 33 feet of building height, and allowance for the primary community assembly use and related ancillary use, for the support or expansion thereof, on or above the ground floor.
Program Background:
AB1851 was passed in 2020 to remove
an important barrier to housing
construction on lands owned by a
religious institution. The law states that
a jurisdiction cannot deny a housing
project proposed by a religious
institution on the sole basis that it will
remove parking. Approximately seven
parcels with religious congregations,
which are classified in Santa Monica
as community assembly uses, have
large surface parking lots, have been
identified on the SSI, and are located
within high or highest resource areas.
During the outreach process of the Housing Element, many of these religious congregations have expressed interest in developing housing on their properties; however, the Zoning Ordinance development standards for these sites severely limits the housing potential of these sites. • Timeframe: by June 30, 2023
• Responsibility: City Planning Division
• Objective: Increase equitable access to all residential neighborhoods and incentivize affordable housing in areas that have historically excluded diverse housing opportunities.
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Program 4.C Provide New Housing Choices And Affordability In High Opportunity Areas Through Incentives For Additional ADUs In R1-Zone Neighborhoods
The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with Program 4.F. This would include allowing an additional ADU to be constructed if the ADU is deed restricted as a rental unit. As ADUs are naturally more affordable by design given their size, the program would help affirmatively further fair housing by helping to provide new housing choices and affordability in high opportunity areas of the City that are largely unaffordable to many people.
Program Background:
Historic practices like redlining and restrictive
covenants have perpetuated housing segregation
and hindered fair access to housing. Although
the City has been a leader in encouraging diverse
neighborhoods through fair housing, rent control
and tenant protections, predominantly homeowner
neighborhoods have accommodated very little
diversity in housing types reducing housing access
for even middle-income households and a large
percentage of Santa Monica workers. R1-zoned
neighborhoods make up approximately 35% of the
land area in the city but contain 13% of the housing
units in the city. In comparison, commercial zoning
comprises only 7% of the City’s land area but contains 15% of the housing units in the City.
The construction of new ADUs in recent years has increased housing opportunities in single -family zones, areas which have traditionally been out of reach for renters. The vast majority of new ADUs constructed or under development in the past 3 years have been in the City’s R1 (singleunit) neighborhoods, providing a valuable source of rental housing access in otherwise high cost neighborhoods. Under State law, properties are permitted to have one ADU and one JADU. This program will further allow one more ADU on single-unit dwelling parcels with the requirement that the additional third ADU be restricted to permanent rental housing. This program will incentivize the production of ADUs thus providing new housing choice and affordability in the high opportunity areas of the R1 neighborhoods.
• Timeframe: by June 30, 2023
• Responsibility: City Planning Division
• Objective: Increase equitable access to all neighborhoods by lowering barriers to housing access in areas that have historically excluded diverse housing opportunities.
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Program 4.D Right To Return Program
The City shall continue to implement a Right to Return Pilot Program and evaluate outreach strategies, applicant demand, the availability of historical documentation, verification processes, compliance with government legislation, and the administrative resources required to implement a broader longterm program. The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households.
Program Background:
In July 2021, the City initiated a Right
of Return Pilot Program that prioritizes
housing for the historically displaced
households in Santa Monica during the
1950s and 1960s due to urban renewal
policies. The pilot program implements
historical displacement policy by providing
housing access to former residents or their
descendants who were displaced by the
creation of the Civic Auditorium in the
Belmar Triangle neighborhood and the
I-10 freeway in the Pico neighborhood, both
of which disproportionately impacted lowincome communities and communities of color. Qualifying households will be placed
on the City of Santa Monica’s affordable
housing waitlist (Below Market Housing
waitlist) with Second Priority and will be referred to affordable housing providers as housing units become available.
• Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division
• Objective: Address the historical displacement of Santa Monica households which resulted from the development of the Civic Auditorium and I-10 freeway through the Pico neighborhood during the 1950s and 1960s that disproportionately impacted low-income communities and communities of color and displaced thousands of households living in Santa Monica.
Construction of the Civic Center Auditorium in 1957
Source: Santa Monica Public Library
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Program 4.E PROVIDE NEW HOUSING CHOICES AND AFFORDABILITY IN
HIGH OPPORTUNITY AREAS THROUGH INCENTIVES FOR
SB9 UNITS IN R1-ZONE NEIGHBORHOODS
The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. In addition, these SB9 units shall be required to be rented or sold. This will open up the possibility for property owners to construct up to 6 units through a multi-step process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F.
Program Background:
Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, predominantly homeowner neighborhoods have accommodated very little diversity in housing types reducing housing access for even middle-income households and a large percentage of Santa Monica workers. R1-zoned neighborhoods make up approximately 35% of the land area in the city but contain 13% of the housing units in the city. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City.
SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, is a state bill that requires cities to allow one additional residential unit onto parcels zoned for single-unit dwellings. Allowing homeowners proposing SB9 projects to also construct ADUs, particularly on larger parcels, will increase new housing opportunities in high opportunity areas and also promote place-based strategies for community revitalization by increasing housing opportunities in all areas of Santa Monica.
• Timeframe: June 30, 2023
• Responsibility: City Planning Division
• Objective: Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods
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Program 4.F ESTABLISH TARGET TO INCREASE HOUSING PRODUCTION IN R1 ZONES AND INCLUDE MID-CYCLE MONITORING
The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. • Timeframe: Assess progress by December 31, 2025
• Responsibility: City Planning Division
• Objective: Increase the number of net new housing units in R1 zones GOAL 5
Housing for persons experiencing homelessness.
Program 5.A Reduce The Number Of Homeless Individuals Living On The Streets Of Santa Monica Through The Provision Of A Range Of Housing Options, With An Emphasis On Affordable,
Permanent, Supportive Housing
The City shall continue to seek and leverage funds that contribute to the development of a range of permanent, supportive housing options, within and outside of Santa Monica. Focus case management and housing resources on the most chronic and vulnerable homeless individuals that have been identified on the City’s Homeless Service Registry. Continue to serve other priority homeless populations through City- funded programs. Continue strategies to reunite those not first-homeless in Santa Monica with family and friends in their home communities. Review City policies and practices that may contribute to homelessness.
Program Background:
Santa Monica has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. In March 2019, the City introduced the Four “Pillars” upon which the City’s homeless strategies are based; 1) preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities; 2) addressing the behavioral health needs of vulnerable residents; 3) maintaining equitable access to safe, fun, and healthy open spaces; and 4) strengthening regional capacity to address homelessness. These strategies have been implemented
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through interdepartmental and community partnerships that contributed to a sustained reduction in homelessness in the City’s downtown and beach areas, and helped contribute to an 8% local reduction in the City of Santa Monica’s annual Homeless Count in 2019.
On an annual basis, the City supports agencies that provide supportive services, emergency shelter, and transitional and permanent supportive housing beds to Santa Monica’s priority homeless populations. • Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division
• Objective: Continue to invest in and implement housing and supportive services to prevent and address the impacts of homelessness.
Program 5.B Low Barrier Navigation Centers As By-Right Use The City shall amend the Zoning Ordinance to allow Low Barrier Navigation Centers as a by-right permitted use in all non-residential zones permitting multi-unit uses.
Program Background:
Assembly Bill 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multi-unit uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a housing first, low-barrier, serviceenriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter and housing.
• Timeframe: December 31, 2023
• Responsibility: City Planning Division
• Objective: Ensure the City’s regulations and procedures are in conformance with State Law.
The Ocean Park Community Center (OPCC), an example of a Low Barrier Navigation Center in Santa Monica.
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GOAL 6
Provision of housing assistance and supportive programs and services to extremely low-, very low-, low-, and moderate-income households and households with special needs, families, seniors, and the homeless.
Program 6.A Enhance Housing Mobility By Maintaining Rental Housing Voucher Programs Throughout the City And Expand To
Assist All Persons With Disabilities
The City shall continue to operate strong rental housing voucher programs throughout the City and advocate for funding guidelines for Section 8 that are competitive for Santa Monica; and shall pursue additional funding to maintain and expand voucher programs, if possible. Review and update the Housing Authority Administrative Plan annually to ensure compliance with the latest HUD regulations and to provide flexibility to respond to tenants’ needs consistent with legal requirements. Utilize vouchers as a tool to prevent senior homelessness where eligible. When funding opportunities are available, expand the rental housing voucher programs to fill the gap between income levels and the cost of housing for persons with permanent disabilities, including persons with Developmental Disabilities.
Program Background:
The Santa Monica Housing Authority (SMHA) administers two types of rental assistance vouchers, tenant-based and project-based, across five different federal housing programs: Housing Choice Voucher (HCV); Continuum of Care (CoC); HOME Investment Partnerships Program (HOME); Veterans Affairs Supportive Housing (VASH), and Emergency Housing Voucher (EHV) programs. Tenant-based vouchers are allocated to specific individuals, which allow participants to choose where to lease rental housing, whereas project-based vouchers are allocated to specific properties rather than participants. In FY2021-21, the SMHA administered approximately 1,600 rental housing vouchers, including Section 8, Continuum of Care vouchers, HOME vouchers, and VASH vouchers. The HOME program targets rent-burdened households at-risk of becoming homeless and persons who have been homeless for at least a year. Of the 772 vouchers that were used, voucher households reside throughout Santa Monica’s multifamily neighborhoods, with no concentration in one zip code. Five properties in Santa Monica representing senior and supportive affordable housing with significant allocations of project-based vouchers are located in zip codes 90401 (Downtown), 90403 (WilshireMontana/Northeast) and 90405 (Ocean Park/Sunset Park) representing a total of 340 affordable housing opportunities.
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Distribution of Voucher Households 2017-2021 by Santa Monica Zip Code Tenant-Based
Vouchers
Project-Based
Vouchers
Total Rental
Housing Vouchers
90401 (Downtown)
Count 154 155 309
Percentage 31% 57% 40%
90402 (North of Montana)
Count 2 0 2
Percentage 0% 0% 0%
90403 (Wilshire-Montana/Northeast)
Count 44 102 146
Percentage 9% 37% 19%
90404 (Mid-City/Pico)
Count 178 0 178
Percentage 36% 0% 23%
• Timeframe: Annual Ongoing
• Responsibility: Santa Monica Housing Authority; Housing and Human Services Division
• Objective: Maintain voucher programs to ensure availability and choice of housing for households at all income levels.
Program 6.B Seek Funding Sources To Support Rental Assistance For Vulnerable Individuals And Households At-Risk Of
Displacement
The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle.
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Program Background:
The City monitors the availability of Federal, State, and County funding sources to support rental assistance programs on an ongoing basis. The City also undertook eviction prevention efforts to focus on keeping residents housed during the ongoing COVID-19 pandemic. The Legal Aid Foundation of Los Angeles (LAFLA) supported residents in maintaining housing through their general legal services program, which provides eviction defense services. Since April 2021, under the City’s Right to Counsel pilot program and County’s Stay Housed LA Program, LAFLA has provided 81 tenants facing eviction with legal representation. In FY2020-21 LAFLA’s general legal services program served 590 Santa Monica households utilizing $506,149 in Human Services Grants Program funding.
The City also created an enhanced communications campaign to inform renter residents and property owners about the State Rental Assistance program, Housing is Key, and to support with application completion. Educational efforts focus on multilingual outreach to the most vulnerable residents who may not have access to online information. Application support was provided by City staff who answered questions, ran a clinic, and connected residents with the State’s help center and established partner organizations. As of June 7, 2022, 2,207 Santa Monica households were served with an average assistance of $15,566 and $34,354,444 total funds paid.
In addition to the State Rental Assistance program, the City implemented the COVID Emergency Rental Assistance Program (ERAP) using $2,549,979 in federal Community Development Block Grant funds (CDBG) and General Funds of $251,535 to provide three months’ rent up to $5,000 to 640 households economically impacted by COVID. A total of 1,106 applications were submitted; 104 households did not qualify for or declined assistance, and an additional 362 households were not offered assistance due to lack of funding (of these 86 received assistance through the LA County program). Funding for program administration came from CDBG and the re-purposing of a County homelessness grant through the Westside Cities Council of Governments (WSCCOG).
The Los Angeles County Development Authority (LACDA) also administered a rental assistance program that opened in August 2020 to assist applicants throughout the County with a total of $133 million from the Coronavirus Aid, Relief, and Economic Security Act (CARES) and County General Funds. At the close of the program, 435 Santa Monica residents were awarded approximately $3.81 million in assistance through the County program.
• Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division
• Objective: Maintain housing stability for vulnerable individuals and households.
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Program 6.C Maintain And Expand The Preserving Our Diversity (Pod) Program
The City shall continue to operate the POD program and pursue additional funding to maintain assistance to seniors and evaluate expanding program assistance to other rent burdened residents vulnerable to displacement, if possible. The program shall ensure that POD subsidies do not result in an increase in rents. The City intends the POD Program to serve at least 150 participants within this Housing Element cycle.
Support measures that are not housing constraints to generate and allocate tax revenue for income assistance.
Program Background:
The City’s POD program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors to have a minimum amount of income remaining after rent is paid each month for food and medical expenses.
Currently, the program is available for qualifying long-term senior residents. In FY2020-21, the POD program served 196 low-income senior households providing an average monthly assistance of approximately $500 per month, allowing participants to age in place. Applications for POD are accepted both online and by mail, with assistance for those seeking a reasonable accommodation. • Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division
• Objective: Assist POD beneficiaries in achieving a basic needs budget.
Program 6.D Information And Outreach Coordination For Tenants And Landlords On Housing Programs And Resources
The City shall prioritize additional education and outreach to tenants and landlords throughout the City to increase awareness of federal and local housing programs and their rights and legal obligations, including Section 8 housing voucher program and anti-discrimination regarding income source.
The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational webinars per year.
Program Background:
Rental housing vouchers provide extremely low- and very low-income households with rent subsidies to bridge the gap between what the household can afford and market rents, although there is a limit to the subsidy amount. The Santa Monica Housing Authority has collaborated with owners of senior
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housing developments to obtain hundreds of new vouchers allocated to the senior developments allowing property owners to fund rehabilitation and maintenance and ensuring long-term affordability for the existing tenants. The Municipal Code and State law require rental property owners to accept Section 8 or housing vouchers and prohibit discrimination against an applicant based on source of income, including housing vouchers. Comments from tenants and landlords during the community engagement for this Housing Element update indicate that there continues to be lack of awareness of the availability of housing programs that could benefit both groups. • Timeframe: Ongoing subject to additional staffing resources • Responsibility: Housing and Human Services Division
• Objective: Raise awareness of housing assistance programs and tenant and landlord rights and responsibilities.
Maintain A Community Development Grant Program
The City shall continue to fund supportive services that serve the priority homeless populations, striking a balance between existing programs that have demonstrated effectiveness and national best practices that are consistent with the City’s adopted Action Plan to Address Homelessness in Santa Monica.
Program Background:
Santa Monica currently provides funding to 19 nonprofit human service and housing development organizations supporting different programs through the Community Development Grant Program.
These programs serve, in part, to assist homeless persons, very low–, and low-income households, and special need populations. Funds are provided through a broad array of funding sources including but not limited to the City’s General Fund, HOME, and Community Development Block Grant Fund.
The Rent Control Department hosts several workshops and seminars for tenants and landlords throughout the year.
Program 6.E
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• Timeframe: Annual Ongoing
• Responsibility: Housing and Human Services Division
• Objective: Maintain a grant program to fund-programs that service priority homeless populations, lower-income households, and special needs populations.
Program 6.F Provide Tenant Relocation Assistance
The City shall continue to implement the Tenant Relocation Assistance program; periodically review existing City policies and ordinances and recommend modifications if deemed necessary, including but not limited to, additional support in locating new housing for displaced residents upon relocation.
The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica.
Program Background:
The City’s Municipal Code provides several tenant relocation programs to protect tenants living in rent-controlled units, with certain exceptions. When a unit is withdrawn from the housing stock, or the landlord recovers possession of a unit, landlords are required to pay a relocation fee for each unit based upon the size of the unit. An additional fee is required if one or more of the tenants is a senior, disabled, or a minor. In lieu of providing financial relocation assistance, the landlord may provide actual physical relocation if the new unit is comparable to the original unit. • Timeframe: Annual Ongoing
• Responsibility: City Attorney’s Office, Housing and Human Services Division, Rent Control Board
• Objective: Provide displaced tenants with cash-based relocation assistance.
Program 6.G Maintain A Temporary Relocation Program
The City shall continue the Temporary Relocation Program, including program oversight and enforcement, and coordination in providing accommodations to minimize impacts to residents including emergency hotel vouchers for tenants who have been ordered to vacate their units by the City for code violations, safety improvements, or maintenance. The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated.
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Program Background:
This program is designed to provide housing for persons temporarily displaced as a result of repairs to their dwelling unit due to health and safety violations or to comply with mandatory programs such as the Seismic Retrofit Program.
• Timeframe: Annual Ongoing
• Responsibility: Building and Safety Division, Housing and Human Services Division • Objective: Provide housing for tenants temporary displaced from their units due to required maintenance.
Program 6.H Maintain Reasonable Accommodations To Ensure Equal Opportunity For Housing
The City shall maintain and continue to support reasonable accommodations to ensure equal housing opportunities, consistent with fair housing laws.
Program Background:
With the anticipated demographic changes resulting in an aging population and increased interest in enhancing opportunities to age in place and live independently, the Zoning Ordinance includes a reasonable accommodation procedure to enable persons with a disability to request an accommodation from land use and zoning regulations, policies and practices as needed to provide those individuals with an equal opportunity to use and enjoy a dwelling, consistent with fair housing law. • Timeframe: Ongoing
• Responsibility: City Planning Division
• Objective: Provide regulatory relief to enable housing access for disabled persons.
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GOAL 7
Eliminate housing discrimination on the basis of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, national origin, ancestry, familial status, income level, source of income, disability, veteran or military status, genetic information, or other such characteristics.
Program 7.A Maintain Fair Housing Enforcement And Outreach Programs
The City shall continue to implement fair housing programs. The City shall educate landlords about discrimination and educate the real estate community on the necessity of ensuring that their practices meet the objectives of the fair housing laws. The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide tenant application assistance and support to special needs populations including seniors, persons with disabilities, and individuals transitioning from institutional settings and individuals who are at risk of institutionalization.
Program Background:
The City Attorney’s Office, through its Public Rights Division (PRD), along with other government agencies, enforces federal, state and local fair housing laws. The PRD has an in-house attorney with expertise in fair housing law and a Spanish-speaking community liaison who works with the attorney.
The PRD investigates discrimination complaints and offers education and programs to residents on their rights and responsibilities under the fair housing laws, and takes complaints involving housing discrimination based on all protected classes, but primarily on disability, family status, source of income, and race. Most of the cases are resolved informally, using demand letters, calls, and meetings to either to persuade the need for a change in what the landlord is doing or to conclude that there is insufficient evidence of a fair housing violation However, if there is sufficient evidence of ongoing fair housing violations and the landlord has refused to correct the problem, then the PRD often files a lawsuit in court to enforce the fair housing laws.
Since 2007, the PRD hosts a Fair Housing Workshop twice a year. The workshop covers several topics, including reasonable accommodations for tenants with disabilities, the City’s Right to Return program, pandemic-related issues in fair housing, and source-of-income discrimination laws which protect Section 8 voucher-holders and users of rental assistance. All owners, property managers, attorneys, social-service providers, and tenants are invited to attend, free of charge. Over the years, hundreds of tenants and housing providers have attended.
The PRD’s workshops continued even through the pandemic, with a switch to virtual settings. The
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City has also made fair housing presentations to other local and regional groups. Just since April 2020, the City presented or even co-hosted housing rights events sponsored by Santa Monica Rent Control Board, the Legal Aid Foundation of Los Angeles, Western Center for Law & Poverty, Santa Monicans for Renters’ Rights, Fair Housing Council of San Diego, ACLU of Southern California, WISE & Healthy Aging, St. Joseph’s Center, and the Santa Monica Committee for Racial Justice. • Timeframe: Ongoing
• Responsibility: City Attorney’s Office
• Objective: Education of tenants and landlords of their rights and responsibilities under fair housing laws.
Program 7.B Provide Tenant/Landlord Mediation And Legal Services The City shall continue to support tenant/landlord mediation and legal services assistance.
Program Background:
The Santa Monica Rent Control Board also mediates disputes between tenants and property owners that arise from rent control law. The City has also partnered with the Status Institute for Dispute Resolution at Pepperdine University School of Law to provide mediation services to help resolve landlord tenant for Santa Monica residents, free of charge. The Housing and Human Services Division funds the Los Angeles Legal Aid Foundation to provide legal services related to housing to low-income Santa Monica residents. Referrals are also made to local dispute resolutions services. • Timeframe: Ongoing
• Responsibility: City Attorney’s Office; Rent Control Board; Housing and Human Services Division
• Objective: Provide tenant/landlord dispute resolution services.
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Program 7.C Maintain The Anti-Discrimination And Tenant Protection Program
The City shall continue to prevent discrimination, tenant harassment, and unlawful evictions through monitoring and enforcing of “just cause” eviction protections, and continue to provide fair housing services through the Public Rights Division of the Santa Monica City Attorney’s Office. The City shall review current laws and recommend any needed modifications to ensure protection of tenants to the maximum extent possible.
Program Background:
Santa Monica has long maintained anti-discrimination protections, which among other prohibitions, prevents a tenant from being evicted if the eviction is based on the tenant’s familial status, including tenant’s status of being married or having children. The Public Rights Division (PRD) of the Santa Monica City Attorney’s Office handles complaints, answers questions about possible violations of the Fair Housing laws in Santa Monica and investigates possible fair housing violations. • Timeframe: Ongoing
• Responsibility: City Attorney’s Office; Rent Control Board; Housing and Human Services Division
• Objective: Protect existing tenants from harassment and unlawful eviction.
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A. Quantified Objectives
Pursuant to Government Code Section 65583(b), the City has developed quantified objectives for housing production, housing rehabilitation, and housing assistance as required by State law. The following sets forth these objectives for the 2021–2029 planning period.
1. New Construction Objectives
The City of Santa Monica was allocated 8,895 units, of which 6,168 units must be affordable, in the 2021-2029 Regional Housing Needs Assessment (RHNA) adopted by the Southern California Association of Governments (SCAG) and certified by the State Department of Housing & Community Development in March 2029.
As one of the required components of a Housing Element, State law [Government Code Section 65583(b)] requires the following:
1. A statement of the community’s goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing.
2. It is recognized that the total housing needs identified pursuant to subdivision (a) [i.e., the RHNA] may exceed available resources and the community’s ability to satisfy this need within the content of the general plan requirements. The quantified objectives need not be identical to the total housing needs. The quantified objectives shall establish the maximum number of housing units by income category, including extremely low income, that can be constructed, rehabilitated, and conserved over a five-year time period.
The City’s success in producing housing units that are deed-restricted to be affordable for the 5th Cycle Housing Element has been made possible by public assistance through the City’s Housing Trust Fund, inclusionary units required by the City’s Affordable Housing Production Program, inclusionary units negotiated in development agreements, and pursuit of new funding resources. The lack of a significant and consistent funding source for affordable housing coupled with high land and construction costs in Santa Monica makes it unrealistic that the City will be able to achieve its 6th Cycle RHNA for affordable housing units. Funding to produce all of the affordable units in Santa Monica’s RHNA allocation would likely continue to require a mix of inclusionary units and public assistance (i.e. any combination of federal, state, county, and tax credits). Even on City-owned land, the funding gap is estimated at approximately $152,000 that would need to be filled by sources other than the City. For privately-funded inclusionary units, the estimated cost to a developer is approximately $480,000.
Figure 5-1 presents Santa Monica’s RHNA along with the City’s new construction objectives by income level. The quantified objective represents a level that the City believes is reasonable given the uncertainty of available funding resources from the State and other sources. The City Council has prioritized funding and land use policies to develop affordable housing.
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Figure 5-1: RHNA vs. Quantified Objective
Household Income
Category RHNA % of Total Quantified Objective % of Total Very Low 2,794 31% 1,116 16%
Low 1,672 19% 654 10%
Moderate 1,702 19% 479 7%
Above Moderate 2,727 31% 4,459 67%
Total 8,895 6,798
Source: City of Santa Monica Community Development Department The goal of 6,798 units can be achieved based on current approved and pending projects, zoning standards, use of City-owned land, and incentives for ADU production. The lower quantified objectives reflect the lack of public financing available for affordable housing. Even with maximizing affordable housing on City-owned sites and the City’s inclusionary requirements from the AHPP and DCP, providing 69% of the future units as affordable will be difficult.
The quantified objective aims for 33% of units produced to be affordable to low and moderate income households. This is in excess of the requirement set forth in the City’s Proposition R (passed in November 1990). Proposition R specifies that at least 30% of all new multifamily-residential housing constructed in the city on an annual basis be permanently affordable to low and moderate-income households with at least 50% of the newly constructed units required to be permanently affordable to low-income households.
2. Housing Rehabilitation and Conservation Objectives
Housing Rehabilitation programs are important for maintaining the integrity of existing housing stock, preventing displacement of existing residents, preserving the overall quality of neighborhoods, and contributing to a higher quality of life.
With respect to housing conservation, the City provides rehabilitation assistance through two main programs:
• The Residential Rehabilitation Program for owners of multifamily rental properties occupied by low- and moderate-income tenants
• The Owner-Occupied Rehabilitation Program for low- and moderate-income owners (typically used for mobile-home owners).
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The City of Santa Monica’s goal for the Housing Element planning period is to support and fund the rehabilitation of 38 units of multi-family and provide 20 minor home repairs, as shown in Figure 5-2. A new program has been added for this Housing Element based on the analysis of affordable housing units with covenants that expire, putting them potentially at risk of losing their affordability.
While the City has focused its efforts in recent years on new construction, acquisition and rehabilitation continues to be an important tool for conserving existing rental housing. The housing is restricted as affordable housing for a period ranging from 55-80 years. Such units were not ‘counted’ toward fair share housing production, but are consistent with the City’s policies for preserving affordable housing units. During the last Housing Element period (2014-2021), the City invested more than $33 million in the acquisition and rehabilitation of existing rental housing, creating four projects with 88 units for very-low and low-income households.
Available funding continues to be a significant issue to support this program’s capacity at present levels. The Housing Plan therefore reflects a reduced quantitative objective for the acquisition and rehabilitation of 40 housing units affordable to very-low income households over the next eight years (Figure 5-2). The City will continue to seek funding sources to maintain this program and exceed the objective.
The City’s housing and supportive services supports long-term residency and housing affordability.
As outlined in the next section, the City has an aggressive program for funding housing and supportive services to special needs populations. These supportive programs help to conserve housing units in that rental/housing assistance, in the form of financial support and legal support for tenants against eviction, assist tenants in maintaining housing, prevent resident displacement, and preserve housing stock. Accordingly, an estimated number of housing vouchers and qualifying tenants for supportive services are reflected as “units” in Table 5-2 under the conservation objective:
• The Preserving Our Diversity (POD) Program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors. It is estimated to include at least 150 participants within the next housing cycle.
• Rental assistance voucher programs include Section 8, Continuum of Care, HOME Tenant-Based Rental Assistance (TBRA) vouchers, and Veterans Affairs Supportive Housing. The City will continue to provide an estimated 1,600 housing vouchers for qualified residents.
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• The City’s Right to Counsel Program is an initiative to provide legal assistance and support for tenants facing eviction, particularly amid the COVID-19 pandemic. This pilot program is available to Santa Monica tenant households whose income is at or below 80% of the County’s Area Medium Income (“AMI”), and facing eviction attempts by their landlord. Maintaining housing for low-income residents also contributes to the conservation of existing units. Assuming the current two-year pilot program will be renewed regularly and annual funding remains consistent over the next 8 years, the goal of the City is to provide assistance to an estimated 210 participants within the next housing cycle.
Figure 5-2: 2021-2029 Housing Rehabilitation and Conservation Quantified Objective Income
Category
Rehabilitated Units Conservation Units
Definition Multi-Family
Rehabilitation
Minor
Home
Repairs
Acquisition
&
Rehabilitation
POD
Rental
Assistance
Vouchers
Right to
Counsel
Very
Low
0-50% of
County
MFI
19 10 40 150 1,600
0 Low
51 to 80%
of County
MFI
19 10 0 0 0 210
Moderate
81 to 120%
of County
MFI
0 0 0 0 0 0
Upper
Over 120%
of County
MFI
0 0 0 0 0 0
Totals 38 20 40 150 1,600 210
58 2,000
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3. Housing and Supportive Services
The City of Santa Monica has an aggressive program for funding housing and supportive services to special needs populations. These include households with very low or extremely low incomes, persons with disabilities, large families, seniors, the homeless, and other persons in need of assistance. The City’s goals for housing assistance and supportive services during the 2021-2029 Housing Element period, contingent upon the availability of adequate funds and annual City Council approval, are:
• Rental Assistance Vouchers: Continue to provide about 1600 vouchers, including Section 8, Continuum of Care, HOME Tenant-Based Rental Assistance (TBRA) vouchers, and Veterans Affairs Supportive Housing vouchers.
• Homeless Services: Focus efforts on the priority populations defined in the Action Plan for Addressing Homelessness in Santa Monica:
o The long-term chronic and vulnerable of the homeless population living on the streets of Santa Monica, including homeless veterans
o Persons whose last permanent address is in Santa Monica o Vulnerable members of Santa Monica’s workforce
o High users of local first responder services
• Regional Partner: Continue to be an active partner in finding regional solutions to the problem of homelessness.
• Health Care for Low Income Persons: Provide primary health care for over 2,700 lowincome Santa Monica residents annually. • Legal Assistance: Provide legal advice and referrals to over 700 low-income Santa Monica residents in the areas of housing, government benefits, and family-law issues annually.
• Senior and Disabled Services: Support and fund a variety of services for senior and disabled individuals, including:
o Provide paratransit services for approximately 2,200 seniors and persons with disabilities annually. This includes providing approximately 1,400 one-way, escorted trips for people who need extra assistance, as well as limited afterhours taxi service.
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o Provide a range of health and mental health services, including health screenings, primary medical care, health education, peer counseling (individual, group, and family), caregiver services, and care coordination o Provide intensive care management services primarily to low-income Santa Monica seniors that include in-home assessments, purchase of services necessary to maintain the client in his/her home, benefits assistance, referrals to other agencies, and close monitoring of clients.
o Provide care management and other support services in conjunction with the Santa Monica Police Department’s efforts to address elder abuse. o Through the non-profit WISE & Healthy Aging (WISE) Diner Meal Program, provide a well-rounded lunch to older adults at three City sites. Boxed meals were provided via pickup or delivery while COVID-19 restrictions were in place. o Provide home-delivered meals to approximately 300 home-bound seniors and persons with disabilities annually. With COVID-19, the need for home-delivered meals increased significantly, with about 650 individuals having accessed this service.
o Provide ongoing operating support for WISE’s Adult Day Care Center serving frail seniors, including seniors with Parkinson’s and Alzheimer’s Disease. o Provide expanded healthy living and arts programming, and opportunities for socialization for older adults with linkages to supportive services, through the consolidation of services in a one-stop facility.
• Housing Modifications for Individuals with a disability: Continue to provide funding to the Disability Community Resource Center, which provides home modifications to low-income households that include a person with a disability. Modifications include the installation of grab bars, nonslip bath mats, ramps, shower benches, and toilet seat hand rails, as well as larger projects such as stair lift installations. Provide assistance to approximately 15 individuals annually.
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Glossary of Terms and Acronyms
1. ADU: Accessory Dwelling Unit
An attached or detached residential dwelling unit that provides complete independent living facilities for one or more persons and that is located on a parcel with a proposed or existing primary single-unit or multi-unit dwelling.
JADU: Junior Accessory Dwelling Unit
A dwelling unit that is no more than 500 square feet in size and is contained entirely within an existing or proposed single-unit dwelling.
2. AFFH: Affirmatively Furthering Fair Housing
Taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.
3. AHO: Affordable Housing Overlay
Program 2.A that would amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in targeted areas of the City such as the Downtown, Bergamot area, and the immediate area around the 17th Street station.
4. AHPP: Affordable Housing Production Program (SMMC 9.64) Requires developers of market rate multi-family developments to contribute to affordable housing production and thereby help the City meet its affordable housing need.
5. FAR: Floor Area Ratio
The ratio of the total floor area of all buildings on a parcel to the total area of the parcel.
6. HCD: California Department of Housing and Community Development
7. HUD: U.S. Department of Housing and Urban Development
8. LUCE: Land Use and Circulation Element
Key components of the City’s General Plan establishing the City’s vision, goals, and long-term framework for the City’s future physical development.
9. QO: Quantified Objective
Estimated number of units likely to be constructed, rehabilitated, or conserved/preserved by income level during the upcoming 6th housing cycle. After the City identifies housing needs, surveys land and financial resources, analyzes constraints, and develops appropriate programmatic and policy responses that reflect the community’s unique needs and circumstances, it then sets quantified objectives, a target goal for the City to achieve based on needs, resources, and constraints.
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10. RHNA: Reginal Housing Needs Assessment
RHNA is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. RHNA quantifies the need for housing within each jurisdiction during the upcoming 6th housing cycle between October 2021 through October 2029.
11. SDB: State Density Bonus
State law that allows a density increase of residential units based on a specified percentage of affordable units provided in a proposed project.
12. SSI: Suitable Sites Inventory
An inventory of land suitable and available for residential development to meet the locality’s regional housing need by income level.
Affordability Levels
13. ELI: Extremely-Low Income
A household whose gross income does not exceed 30% of the area median income.
14. VLI: Very-Low Income
A household whose gross income does not exceed 50% of the area median income.
15. LI: Low-Income
A household whose gross income does not exceed 80% of the area median income.
16. Moderate-Income:
A household whose gross income exceeds the maximum income for an 80% income household and whose gross income does not exceed 120% of the area median income.
Zoning Districts, Area Plans, and Neighborhoods
17. R 1: Single-Unit Residential District
Areas for single-unit housing on individual parcels at densities of one unit plus one accessory dwelling unit (ADU) and one junior accessory dwelling unit (JADU) per parcel.
18. R2: Low Density Residential District
Areas for a variety of low-density housing types. These include single-unit housing, duplexes, triplexes, low-scale multi-unit housing, ADUs, etc.
19. MUBL: Mixed-Use Boulevard Low District
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20. MUB: Mixed-Use Boulevard District
21. GC: General Commercial
22. NC: Neighborhood Commercial District (Main Street, Ocean Park Blvd, Pico Blvd, Montana Ave)
23. IC: Industrial Conservation
24. OC: Office Campus
25. HMU: Healthcare Mixed Use
26. OF: Oceanfront District
27. DCP: Downtown Community Plan
o LT: Lincoln Transition
o NV: Neighborhood Village
o BC: Bayside Conservation (Promenade)
o BC: Bayside Conservation (2nd & 4th Streets)
o TA: Transit Adjacent
o OT: Ocean Transition
o WT: Wilshire Transition
28. BAP: Bergamot Area Plan
o BTV: Bergamot Transit Village
o MUC: Mixed-Use Creative
o CAC: Conservation: Arts Center
o CSC: Conservation: Creative Sector
29. NOMA: North of Montana Neighborhood
30. Wilmont: Wilshire-Montana Neighborhood
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Packet Pg. 619 Attachment: Housing Element (Chapters 1-5) Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E:
Constraints on Housing
● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ●● ● ● ● ● ● ●●● ● ● ● ● ●
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Packet Pg. 620 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Table of Contents
INTRODUCTION...................................................................................................................................................................... 4 A. GOVERNMENTAL CONSTRAINTS........................................................................................................................ 4
1. Land Use Controls.................................................................................................................................................... 4 a. LandUse andCirculationElement............................................................................................................. 5 b. Zoning Ordinance .............................................................................................................................................. 8 i. Affordable Housing......................................................................................................................................14 ii. Affordable Housing Production Program ........................................................................................14 iii. Community Benefits ...................................................................................................................................15 iv. Parking Requirements................................................................................................................................15 v. State Density Bonus.....................................................................................................................................17 c. Downtown Community Plan .......................................................................................................................18 d. Bergamot Area Plan ........................................................................................................................................21 e. Civic Center Specific Plan............................................................................................................................23 f. Local Coastal Program .................................................................................................................................24
2. Zoning for a Variety of Housing Types ........................................................................................................24 a. Accessory Dwelling Units /Junior Accessory Dwelling Units ......................................................27 b. Emergency Shelters........................................................................................................................................30 i. Capacity for Emergency Shelters........................................................................................................31 c. Employee Housing...........................................................................................................................................32 d. Farmworker Housing......................................................................................................................................32 e. Group Residential.............................................................................................................................................32 f. Low Barrier Navigation Centers ...............................................................................................................33 g. Manufactured Homes and Mobile Home Parks................................................................................33 h. Residential Facilities ........................................................................................................................................34 i. Single-Room Occupancy Housing..........................................................................................................35 j. Supportive/Transitional Housing..............................................................................................................36
3. Zoning Regulations and Practices for Persons with Disabilities.....................................................37 a. Definition of a Family.......................................................................................................................................37 b. Definition of Disability .....................................................................................................................................38 c. Reasonable Accommodation....................................................................................................................38
4. Building Codes and Code Compliance ......................................................................................................39 a. Building Code Implementations ...............................................................................................................39 b. Local Amendments.........................................................................................................................................40 c. Compliance and Enforcement..................................................................................................................42
5. On- and Off-Site Improvements....................................................................................................................42
6. Entitlement and Development Impact Fees ............................................................................................43
7. Entitlement and Permit Processing..............................................................................................................48 a. Processes and Thresholds...........................................................................................................................48 b. Ministerial Approvals.......................................................................................................................................49 i. Administrative Approvals ........................................................................................................................49 ii. Building Permit Only Projects ................................................................................................................50
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Packet Pg. 621 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) c. Discretionary Approval..................................................................................................................................50 i. Development Review Permit.................................................................................................................50 d. Architectural Review Board........................................................................................................................52 e. Use Permits and Other Processes............................................................................................................53 i. Conditional and Minor Use Permits.....................................................................................................53 ii. Subdivision Maps..........................................................................................................................................55 f. State Law..............................................................................................................................................................56 i. Senate Bill 330 ...............................................................................................................................................56 ii. Senate Bill 35..................................................................................................................................................57 iii. Housing Accountability Act....................................................................................................................57
8. Local Measures, Propositions, Rent Control Law, and Ordinances.............................................58 a. Santa Monica City Charter Section 615.................................................................................................58 b. Rent Control ........................................................................................................................................................59 i. Vacancy Decontrol.....................................................................................................................................60 ii. Just Cause Eviction.....................................................................................................................................60 iii. Tenant Harassment Protections .........................................................................................................62 iv. Relocation Assistance...............................................................................................................................62 v. Rent Control Dispute Resolution..........................................................................................................63 c. State of California, Article 34......................................................................................................................64 d. Home Sharing (Short-Term Rental) Ordinance...............................................................................65 e. Residential Leasing Requirements Ordinance..................................................................................66 f. City Anti-Discrimination Ordinances .....................................................................................................67 i. Sexual Orientation or Domestic Partnership.................................................................................67 ii. Persons Living with AIDS...........................................................................................................................67 iii. Families with Children ...............................................................................................................................67 g. Rent Control Bootleg Unit Ordinance.....................................................................................................68 h. Water Neutrality Ordinance.......................................................................................................................68 B. NON-GOVERNMENTAL CONSTRAINTS.........................................................................................................70
1. Construction Costs ...............................................................................................................................................70
2. Land Costs and Availability................................................................................................................................71
3. Availability of Financing.......................................................................................................................................71
4. Requests for Housing Development at Reduced Densities..............................................................72
5. Length of Time Between Project Approval and Applications for Building Permits ..............72
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Packet Pg. 622 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-4
INTRODUCTION
The City of Santa Monica has consistently placed the provision of adequate and affordable housing for all residents as one of its primary goals. However, many factors can encourage or constrain the development, maintenance, and improvement of housing including governmental, market, construction, and infrastructure constraints. Pursuant to Government Code Section 65583(a)(5-6), this appendix identifies potential governmental and nongovernmental constraints and analyzes the extent to which the City can mitigate the negative impacts of these constraints where possible. A thorough understanding of the current constraints to housing development can help to create appropriate policy responses to mitigate constraints and make it easier and more affordable to develop housing.
A. GOVERNMENTAL CONSTRAINTS
Governmental policies and regulations can result in both positive and negative effects on the availability and production of housing. This section, as required by Government Code Section 65583(a)(5), describes and evaluates City policies and regulations that could potentially constrain the City’s ability to achieve its housing goals. Potential constraints to housing include land use controls (through General Plan policies and zoning regulations), development standards, infrastructure requirements, development impact fees, and development approval processes. While government policies and regulations are intended to serve public objectives and further the public good, the City of Santa Monica recognizes that its actions can potentially constrain the availability and affordability of housing to meet the community’s future needs. The City has implemented several measures, and proposes additional programs, to streamline the approval process and remove barriers to all types of housing throughout Santa Monica as described in this section.
1. Land Use Controls
Land use controls, such as use regulations and development standards, have the most immediate impact on the location and construction of new housing. Below is a description of the various plans, documents, and other controls that set forth the goals, policies, and standards that affect both where various types of housing can be located in the City [see Section A(2) below] as well as the development standards and requirements that shape housing developments. Pursuant to Government Code Section 65940.1(a)(1)(B), all documents and standards summarized below can be found on theCity’s Community Development Department website.
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Packet Pg. 623 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) E-5 City of Santa Monica 2021-2029 Housing Element
a. Land Use and Circulation Element
Santa Monica adopted its General Plan Land Use and Circulation Element (LUCE) in 2010 (subsequently updated in 2015 with the Zoning Ordinance update, 2017 with the adoption of the Downtown Community Plan, and 2020 with the revisions to housing process thresholds) which substantially revised the City’s land use policies, goals,and standards in non-residential zones but generally maintained the status quo in the city’s traditionalresidential neighborhoods. The overarching goal of the LUCE is to create significant new additional housing opportunities within transit-served areas in a manner that provides more affordable options, enhances sustainability, creates complete neighborhoods, and provides easy access to local services.
Additionally, the LUCE established policies to preserve the existing pattern of uses for the protection and long-term conservation of established neighborhoods. To accomplish these goals, the LUCE implemented a variety of strategies including, but not limited to the following:
• Encourage the creation of new housing in selected transit-accessible areas such as Downtown, Bergamot, and along the City’s boulevards.
• Established Activity Center Overlays, which would provide opportunity to promote the creation of mixed-use gathering areas at transportation crossroads on parcels of sufficient size offering goods and services for the neighborhood, convenient transit access, and unique urban spaces. Each Activity Center relied upon cooperation from multiple property owners to consolidate large parcels, an area plan, and a development agreement for each individual project.
• Establish a Neighborhood Conservation Strategy to promote the protection of housing in existing neighborhoods, much of which is under rent control, strengthen standards for demolition, and redirect growth to appropriate locations along transit corridors and in the vicinity of the Metro E (formerly Expo) light rail stations. • Establish a maximum base height for ministerial project review and require projects exceeding the base height to incorporate community benefits, such as additional affordable housing.
The LUCE established 17 land use designations, as shown in Map E-1, grouped into the following five broad categories:
• Neighborhoods
• Boulevards
• Mixed Use Centers
• Employment and Commerce
• Community and Public Uses
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Packet Pg. 624 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-6
Map E-1 LUCE Land Use Designations
The LUCE encouraged the expansion of housing opportunities into new areas of the City with residential uses permitted in all but three (Industrial Conservation, Office Campus, and Parks and Open Space) of the 17 land use designations. While the implementing Zoning Ordinance established specific development standards, the LUCE set forth standards for building height, densities (in neighborhood designations),andintensities that establish the outer parameters for zoning. The LUCE does not specify maximum densities for non-neighborhood designations.
Instead, density is regulated through building intensities such as Floor Area Ratio (FAR) and height which has provided flexibility to housing developments. In most land use designations, the LUCE also established a tiered system that affords additional building height and density (through traditional means or through an increase in FAR depending on the designation) beyond the base (Tier 1) standards for projects that provide community benefits or that are 100% affordable housing. However, these establishedouter parameters for Tier 1 projects, which were established in 2010, currently present constraints on the City’s ability to meet its updated housing goals due to low FARs and building heights that were demonstrated to be infeasible in studies conducted in the spring of 2021. Therefore, Housing Element Programs 1.F and 1.J propose to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production citywide.
Figure E-1 presents the 17 LUCE land use designations and summarizes the base (Tier 1) height and density/intensity standards and the Tier 2 and 3 standards for projects which provide identified community benefits and/or100% affordable housing developments.
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Packet Pg. 625 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) E-7 City of Santa Monica 2021-2029 Housing Element
Figure E-1 LUCE Land Use Designation –Height and Density/Intensity Parameters LUCE Land Use
Designation
Max. Building Height and Density/Intensity
Tier 1 Tier 2 Tier 3 100% Affordable
Housing
Neighborhoods
Single-Unit Housing No tiers. Height: 28’ – 35’ depending on parcel size, dimensions, and location; Density: 1 du/parcel
Low Density Housing No tiers. Height: 30’ – 40’ depending on parcel location; Density: 29 du/acre
Medium Density Housing 30’ / 29 du/acre 40’ / 35 du/acre - 40’ / 35 du/acre High Density Housing 30’ / 35 du/acre 45’ / 48 du/acre - 45’ / 48 du/acre Boulevards
Mixed Use Boulevard
Low
32’ / 1.5 FAR
36’ / 1.5 FAR* 36’ / 1.75 FAR 47’ / 2.0 FAR 47’ / 2.0 FAR Mixed Use Boulevard
(100% residential above
ground floor)
32’ / 1.5 FAR
39’ / 1.5 FAR*
50’ / 2.25 FAR 55’ / 2.75 FAR 55’ / 2.75 FAR
DCP – East Side of
Lincoln Blvd:
50’ / 2.25 FAR
-
DCP – East Side of
Lincoln Blvd:
60’ / 2.75 FAR
DCP – West Side
of Lincoln Blvd:
60’ / 2.75 FAR
-
DCP – West Side of
Lincoln Blvd:
70’ / 3.25 FAR
DCP – Wilshire
Blvd West of
Lincoln Blvd:
50’ / 2.25 FAR
- -
Mixed Use Boulevard
(All Other Projects)
32’ / 1.5 FAR
35’ / 1.5 FAR*
45’ / 2.25 FAR 55’ / 2.75 FAR 55’ / 2.75 FAR
DCP – East Side of
Lincoln Blvd:
40’ / 1.75 FAR
-
DCP – East Side of
Lincoln Blvd:
55’ / 2.75 FAR
DCP – West Side
of Lincoln Blvd:
50’ / 2.25 FAR
-
DCP – West Side of
Lincoln Blvd:
55’’ / 3.25 FAR
DCP – Wilshire
Blvd West of
Lincoln Blvd:
40’ / 1.75 FAR
-
DCP – Wilshire Blvd
West of Lincoln Blvd:
40’ / 1.75 FAR
General Commercial
(Santa Monica Blvd)
32’ / 1.25 FAR 35’ / 1.5 FAR - 35’ / 1.5 FAR
General Commercial
(Lincoln & Pico Blvds)
32’ / 1.5 FAR
36’ / 1.5 FAR*
36’ / 1.75 FAR
2.0 FAR*** - 40’ / 2.0 FAR
Mixed Use Centers
Neighborhood
Commercial
32’ / 1.5 FAR
1.75 FAR** - -
32’ / 1.75 FAR
40’ / 2.0 FAR (Pico
Blvd)
Bergamot Transit Village 32’ / 1.75 FAR
39’ / 1.75 FAR* 60’ / 3.0 FAR 75’ / 3.5 FAR 75’ / 3.5 FAR Mixed Use Creative 32’ / 1.5 FAR
36’ / 1.5 FAR* 47’ / 2.0 FAR 57’ / 2.5 FAR 57’ / 2.5 FAR Beach and Oceanfront 32’ / 1.5 FAR
36’ / 1.5 FAR*
47’ / 2.0 FAR
2.25 FAR*** - 47’ / 2.25 FAR
Downtown Core Downtown Community Plan establishes development standards
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Packet Pg. 626 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-8
LUCE Land Use
Designation
Max. Building Height and Density/Intensity
Tier 1 Tier 2 Tier 3 100% Affordable
Housing
Employment and Commerce
Industrial Conservation Residential uses are not permitted Office Campus Residential uses are not permitted
Healthcare Mixed-Use No tiers. Hospital Area Specific Plan establishes development standards Community and Public Uses
Institutional/Public
Lands/ Civic Center
No tiers. Civic Center Specific Plan establishes development standards Office Campus Residential uses are not permitted
* Height bonus for provision of on-site affordable housing. ** FAR bonus for provision of on-site affordable housing. *** FAR bonus for provision of additional affordable housing. b. Zoning Ordinance
In 2015, the City completed a comprehensive update of its Zoning Ordinance to ensure consistency with the new policies, goals, and standards set forth in the LUCE and specified implementation mechanisms for achieving these policy standards. Through the Zoning Ordinance, land use regulations regarding where types of housing can be developed within the City and various development standards such as parcel size, density (for residential zones), number of stories, building height, parcel coverage/FAR, setbacks, and open space are provided for each of the City’s 21 zone district classifications governed by the Zoning Ordinance (as shown in Map E-2). Except in the City’s residential zones where traditional means of density are prescribed, density limitations are controlled through a combination of building height and FAR limitations. The Zoning Ordinance defines a “dwelling unit” as “one or more rooms designed, occupied, or intended for occupancy as separate living quarters, with full cooking, sleeping and bathroom facilities for the exclusive use of a single household” that exceeds 375 square feet.
Additionally, the Zoning Ordinance and its associated land use regulations provide additional regulations for affordable units to ensure consistency with market rate unit sizes including standards for minimum unit sizes and unit mix/bedroom counts. Typically, these unit size requirements range from 500 square feet for a studio unitto 850 square feet for a two-bedroom unit.
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Packet Pg. 627 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) E-9 City of Santa Monica 2021-2029 Housing Element
Map E-2 Zoning Ordinance Zone District Classifications
While the Zoning Ordinance also implements the tiered development concept that was established in the LUCE, between the adoption of the LUCE in 2010 and the Zoning Ordinance update in 2015, Santa Monica’s growth management strategy fluctuated based on a multitude of factors that influenced how the community’s priorities were identified and addressed. This resulted in a reduced tiered system implemented in the Zoning Ordinance that eliminated the Tier 3 option identified in the LUCE for certain land use designations. The changes also removed four of the five “Activity Centers” which were intended to incentivize mixed-use residential development around the City’s transit stations through additional height above Tier 3 limits and FAR increases. As established in the LUCE, Tier 3 projects were voluntary and required a discretionary process and negotiated community benefits, while Activity Centers required cooperation of multiple property owners of large sites, an area plan, and individual development agreements for each project. As a result of the extensive process necessary to achieve Tier 3 or an Activity Center, the City moved toward a more standardized and simplified process through creation of an objective community benefits system.
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Packet Pg. 628 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix E | Constraints on Housing E-10
Even with the removal of these concepts, the City’s development standards are generous toward housing projects especially in mixed-use and commercial zones where setbacks are minimal (if any) and density limits are not established. The tiered system, with its provision of pre-established community benefits in exchange for increased building heights and densities/intensities, has also proven to be the preferred route for many housing developers to capture some level of additional development potential. However, based on feasibility testing conducted by the City’s economic consultant, current development standards such as low FAR and building height limitations have been identified to be constraints on the City’s ability to meet its updated housing goals. Additionally, other development standards such as minimum/maximum ground floor heights, active ground floor use requirements, daylight plane, and maximum building footprint have been brought to the City’s attention as other possible constraints. In some cases, a developer may apply for a modification or waiver to provide relief from these development requirements, but this adds time and uncertainty to housing project approvals. Therefore, Housing Element Program 1.J proposes to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production citywide. The new development standards for FAR and building height will be higher than existing standards and in some cases, higher than what was initially adopted as part of the original 2010 LUCE.
Within the residential zone districts (R2, R3, R4, OPD, OP2, OP3, and OP4), housing development is subject to a density limitation based on a units per acre calculation or a total maximum number of units, whichever is less. Most of the City’s rent control and more naturally occurring “affordable” housing stock is located in these residential districts, and as such, the density limits are intended to prevent the widespread displacement of tenants in existing residential units, particularly rent control units. However, there are a number of residentially zoned sites that are developed as surface parking lots for commercial uses on boulevard fronting parcels. The current density limits, as well as other development regulations (such as access requirements), are an existing barrier to development of these surface parking lot sites. Therefore, Housing Element Program 1.C proposes to remove the density limits for these parcels and revise the Zoning Ordinance to incentivize the development of surface parking lots in residential zones.
Figures E-2, E-3, and E-4 present the main development standards that control housing development within the City’s residential, commercial, and other zone districts, respectively.
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Packet Pg. 629 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-2 Development Standards in Residential Zone Districts Development
Standard
Residential Zone Districts
R1 R2 R3 R4 OP1 OPD OP2 OP3 OP4
Minimum Parcel Size 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 4,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft.
Maximum Parcel Area per Unit (Density)
Tier 1 –Base Standard 1 unit 2,000 (or 4 total units,
whichever is less)
1,500 (or 5 total units,
whichever is less)
1,250 (or 6 total units,
whichever is less) 1 unit 2 units 2,000 1,500 1,250
Tier 2 –With Provisions of
Community Benefits - - 1,250 900 - - - - -
100% Affordable Housing
Projects - 1,500 1,250 900 - - - - -
Maximum ParcelCoverage (% of Parcel Area)
Base Standard
45% - 55%
depending on
number of stories
and new/existing
development
Ground floor: 45%
Upper Stories: 90%
of allowable
ground floor
coverage
Ground floor: 50%
Upper Stories: 90%
of allowable
ground floor
coverage
Ground floor: 50%
Upper Stories (% of
allowable ground
floor coverage):
2 nd Story: 80%
3 rd Story: 60%
4 th Story: 50%
50% 50% 50% 50% 50%
100% Affordable Housing
Projects -
90% of allowable
ground floor
90% of allowable
ground floor
50% of allowable
ground floor 60% 60% 60% 60% 60%
Maximum Building Height (Stories/Feet)
Tier 1 – Base Standard
2 / 28’ -32’
depending on
parcel size
2 / 30’ 2 / 30’ 3 / 30’
2 / 20’ –27’
depending
on roof type
2 / 23’ –30’
depending
on roof type
2 / 23’ –30’
depending
on roof type
2 / 23’ –30’
depending on roof
type
3 / 35’
Tier 2 –With Provisions of
Community Benefits - - 3 / 40’ 4 / 45’ - - - - -
100% Affordable Housing
Projects - No limit / 30’ No limit / 40’ No limit / 45’ 2 No limit / 23’ –30’
depending on roof
type
No limit / 23’ –30’
depending on roof
type
No limit / 23’ –30’
depending on roof
type
No limit / 35’
Minimum Setbacks
Front Varies by street 20’ 20’ 20’ 15’ 30’ 20’ 20’ 15’
Sides
10% or
30% aggregate
Parcel 50’ or greater:
8’
Parcel less than 50’:
4’ or 16%
Parcel 50’ or greater:
8’
Parcel less than 50’:
4’ or 16%
Parcel 50’ or greater:
8’
Parcel less than 50’:
4’ or 16%
Development/
Parcel Specific
Development/
Parcel Specific
Development/
Parcel Specific
Development/
Parcel Specific
Development/
Parcel Specific
Rear 15’ 15’ 15’ 15’ 10’ 15’ 15’ 15’ 15’
Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private - 60 sq. ft. 60 sq. ft. 60 sq. ft. - 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft.
Total - 150 sq. ft. 150 sq. ft. 150 sq. ft. - 150 sq. ft. 150 sq. ft. 150 sq. ft. 100 sq. ft.
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Packet Pg. 630 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in FigureE-3 Development Standards for Commercial Zone Districts Development
Standard
Commercial Zone Districts
MUBL MUB GC
(Santa Monica Blvd)
GC
(Lincoln & Pico Blvds) NC NC(Main St)
NC
(Ocean Park Blvd &
Montana Ave)
Minimum Parcel Size 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft.
Maximum FAR
Tier 1 –Base Standard 1.25 1.25 1.0 1.25 1.25 0.75 0.75 Tier 1 –Projects Including On-site
Affordable Housing in
Compliance with AHPP
1.5 1.5 1.25 1.5 1.5 1.0 1.0
Tier 2 –With Provisions of
Community Benefits 1.75 2.25 1.5
1.75 (2.0 if on-site
affordable housing
provided)
- - -
100% Affordable Housing
Projects 2.0 2.75 1.5 2.0 1.75; 2.0, on Pico Blvd only 1.25 1.25 Maximum Building Height (Stories/Feet)
Tier 1 – Base Standard 2 / 32′ 2 / 32′ 2 / 32′ 2 / 32′ 2 / 32′ 2 / 27′ 2 / 32′ Tier 1 –Projects Including On-site
Affordable Housing in
Compliance with AHPP
3 / 36′
3 / 39′ if 100% residential
above ground floor, 3/35′
for all other projects
- 3 / 36′ 2 / 32′ 2 / 27′ 2 / 32′
Tier 2 –With Provisions of
Community Benefits 3 / 36′ 3 / 45′ 2 / 35′
3 / 32′ (3 / 36′ if on-site
affordable housing
provided)
- - -
Tier 2 –With Provisions of
Community Benefits and 100%
Residential Above the Ground
Floor
No limit / 36′ No limit / 50′ No limit / 35′
No limit to stories / 32′ (36′
if on-site affordable
housing provided)
- - -
100% Affordable Housing
Projects No limit / 55′ No limit / 55′ No limit / 35′ No limit / 40′ No limit / 32′; 40′ on Pico Blvd only No limit / 32′ No limit / 32′ Minimum Setbacks
Interior Side and Rear if Adjacent
to Residential District 10’ 10’ 10’ 10’ 10’ 10’ 10’
Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft. 60 sq. ft.
Total 100 sq. ft. 100 sq. ft. 100 sq. ft.. 100 sq. ft. 100 sq. ft. 100 sq. ft.. 100 sq. ft.
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Packet Pg. 631 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Figure E
-4 Development Standards for Other Zone Districts
Development
Standard
Zone Districts
IC OC HMU OF
Minimum Parcel Size 15,000 sq. ft. 15,000 sq. ft. 7,500 sq. ft. 5,000 sq. ft.
Maximum Density ---
Parcels Along PCH between Santa Monica Pier and the north City limits:
Parcels 4,000 sq. ft. or more: 1 dwelling unit/1,500 sq. ft.
Parcels less than 4,000 sq. ft.: 1 dwelling unit/parcel if existing, no new dwelling units
Maximum FAR
Tier 1 –Base Standard 1.0 1.5 1.5 1.5; 0.5 for parcels located along the PCD between the Santa Monica Pier and the north City limits
Tier 2 –With Provisions of Community
Benefits 1.75 1.75 2.5 2.0
100% Affordable Housing Projects 2.25- 2.5 2.25
Maximum Parcel Coverage ---
70; 50 on parcels along the PCH between the Santa Monica Pier and the north City limits
Maximum Building Height (Stories/Feet)
Tier 1 – Base Standard 2 / 32′ 2 / 32′ 3 / 45′ 2 / 32’ –30’ depending on roof type and location Tier 1 –Projects Including On-site
Affordable Housing in Compliance with
AHPP
--- 3 / 36′
Tier 2 –With Provisions of Community
Benefits 3 / 45′ 3 / 45′ 5 / 70′ 3/47′
Tier 2 –With Provisions of Community
Benefits and 100% Residential Above the
Ground Floor
--- No limit / 47′
100% Affordable Housing Projects No limit / 45′- No limit / 70′ No limit / 47′ Minimum Setbacks
Street Frontage--- 5’ except for 20’. on PCH between northern City limits and Santa Monica Pier Side--- Parcel specific
Rear---
15’ if adjacent to a residential use; 25’ for beach rear setback on parcels over 100’. in depth located along the PCH between the Santa Monica Pier and the north City limits
Interior Side and Rear if Adjacent to
Residential District 15’ 15’ 15’
-
Minimum Outdoor Living Area per Unit (Sites with 3+ Units) Private-- 60 sq. ft. 60 sq. ft.
Total-- 100 sq. ft.. 100 sq. ft.
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Packet Pg. 632 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix E | Constraints on Housing E-14
i. Affordable Housing
Santa Monica has consistently tried to remove barriers and incentivize 100% affordable housing projects in all of its zone districts citywide through the following methods:
• Greater FAR, density, and building height allowances
• No limit to the number of stories within the maximum building height • Parking reductions
• Ministerial permit processing
• No City Planning application fees or development impact fees • Compliance with California Assembly Bill (AB) 1763 (addition of 3 stories or 33’ in height, four incentives/concessions, no parking requirements) Through new Housing Element programs and concepts, such as the Moderate Income Housing Overlay identified in Housing Element Program 2.A, Santa Monica will continue to provide and expand benefits for 100% affordable housing projects throughout the City. ii. Affordable Housing Production Program
The City’s AffordableHousing ProductionProgram (AHPP), implemented through Santa Monica Municipal Code (SMMC) Chapter 9.64, requires that residential and mixed-use projects of two or more units contribute to affordable housing production to assist the City in addressing its overall affordable housing needs. Figure E-5 summarizes the options forfulfillingtheCity’sAHPP requirements through a menu option. However, Housing Element Program 2.C proposes revisions to the City’s AHPP, including re-evaluation of the minimum required percentage of onsite or off-site units, to determine the best means of achieving the City’s housing goals, which may include increasing the threshold forprovidingon-site units, addingflexibility in meeting goals through an in lieu fee or hybrid option, and increases to the number of units to be produced per project. To the extent Program 2 .C proposes amendments to the AHPP to increase the number of units that must be producedper project to increase the number of affordable units throughout the City, Programs 1.F and 1.J will ensure that the new FARs and building heights for housing projects that comply with the minimum AHPP requirements will be feasible.
Figure E-5Affordable Housing Production Program Options Projects with 2-3 Ownership Units
OR 2+ Rental Units
Projects with 4-15
Ownership Units
Projects with 16 or More
Ownership Units
On-site
Option
5% extremely low income units
(option currently unavailable until
after February 28, 2022); or 10% very
low income units, or 20% low income
units, or 100% moderate income units
20% moderate or 20%
low or 10% very low
income units
25% moderate or 25% low
or 15% very low income
units
Off-site
Option Same as on-site option 25% more than required number of on-site units 25% more than required
number of on-site units
Affordable $36.49/SF for apartments Not Applicable Not Applicable
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Housing
Fee (2020)
$42.62/SF for condominiums
Unit Development Cost: $382,795.00
iii. Community Benefits
The purpose of community benefits is to implement LUCE policies that require community benefits in exchange for increased development parameters. As discussed above, for a housing project to receive Tier 2 or 3 increased building heights and/or densities/intensities, the project must provide community benefits as prescribed in SMMC Chapter 9.23 or SMMC Section
9.10.070 for projects located within the Downtown Community Plan area. Community benefits consist of the following:
1. Housing (Increased provision of Affordable Housing and Unit Mix requirements)
2. Transportation Impact Fee
3. Open Space (Additional fee or provision of publicly accessible open space)
4. Transportation Demand Management (Preparation of a Developer TDM trip reduction plan, Transportation Allowance equivalent to 75% the cost of a monthly transit pass, and on-site shared bicycles)
While some community benefits require on-site features such as increased affordable units and unit mix requirements (prescribed percentages and ratios of studio, two, and three bedroom units) , others only require increases to development impact fees (an additional 14% applied only to the increase above Tier 1) . While community benefits can add additional requirements and fees to housing projects, they are an elective process (i.e., voluntary Tier 2 or Tier 3 projects) and are offset by increased development potential. Furthermore, Housing Element Program 1.J will be reevaluating and increasing development standards (FAR and building height) in mixed-use and commercial zones to support housing production. The new FARs and building heights for housing projects will be based on feasibility analysis that takes into account development costs inclusive of the requirements for community benefits, local fees, local building code requirements, as well as affordable housing requirements in the City’s AHPP. Additionally, 100% affordable housing projects are deemed to have satisfied the housing community benefit requirement and are not required to provide additional community benefits. iv. Parking Requirements
Figure E-6 summarizes Santa Monica’s parking requirements for residential uses throughout the City except for those areas governed by the Bergamot Area Plan (BAP). Single-unit dwellings are required to provide a flat rate of two parking spaces, whereas for other residential uses parking is calculated on a per-bedroom basis and in some cases per bed for certain housing types.
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Packet Pg. 634 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-6 ParkingRequirements forResidentialUses, Excluding the Bergamot Plan Area Residential Use/Facility Citywide(Excluding Parking Overlay Area 1, Downtown Community Plan Area, and Bergamot Area Plan Area) Parking Overlay Area 1 Downtown Community Plan Area(Maximum Parking Allowed) Single-Unit Dwelling 2 spaces per dwelling unit 2 spaces per dwelling unit, which may be tandem 2 spaces per dwelling unit Accessory Dwelling Unit 1 space per dwelling unit 1 space per dwelling unit N/A Junior Accessory Dwelling Unit N/A N/A N/A
Multiple-Unit Dwelling
Market Rate Units:
Guest = 1 space per 5 units
Studio, no bedroom = 1 space per unit
1 bedroom = 1.5 spaces per unit
2 or more bedrooms = 2 spaces per unit
Deed Restricted Affordable Units:
Studio, no bedroom = 0.5 space per unit
1 bedroom = 0.75 spaces per unit
2 or more bedrooms = 1 spaces per unit
Market Rate Units:
Guest = 1 space per 10 units
Studio, no bedroom = 1 space per unit
1 bedroom = 1 space per unit
2 or more bedrooms = 1.5 spaces per unit
Deed Restricted Affordable Units:
Studio, no bedroom = 0.5 space per unit
1 bedroom = 0.5 spaces per unit
2 or more bedrooms = 1 spaces per unit
Market Rate Units:
Guest = 1 space per 15 units
Studio, no bedroom = 0.5 space per unit
1 bedroom = 0.5 space per unit
2 or more bedrooms = 1 space per unit
Deed Restricted Affordable Units:
Guest = 1 space per 30 units
Studio, no bedroom = 0.25 space per unit
1 bedroom = 0.25 spaces per unit
2 or more bedrooms = 0.5 spaces per unit
Senior Citizen Multiple-Unit
Dwelling
0.5 space per unit
Guest = 1 space per 5 units
Low and moderate income units = 0.25 space per unit
0.5 space per unit
Guest = 1 space per 6 units
Low and moderate income units = 0.25 space per unit
0.5 space per unit
Guest = 1 space per 6 units
Low and moderate income units = 0.25 space per unit
Single-Room Occupancy See Multiple-Unit Dwelling See Multiple-Unit Dwelling See Multiple-Unit Dwelling Group Residential 0.5 space per bed 0.5 space per bed 0.5 space per bed Congregate Housing 1 space per 5 beds 1 space per 5 beds 1 space per 5 beds Senior Group Residential
0.5 space per unit
Guest = 1 space per 5 units
Deed restricted affordable = .025 space per unit
0.5 space per unit
Guest = none required
Deed restricted affordable = .025 space per unit
0.5 space per unit
Guest = none required
Deed restricted affordable = .025 space per unit
Elderly and Long-Term Care 0.5 space per bed plus one visitor space per 5 beds 0.2 space per bed 0.2 space per bed Residential Care, General If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds
If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds
If more than 6residents = 0.5 space per bed plus 1 visitor space per 5 beds
Residential Care, Limited None required other than what is required for existing residence None required other than what is required for existing residence None required other than what is required for existing residence Residential Care, Senior
If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
Hospice, General
If more than 6 residents = 0.25 space per bed plus 1 visitor space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
If more than 6 residents = 1 space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
If more than 6 residents = 1 space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
Hospice, Limited None required other than what is required for the existing residence
None required other than what is required for the existing residence
None required other than what is required for the existing residence
Supportive Housing
If more than 6 residents = 0.5 space per bed plus 1 visitor space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
If more than 6 residents = 1 space per 5 beds
If less than 6 residents = none other than whatis required for the existing residence
If more than 6 residents = 1 space per 5 beds
If less than 6 residents = none other than what is required for the existing residence
Transitional Housing None other than what is required for residential type None other than what is required for residential type None other than what is required for residential type Live-Work 1 space per unit plus 1 guest space per unit 1 space per unit plus 1 guest space per unit 1 space per 500 sq.ft.
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Realizing the constraint parking can have on housing projects, the City provides the following alternatives to relieve and/or lessen parking requirements for new development:
• Reduced parking requirements for deed-restricted affordable housing units • No minimum parking requirements for 100% affordable housing projects located within 1/2 mile of a major transit stop consistent with State density bonus law (AB 1763) • Reduced parking requirements for projects located in close proximity to transit, identified as Parking Overlay Area 1
• Reduced parking requirements for the provisions of car-sharing parking spaces.
Parking is reduced by two spaces for every one car-sharing space provided, up to a maximum of 25% of the required parking spaces, not exceed 10 spaces • Allowance for shared parking in nonresidential zone districts for projects within close proximity to each other
• Elimination of parking requirements and the need to replace displaced existing parking in conjunction with the construction/establishment of Accessory Dwelling Units and Junior Accessory Dwelling Units
• No minimum parking requirements in the Downtown area
Additionally, Housing Element Program 1.D proposes to revise minimum parking requirements for housing projects.
As for the Downtown area, instead of minimum parking requirements, the numbers provided in Figure E-6 stipulate parking maximums. This regulatory shift from parking minimums to parking maximums has allowed housing providers to right-size their parking needs including the option to provide no parking at all in the City’s Downtown area.
Unlike the majority of the City where residential parking requirements are based on bedroom count, residential parking in the BAP is based on unit count. Additionally, the BAP provides both minimum and maximum parking requirements which gives developers the ability to provide the appropriate amount of parking to serve each development. Also unique to the BAP is the concept of requiring less parking per unit when the plan area reaches 5,000 new parking spaces after the plan was adopted, which was in 2013. This eventual reduction will further lessen the constraint parking places on housing projects within the plan area. Figure E-7 summarizes the parking requirements for residential uses in the BAP.
Figure E-7 ParkingRequirements forResidentialUses in the Bergamot Plan Area Stage of Plan
Development
Minimum Space Required per Unit Maximum Spaces Permitted per Unit Tier 1 & 2 Tier 3 Tier 1 & 2 Tier 3
At Plan
Adoption
1.5, of which at least
1.0 must be reserved
1.5, of which at
least 1.0 must be
reserved and 0.5
must be shared
2.0, of which no
more than 1.5 may
be reserved (With
voluntary shared
parking)
2.0, of which no
more than 1.5 may
be reserved
At 5,000 Net
New Spaces
1.0, which may be
reserved or shared
1.0, which must be
shared
1.5, of which no
more than 1.0 may
be reserved (With
voluntary shared
parking)
1.5, of which no
more than 0.5 may
be reserved
v. State Density Bonus
State law (California Government Code Section 65915-65918) requires cities and counties to approve density bonuses for housing developments that contain specified percentages of affordable housing units or units restricted to occupancy by seniors. A density bonus is the allocation of development rights that allows a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned.
Projects that qualify for a density bonus are also eligible for reduced parking standards and additional concessions or incentives and waivers of development standards. The legislature has
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made frequent changes to State density bonus law over the years, including AB 1763 which significantly increased density bonus provisions for 100% affordable projects and AB 2345 which increased density bonus provisions for housing development projects that are not 100% affordable but qualify for a density bonus.
The City’s density bonus law is outlined in SMMC Chapter 9.22, was last updated in 2020, but does not reflect certain recent changes in State law that became effective in 2021. As currently written, Chapter 9.22, applies to projects in the City’s residential districts, and to 100% affordable housing projects located anywhere in the City. When Chapter 9.22 was updated in 2020, the City deferred including provisions for application of the State Density Bonus Law for projects other than 100% affordable projects in the City’s nonresidential districts, which do not implement a maximum density control, pending further study. Nevertheless, in accordance with State law and City Council direction given on June 15, 2021, the City is implementing State density bonus law in all districts for all housing projects. As described in Housing Element Program 2.D, the City will update its density bonus ordinance to be consistent with State law requirements. c. Downtown Community Plan
The Downtown Community Plan (DCP), adopted in July 2017, is a specific plan to implement the LUCE goals and policies for the City’s Downtown core. The DCP addresses important issues in the Downtown including, but not limited to, historic preservation, high quality architecture, sensitive urban design, diverse housing opportunities, sustainability, expansion of cultural arts offerings, additional open spaces that support quality of life, walkability, additional office space to meet the needs of creative businesses, and integration with the Metro E light rail stations.
Map E-3 Downtown Community Plan Zone District Classifications
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The DCP establishedsix zone district classifications as shown in Map E-3. Similar to the LUCE and Zoning Ordinance, the DCP specifies land use regulations regarding where various types of housing can be developedand various development standards such as parcel size, FAR, building height, setbacks, and open space for the zone districts it governs. The DCP also established a tiered system for developments with housing and community benefits specific to the DCP.
These community benefits, as described in SMMC Section 9.10.070, includeincreased affordable housing, unit mix requirements, Transportation Demand Management plans, and increased fees for transportation impacts, open space, and affordable housing commercial linkage. As with other commercial zone districts within the City, the DCP does not impose density limits, but rather density is controlled through a combination of maximum building heights, FAR limitations, and other massing/siting development standards, which has provided flexibility for housing projects. Additionally, similar to the Zoning Ordinance, minimum dwelling unit sizes and unit mix/bedroom counts are prescribed for affordable units to ensure their consistency with market rate units.
Overall, the DCP standards largely allow for the greatest amount of flexibility and incentives for housing developments within the City. Housing projects in the Downtown are given additional FAR and building height as compared to commercial projects. However, development standards such as low FAR and building height limitations have been identified to be constraints on the City’s ability to meet its housing goals. Additionally, development standards such a minimum/maximum ground floor heights, active ground floor commercial use requirements, daylight plane, and maximum building footprint have been brought to the City’s attention as other possible constraints. In general, while these standards can be perceived as onerous for housing developers, they have not precluded the development of housing in the Downtown, as demonstrated by the 20 applications for housing projects in the Downtown over the past 5 years, However, Housing Element Program 1.F proposes to reevaluate development standards and regulations, both independently and cumulatively, to not only ensure housing projects are feasible, but that they also incentivize housing production in the Downtown area Increases to FAR and building heights for housing projects through Program 1.F will be based on feasibility analysis which has taken into account development costs inclusive of the requirements for community benefits, local fees, local building code requirements, as well as affordable housing requirements in the City’s AHPP.
Figure E-8 presents the main developments standards that control residential development within the DCP zone districts.
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Packet Pg. 638 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-8 Development Standards for Downtown Community Plan Zone Districts Development
Standard
Downtown Community Plan ZoneDistricts
LT
(East)
LT
(West) NV BC(Promenade)
BC
(2nd& 4th Streets) TA OT WT
Minimum Parcel Size 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft. 7,500 sq. ft.
Maximum FAR
Tier 1 –Base Standard 1.25 1.25 1.75 1.75 1.75 1.75 1.75 1.5 Tier 1 –With Housing 1.5 1.5 2.25 2.25 2.25 2.25 2.25 1.5 Tier 2 –With Provisions of Community Benefits 1.75 2.25 2.75 2.75 3.0 3.0 2.25 1.75 Tier 2 –With Housing and Provisions of Community Benefits 2.25 2.75 3.5 2.75 3.5 3.5 2.75 2.25 Tier 2 –With Housing for parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core
- - - - - - -
2.75 Tier 3 –With Provisions of Community Benefits - - - - - 3.5 - - Tier 3 –With Housing and Provisions of Community Benefits - - - - - 4.0 - - 100% Affordable Housing Projects 2.75 3.25 4.0 3.25 4.0 4.0 3.25 2.75 100% Affordable Housing Projects –Parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core
- - - - - - -
3.25 Maximum Building Height
Tier 1 –Base Standard 32’ 32’ 32’ 32’ 32’ 32’ 32’ 32’
Tier 1 –Projects Including On-Site Affordable Housing In Compliance with AHPP 39’ 39’ 39’ 39’ 39’ 39’ 39’ 39’
Tier 2 –With Provisions of Community Benefits 40’ 50’ 60’ 60’ 60’ 60’ 50’ 40' Tier 2 –With Housing and Provisions of Community Benefits 50’ 60’ 60’ 60’ 60’ 60’ 50’ 50’ Tier 2 –With Housing for parcels that front on Wilshire Blvd, are not located adjacent to a residential district, and have a LUCE designation of Downtown Core
- - - - - - -
60’
Tier 3 –With Provisions of Community Benefits - - - - - 84’ - - Tier 3 –With Housing and Provisions of Community Benefits - - - - - 84’ - - 100% Affordable Housing Projects 60’ 70’ 70’ 70’ 70’ 84’ 60’ 60' Minimum Setbacks
Interior Side and Rear if Adjacent to Residential District 10’ 10’ - - - - - 10’ Minimum Open Space (% of Buildable Area)
Lot Width of 50’ or Less - - - - - - - -
Lot Width between 52-and 150’ 20% 20% 20% - 20% 20% 20% 20% Lot Width greater than 150’ 25% 25% 25% - 25% 25% 25% 25%
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Packet Pg. 639 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in E-21 City of Santa Monica 2021-2029 Housing Element
d. Bergamot Area Plan
The Bergamot Area Plan (BAP), adopted in September 2013, is a specific plan that provides guidance on transitioning former industrial lands of the Bergamot Area into an arts-focused, mixed-use, pedestrian-oriented neighborhood.
As shown on Map E-4, the BAP established two main zone district classifications, Bergamot Transit Village (BTV) and Mixed Use Creative (MUC), with two conservation districts, Conservation Arts Center (CAC) and Conservation Creative Sector(CCS). Similar to the LUCE and Zoning Ordinance, the BAP specifies land use regulations regarding where types of housing can be developedand development standards such as FAR, building height, and open space for the zone districts it governs. The BAP also requires a minimum mix of uses for developments within the MUC zone district. As with the DCP and other commercial zone districts, the BAP institutes a tiered system for developments that provide community benefits and controls density through maximum building heights and FAR limitations. Additionally, similar to the Zoning Ordinance, minimum dwelling unit sizes and unit mix/bedroom counts are prescribed for affordable units to ensure their consistency with market rate units.
Map E-4 Bergamot Area Plan Zone District Classifications
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However, unique to the BAP, is the concept of flexible standards. While some development standards are mandatory, others are flexible if it is determined that the project promotes design creativity, architectural innovation, and the vitality of the street and sidewalk environment and setting. Mandatory standards include FAR and building height, while flexible standards include mix of uses and open space standards. However, this concept of having flexible standards has led to more discretionary process for projects. Therefore, Housing Element Program 1.E proposes to revise the design standards in the BAP for easier understanding and support of housing production.
Since adoption of the BAP, the transit and job-rich Bergamot area has experienced a lack of housing production. Two potential reasons for this may include insufficient Tier 2 development standard increases that would otherwise incentivize housing over commercial development and a general concern about risk and predictability with the development agreement process that is required to access the heightened Tier 3 development standards. Therefore, Housing Element Program 1.J proposes to reevaluate development standards and regulations , both independently and cumulatively, to not only ensure housing projects are feasible, but that but that they also incentivize housing production in the BAP area to meet the City’s housing goals.
This program includes, but is not limited to, increasing FAR and building height limits.
Figure E-9 presents the main developments standards that control residential development within the BAP zone districts.
Figure E-9 Development Standards for Bergamot AreaPlanZone Districts Development
Standard
Bergamot Area Plan Zone Districts
BTV MUC CCS CAC
Maximum FAR (Parcel 100,000 SF or Greater / Parcel Less Than 100,000 SF) Tier 1
1.75 / 1.75
(25% FAR bonus for
projects providing
additional affordable
units)
1.5 / 1.5
(25% FAR bonus for
projects providing
additional
affordable units)
1.5 1.0 / 1.0
Tier 2
2.0 / 2.0
(25% FAR bonus for
projects providing
additional affordable
units)
1.7 / 1.7
(25% FAR bonus for
projects providing
additional
affordable units)
- 1.0 / 1.5
Tier 3 2.5 / 2.5 2.2 /2.5 - 1.0 / 2.5
Maximum Building Height (Standard / Variation)
Tier 1 32’ / 39’ if housing is
provided
32’ / 36’ if
affordable housing
is provided
32’ / 36’ if live/work
component is
provided
32’ / -
Tier 2 – With
Provisions of
Community
Benefits
60’ / - 47’ / - - 60’ / -
Tier 3 – With
Provisions of
75’ / 86’ with
increase ground
57’ / - - 75’ / 86’ with
increase ground
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Packet Pg. 641 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) E-23 City of Santa Monica 2021-2029 Housing Element
Development
Standard
Bergamot Area Plan Zone Districts
BTV MUC CCS CAC
Community
Benefits
floor-to-floor height floor-to-floor height
Minimum Open Space - % of Site Area
(Site Greater than 80,000 SF / Site 40,000 SF – 80,000 SF / Site Less than 40,000 SF) Tier 1 20% / 15% / 10% 15% / 12% / 7% 15% -
Tier 2 20% / 15% / 10% 15% / 12% / 7% 12% 15%
Tier 3 25% / 20% / 15% 20% / 15% / 10% 7% 10%
Minimum
Required Mix of
Uses for Parcels
over 120,000 SF
-
50% Commercial /
50% Residential
(Ratio can vary up
to 10%)
- -
e. Civic Center Specific Plan
The Civic Center Specific Plan, adopted in June 2005 with subsequent amendments, is unique in that it established a vision that promotes civic buildings and public open spaces and also provided standards that are more building specific for one of its four special use districts.
Currently the plan area is built out and development of additional residential units, which would likely come from the redevelopment of existing buildings, would require an amendment to the plan. However, Housing Element Program 4.A will be removing limitations on where housing can be located within the City, which will enable greater housing opportunities in areas such as the Civic Center Specific Plan areas. Map E-5 presents the Civic Center Specific Plan Special Use Districts.
Map E-5 Civic Center Specific Plan Special Zone District
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f. Local Coastal Program
The California Coastal Commission (Coastal Commission), in partnership with coastal cities and counties, plans and regulates the use of land, water, and coastal resources in the Coastal Zone. The Coastal Zone in Santa Monica encompasses the mean high tide line as the western border and generally up to 4th Street north of Pico Boulevard and Lincoln Boulevard south of Pico Boulevard. For projects in the Coastal Zone, a Coastal Development Permit (CDP) is required, which is issued by the Coastal Commission unless a local government has a Commissioncertified Local Coastal Program (LCP). CDPs are required for development activities broadly defined by the Coastal Act to include (among others) construction of buildings, divisions of land, and activities that change the intensity of use of land or public access to coastal waters.
Currently, the City is in the process of certifying an updated LCP to reflect the combined policies, goals, and objectives set forth in the City’s LUCE, Zoning Ordinance, and DCP (all of which were adopted after the City’s existing LCP was partially certified in 1992). In October 2018, the updated Land Use Plan was adopted by the Santa Monica City Council (the first step in the process), but is still awaiting certification from the Coastal Commission. The Implementation Plan, which began in June 2019, is currently in progress.
As the City does not yet have a certified LCP, housing projects within the Coastal Zone are required to obtain a CDP from the Coastal Commission before receiving a building permit from the City. While this can add both an additional process and timing constraint on housing projects, the City currently has no control over this process.
2. Zoning for a Variety of Housing Types
The City of Santa Monica encourages and facilitates the development of a variety of housing types beyond traditional single-unit and multiple-unit dwellings. These additional housing types include such uses as accessory dwelling units and junior accessory dwelling units, emergency shelters, employee housing, farmworker housing, group residential, low barrier navigation centers, manufactured homes and mobile home parks, residential facilities, single-room occupancy housing, and supportive and transitional housing, as well as accessible housing for the disabled [see Section A(3) below].
Figure E-10 presents a comprehensive matrix of land use regulations compiled from all City implementation plans (Zoning Ordinance, DCP, BAP) that specify where and how each housing type is permitted. Of the 32 zone districts within Santa Monica, all but one (OS) allow for some type of housing. How each housing type is processed is identified with either a “P” for when the use is permitted by right, an “L” for the when use is permitted if it complies with specific limitations such as location or size, or either an “MUP” or “CUP” for when the use requires discretionary approval [see Section 7(e) below]. If the use does not have a process identified it means that the use is not permitted, and if an “L” is coupled with another process it either means that the use must comply with both processes or if separated by a “/”, the use must comply with the second process listed if it cannot abide by the first.
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Packet Pg. 643 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) E-25 City of Santa Monica 2021-2029 Housing Element
While Santa Monica has made efforts to remove barriers to all housing types, some land use classifications and zoning implementations might not be consistent with updates to State law that have occurred since the City adopted its comprehensive Zoning Ordinance update in 2015.
Therefore, Housing Element Program 2.I states that the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints, including those for persons with disabilities.
Additionally, Housing Element Program 4.A proposes to amend the Zoning Ordinance and all specific plans to add multi-unit housing as a permitted use in all non-residential zones where housing is currently prohibited. Housing Element Programs 1.F and 1.J will also be reevaluating other restrictions that prohibit the location of housing, such as limitations on the ground floor.
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Packet Pg. 644 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Figure E-10 Permitted HousingTypes by Zone District
Residential Uses R1 R2 R3 R4 OP1 OPD OP2 OP3 OP4 LT NV BC (Prom.)
BC
(2nd/4th) TA OT WT MUBL MUB GC NC BTV MUC CAC CCS IC OC HMU OF CC PL OS RMH Single-Unit Dwelling P P P P P P P P P L(1) L(1) L(1) L(1) L(1) L(1) L(1) P P P P - - - - - - P P - - - - Accessory Dwelling Unit P P P P P P P P P P P P P P P P P P P P P P P P - - P P P - - - Junior Accessory
Dwelling Unit P P P P P P P P P P P P P P P P P P P P - - - - - - P P - - - - Duplex MUP P P P - P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P - - - - - - - P - - - - Multiple-Unit Structure - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Senior Citizen MultipleUnit Residential - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Single-Room
Occupancy Housing - P P P - - P P P L(1) L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - - P P L(1) - - - Group Residential - MUP MUP MUP - - MUP MUP MUP MUP MUP, L(3) MUP, L(1) MUP, L(1) MUP MUP MUP MUP MUP MUP MUP P P CUP - - - - MUP L(1) - - - Congregate Housing - P P P - - P P P P
MUP,
L(3) CUP, L(1) CUP, L(1) MUP MUP MUP P P P P P P CUP - L(1) L(1) P P L(1) - - - Senior Group Housing - P P P - L(2) P P P P
MUP,
L(3) MUP, L(1) MUP, L(1) MUP, L(1)
MUP,
L(1)
MUP,
L(1) P P P P P P CUP - CUP CUP P P L(1) - - -
Elderly and Long-Term
Care - CUP CUP CUP - - CUP CUP CUP P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - - P P P - - - - Emergency Shelters - - CUP CUP - - CUP CUP CUP L(6)/
CUP
L(6)/
CUP CUP/ L(1) L(1/6), CUP
L(6)/
CUP
L(6)/
CUP
L(6)/
CUP
L(3)/
CUP
L(3)/
CUP
L(3)/
CUP
L(3)/
CUP P P CUP -
L(2)/
CUP
L(2)/
CUP
L(2)/
CUP CUP - P - -
Residential Care,
General - MUP MUP MUP - - MUP MUP MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - - - - P L(1) - - - Residential Care, Limited P P P P P P P P P P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Residential Care, Senior -
L(2)/
MUP
L(2)/
MUP
L(2)/
MUP L(2) L(2) L(3)/MUP
L(3)/
MUP
L(3)/
MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Hospice, General - MUP MUP MUP - MUP MUP MUP MUP P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - - - - - - - - - Hospice, Limited P P P P P P P P P P L(3) L(1) L(1) P L(1) L(1) P P P P P P CUP - P P P - - - - - Supportive Housing P P P P P P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Transitional Housing P P P P P P P P P P L(3) L(1) L(1) L(1) L(1) L(1) P P P P P P CUP - P P P P L(1) - - - Live-Work - - - - - - - - - L(13) L(3/13) L(1/13) L(13) L(13) L(1/13) L(13) L(14) L(14) L(14) L(14) P P CUP P L(14) CUP L(14) - L(1) - - - Existing Mobile Home
Park - - - - - - - - - - - - - - - - - - - - - P - - - - - - - - - - Mobile Home Park - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - P “P” =Permittedby rightwithout discretionary action.
“L(#)” = Limited uses, which are permitted by right, provided they comply with specific limitation. “MUP” = Use classifications that are permitted after review and approval of a Minor Use Permit. “CUP” = Use classifications that are permitted after review and approval of a Conditional Use Permit. “-“ = Not permitted
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The following analysis details how the City facilitates specific special housing types consistent with State law requirements.
a. Accessory Dwelling Units /Junior Accessory Dwelling Units Accessory Dwellings Units (ADUs) play an important role in the production of housing particularly within single-unit residential zoning districts where historically only one unit is permitted per parcel. In recognition of this, the State over the past four years has enacted laws to help spur the production of housing through the development of ADUs. Building off of initial State law passed in 2017 that began removing barriers to ADU production, three new State laws [AB 68, AB 881, and Senate Bill (SB) 13] came into effect on January 1, 2020 that significantly expanded potential ADU development. Statewide, these new laws revised development standards that sometimes limited ADU construction such as eliminating minimum parcel size, establishing larger unit sizes based on bedroom count, reducing minimum side and rear setbacks, and removing on-site parking requirements. In addition, the new laws extended ADUs into multiple-unit residential and mixed-use zoning districts, introduced the new concept of deed restricted Junior Accessory Dwelling Units (JADUs) when in conjunction with single-unit dwellings, and established a strict 60-day processing timeframe and development parameters for ADUs that must be approved ministerially.
On September 8, 2020, the City approved an ordinance incorporating these State law requirements into a new ADU/JADU section of the Zoning Ordinance, SMMC Section 9.31.025:
Accessory Dwelling Units and Junior Accessory Dwelling Units. Additionally, to further encourage the production of ADUs and JADUs, the City expanded upon the new requirements by exempting all ADUs and JADUs from parcel coverage or floor area calculations and requiring only a ministerial process for review and approval of ADUs and JADUs. Additionally, no development fees are collected for the construction or establishment of ADUs or JADUs. Figure E-11 summarizes the main development standards adopted for an ADU or JADU consistent with State law.
Figure E-11 ADU and JADU Development Standards
Standard Requirement
Minimum Parcel Size No minimum parcel size
Maximum Number of Units
Single-Unit Development:
• One ADU or one JADU is permitted per parcel, except that one JADU and one detached ADU may be permitted on a single parcel
• JADUs are only permitted within single-unit zone districts Multi-Unit Development:
• Two detached ADUs
AND/OR
• Any area not used as livable space and that can be brought up to State building standards for dwellings, can be converted to at least one ADU or to a maximum number that equals 25% of the existing unit count.
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Standard Requirement
Maximum Size
ADUs:
• Studio/1 bedroom – 850 square feet
• 2+ bedrooms – 1,000 square feet or 1,200 square feet for parcels greater than 10,000 square feet
JADUs:
• 500 square feet
Parcel Coverage /
Floor Area Exempt
Setbacks Rear and side setbacks – 4 feet
Unit Requirements
ADUs:
• No interior access between the ADU and primary dwelling is permitted • Exterior access separate from the primary dwelling shall be provided • Independent eating and cooking facilities including, but not limited to, a sink, refrigerator, and a stovetop and/or oven shall be provided • Independent sanitation facilities including, but not limited to, a sink, toilet, and a shower and/or bathtub shall be provided
JADUs:
• Exterior access separate from the primary dwelling shall be provided; however, interior connection is permitted.
• An efficiency kitchen that includes a cooking facility with appliances and a food preparation counter and storage cabinets that are of reasonable size in relation to the size of the JADU shall be provided • May provide individual or share sanitation facilities with the primary dwelling
Parking • Additional on-site parking is not required for an ADU • Converted parking spaces are not required to be replaced Since implementation of these new State laws, the City has seen an increase in ADU production and interest, averaging 56 ADUs per year between 2018 and 2021. Figure E-12and Map E-6below summarize ADU development and location within the City since 2018 when State law began to focus on incentivizing ADUs.
Figure E-12Santa Monica ADU Production
Building Permit Issuance Year Permits Issued
2018 23
2019 60
2020 41
2021 102
TOTAL: 226
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Map E-6 ADU Locations
While Santa Monica has taken steps beyond what is required by State law to streamline and incentivize the production of ADUs, Housing Element Program 4.C proposes an ADU incentive program for single-unit residential zone districts. The incentive program will allow a property owner the ability to construct an additional ADU if they deed restrict one of the ADUs as a rental unit. This incentive program would help achieve the Housing Element goal of affirmatively furthering fair housing by providing more housing opportunities that are affordable by design within single-unit residential zone districts, which are areas of the city that have largely been unaffordable to many. To further remove barriers and help facilitate ADU production, Housing Element Program 1.G proposes to develop an ADU Accelerator Program to simplify the ADU process by providing prospective ADU developers with a handbook detailing all ADU standards and review procedures and pre-approved ADU plans that can be selected to reduce time and costs associated with ADU development. Additionally, to ensure compliance with State law, Program 1.G also includes language regarding continuing to review State law and updating the City’s locally adopted ordinance as needed.
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b. Emergency Shelters
State law [Government Code Section 65583] requires each jurisdiction to identify one or more zoning districts where emergency homeless shelters are allowed without a discretionary permit. Additionally, Government Code Section 65583(a)(4) limits the development standards and locational restrictions that can be applied to emergency shelters. Emergency shelters may only be subject to those development and management standards that apply to residential or commercial development within the same zone except that a local government may apply written, objective standards that include all the following:
• The maximum number of beds or persons permitted to be served nightly by the facility; • Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone; • The size and location of exterior and interior onsite waiting and client intake areas; • The provision of onsite management;
• The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart;
• The length of stay;
• Lighting; and
• Security during hours that the emergency shelter is in operation.
Emergency shelters are defined in the Zoning Ordinance as “a temporary, short-term residence providing housing with minimal supportive services for homeless families or individual persons where occupancy is limited to six months or less, as defined in Section 50801 of the California Health and Safety Code. Medical assistance, counseling, and meals may be provided.” As shown in Figure E-10, emergency shelters are permitted by-right in the BTV, MUC, and PL zone districts with no limitations and by-right up to 55 beds in 13 other mixeduse/commercial zone districts (identified by the L2, L3, and L6 designations) .
Additionally, SMMC Section 9.31.130 of the Zoning Ordinance sets forth standards for emergency shelters to ensure they do not adversely impact adjacent parcels or the surrounding neighborhood and that they will be developed in a manner that protects the health, safety, and general welfare of the nearby residents and businesses while providing for the housing needs of a vulnerable segment of the community. The standards include provisions and limitations on lighting, laundry facilities, common facilities, security, outdoor activity, services (including lengths of stay), maximum unit density, and health and safety standards. In terms of density, emergency shelters that are located in residential zone districts, when not developed in an individual dwelling unit format, are not subject to the underlying zone district’s maximum unit density standard, but the number of beds are limited to three times the maximum number of dwelling units which would otherwise be permitted on the site. Temporary shelter is also available to residents for no more than six months with extensions up to 180 days available if the
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shelter operator determines that no alternative housing is available. Additionally, minimum parking requirement for emergency shelters is one space per 10 beds, which is less parking required compared to other similar type of special needs housing.
Therefore, the City is in compliance with State law by allowing emergency shelters by-right in at least one zone district and is within the limits of all development and management standards.
However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints. Revisions will also include, but are not limited to, updated parking requirements for Emergency Shelters pursuant to AB 139. i. Capacity for Emergency Shelters
Government Code Section 65583(a)(4)(A) requires the Housing Element to demonstrate that the zones where emergency shelters are allowed by-right include sufficient capacity to accommodate the need for emergency shelter identified in the most recent point-in-time count conducted before the start of the planning period. According to the most recent annual point-in-time homeless count performed in 2020 (2021 count cancelled due to COVID-19 restrictions), a total of 907 individuals were counted on the streets, in cars and encampments, and in shelters and institutions within the City.
In order to determinethe City’s capacity for emergency shelters, properties on the Suitable Sites Inventory (SSI) with development potential to accommodate emergency shelters were evaluated based on size and location to transit and services. According to the SSI, there are 10 parcels within the BTVand MUC zone districts that can accommodate emergency shelters with no limitations on bed count and 118 parcels in the LT, NV, MUBL, MUB, and GC zone districts that limit emergency shelters to 55 bed per parcel. Existing facilities accommodating an approximate range of 16-70 beds have an average parcel size of 20,525 square feet, and of the 128 SSI parcels, 33 parcels would fall within this range. Therefore, it can be concluded that the parcel sizes on the SSI can accommodate emergency shelters of at least 55 beds. In order to quantify the number of beds that can be established on sites with no bed count limit, a 160 square foot per bed size was applied based on both local analysis and County of Los Angeles standards . As shown in Figure E-13, the City has capacity of 3,013 emergency shelter beds.
Therefore, Santa Monica has sufficient capacity to accommodate its emergency shelter need based on the 2020 point-in-time count of 907.
Figure E-13 Santa Monica Emegency Shelter Capcity
Zone
District
Number of
Parcels
Total Land Area (SF) Emergency Shelter Bed
Capacity
LT** 2 43,996 110
NV** 1 22,651 55
MUBL** 13 467,399 715
MUB** 9 273,121 495
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GC** 3 81,457 165
BTV* 1 38,333 240
MUC* 4 197,327 1233
Total: 33 1,124,283 3,013
* No limitation on bed count (160 SF per bed applied)
** 55 bed limit per parcel
c. Employee Housing
The provisions of Section 17021.5 of the California Health and Safety Code state that employee housing for six or fewer employees must be treated as a single-unit dwelling in regards to land used designation, processing procedure, and fees. As the City does not regulate the occupancy of single-unit dwellings and there are no provisions in the City’s code to restrict employee housing for six or fewer employees, the City complies with this requirement. However, as discussed below in Section A(3), the City’s definition of “household” may present a constraint.
Therefore, through Housing Element Program 2.1, regulations impacting special needs housing and residential land uses will be reviewed.
d. Farmworker Housing
While Santa Monica is highly urbanized and does not have any agricultural industries, according to the 2017 United States Department of Agriculture (USDA) Agricultural Census, there were 1,035 farms with 1,793 total producers within Los Angeles County. Additionally, the California Employment Development Department estimated that the 2020 annual average of agricultural employment was between 1,501 and 5,000 within the County. Therefore, within the region there is a need for farmworker housing, whether that be permanent or seasonal. In order to accommodate this need, Santa Monica provides a variety of housing types, such as employee housing and group residential, that are further discussed in this appendix that would be able to accommodate housing needs for these workers.
e. Group Residential
Group Residential is defined by the Zoning Ordinance as “shared living quarters without a separate kitchen or bathroom facilities wherein two or more rooms are rented to individuals under separate rental agreements or leases, either written or oral, whether or not an owner, agent or rental manager is in residence, offered for rent for permanent or semi-transient residents for periods generally of at least 30 days.” This land use classification includes rooming and boarding houses, dormitories, fraternities, convents, monasteries, and other types of organizational housing, and private residential clubs but excludes extended stay hotels intended for long-term occupancy and residential facilities. As shown in Figure E-10, group residential is allowed in the same zone districts as multiple-unit structures but typically requires discretionary approval of a Minor or Conditional Use Permit.
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Within the land use category of group residential, the subcategories of Congregate Housing and Senior Group Residential have special standards and are treated separately.
Congregate Housing is defined as “a residential facility with shared kitchen facilities, deedrestricted or restricted by an agreement approved by the City for occupancy by low- or moderate-income households, designed for occupancy for periods of six months or longer, providing services that may include meals, housekeeping, and personal care assistance as well as common areas for residents of the facility." Similar to the requirement for transitional housing, the Zoning Ordinance establishes maximum density limitations for beds in congregate housing facilities that is three times the maximum number of dwelling units that would otherwise be permitted, as well as requiring a management plan for the facility.
Senior Group Residential is defined as “a residential facility that provides residence for a group of senior citizens as defined in Health and Safety Code Section 1569.2(k) with a central kitchen and dining facilities and a separate bedroom or private living quarters.” To ensure that senior group residential does not “adversely impact adjacent parcels or the surrounding neighborhood and are developed in a manner that protects the health, safety, and general welfare of nearby residents, while providing for the housing needs of an important segment of the community,” the land use must adhere to standards related to location, development, and operation. This includes such standards as maximum number of private living quarters, kitchen and laundry facilities, common area facilities, security, minimum age requirements, minimum private living quarter sizes, and outdoor living area requirements.
As shown in Figure E-10, unlike the rest of the group residential land use, both subcategories are permitted by right in all multiple-unit residential and mixed-use districts and only need discretionary approvals in the DCP and employment zone districts. However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints.
f. Low Barrier Navigation Centers
AB 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multiple-unit uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a “housing first, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing”. Housing Element Program 5.B proposes to amend the Zoning Ordinance to comply with this new land use requirement. g. Manufactured Homes and Mobile Home Parks
State law requires jurisdictions to allow the placement of manufactured homes (also referred to as factory-built homes and modular homes) meeting Federal construction standards and
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manufactured home subdivisions in single-unit neighborhoods. Government Code Sections 65852.3 through 65852.5 require that manufactured homes be permitted in single-unit districts subject to the same land use regulations as conventional homes.
In accordance with State law, the City’s Zoning Ordinance includes manufactured housing units within its single-unit dwelling land use classification. This allows manufactured homes to be permitted wherever single-unit dwellings can be located which is in all residential, commercial, and DCP zones districts (single-unit dwellings are not a permitted land use within the BAP area).
As manufactured homes are considered single-unit dwellings, they must be compatible in design and appearance with other residential structures in the vicinity and be built on a foundation as well as meet other standards regarding roofing materials, siding, and skirting.
Santa Monica defines the “Mobile Home Park” land use as “any area or tract of land where 2 or more lots are rented, leased, or held out for rent or lease, to accommodate mobile homes used for human habitation.” There are only two remaining mobile home parks located within Santa Monica: (1) the Village Trailer Park that consists of 10 units and is located in the MUC zone district and (2) the Mountain View Mobile Home Park. Mountain View, with an approved capacity of 105 units, is located in the specially zoned “Residential Mobile Home Park District” which was established to preserve and protect existing mobile home parks as developments that offer alternative types of residential units and opportunities for affordable housing with special development standards and processes specific to the zone. h. Residential Facilities
The City of Santa Monica’s Zoning Ordinance classifies a group home as a “Residential Facility”, which is defined as follows:
“Facilities that provide permanent living accommodations and 24-hour primarily non-medical care and supervision for persons in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living.
Living accommodations are shared living quarters with or without separate kitchen or bathroom facilities for each room or unit. This classification includes facilities that are operated for profit as well as those operated by public or notfor-profit institutions, including group homes for minors, persons with disabilities, people in recovery from alcohol or drug addictions, and hospice facilities.” Within the Residential Facility classification, the use is divided between five subtypes with the following distinctions:
• Residential Care, General: A residential facility licensed by the State of California providing care for more than 6 persons.
• Residential Care, Limited: A residential facility licensed by the State of California providing care for 6 or fewer persons.
• Residential Care, Seniors: housing arrangement chosen voluntarily by the resident, the
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resident’s guardian, conservator, or other responsible person, where residents are 60 years of age or older and where varying levels of care and supervision are provided as agreed to at the time of admission or determined necessary at subsequent times of reappraisal. This classification includes continuing care retirement communities and life care communities licensed for residential care by the State of California. • Hospice, General: A facility that provides residential living quarters for more than 6 terminally ill persons.
• Hospice, Limited: A facility that provides residential living quarters for up to 6 terminally ill persons.
California State law mandates that State-licensed group homes of six or fewer residents must be regulated in the same manner as single-unit dwellings for zoning purposes. As shown in Figure E-10, Santa Monica is consistent with State law as Residential Care Limited is permitted in the same zone districts and/or to the same locational standards as single-unit dwellings and in some cases even where single-unit dwellings are not permitted such as in the BTV, MUC, CAC, IC, and OC zone districts. As for Residential Care General, the use is permitted by right in most of the City’s mixed-use and commercial zone districts that allow for larger development, but it is only permitted if certain locational standards are met or if the use obtains approval of either a Minor or Conditional Use Permit in the City’s multiple-unit residential zone districts. As Residential Care Facilities are treated as residential uses, they are subject to the same development standards as any permitted residential use of the same housing type in the district in which they are located. However, Residential Care General is required to be located a minimum distance of 300 feet from any other Residential Facility.
Hospice Limited and Hospice General generally follow the same approval process as their Residential Care counterparts, whereas Residential Care Senior follows the approval process based on the number of residents the facility holds.
While Santa Monica is in compliance with State law for group homes of six or fewer residents, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure compliance with all State laws and to remove any unintended constraints, such as when and how land uses are permitted. This would include reviewing requirements for group homes with seven or more residents. i. Single-Room Occupancy Housing
Single-Room Occupancy (SRO) housing is defined in the City’s Zoning Ordinance as “multipleunit residential buildings containing housing units that may have kitchen and/or bathroom facilities and are guest rooms or efficiency units as defined by the State Health and Safety Code.” Additionally, SROs are only permitted to be “occupied by no more than two persons,” must be “offered on a monthly rental basis or longer,” and are subject to specific standards that all SROs must abide by as set forth in SMMC Section 9.31.330. These standards include the following:
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• Maximum Occupancy. Each SRO unit shall be designed to accommodate a maximum of two persons.
• Minimum Size. An SRO unit must have at least 150 square feet of floor area, excluding closet and bathroom. No individual unit may exceed 375 square feet. • Minimum Width. An SRO of one room shall not be less than 12 feet in width. • Entrances. All SRO units must be independently accessible from a single main entry, excluding emergency and other service support exits.
• Bathroom. An SRO unit is not required to but may contain partial or full bathroom facilities. A partial bathroom facility shall have at least a toilet and sink; a full facility shall have a toilet, sink and bathtub, shower or bathtub/shower combination. If a full bathroom facility is not provided, common bathroom facilities shall be provided in accordance with the California Building Code for congregate residences with at least one full bathroom per floor.
• Closet. Each SRO unit shall have a separate closet.
• Common Area. Four square feet per living unit shall be provided, excluding janitorial storage, laundry facilities and common hallways. At least 200 square feet in area of interior common space provided as a ground floor entry area that provides a central focus for tenant social interaction and meetings.
• Tenancy. Tenancy of SRO units shall be for 30 or more days. • Facility Management. An SRO structure with ten or more units shall provide full-time on-site management. An SRO structure with fewer than ten units shall provide a management office on-site.
SROs are classified by the City’s Zoning Ordinance under the multiple-unit dwelling land use classification and are therefore permitted wherever and however multiple-unit structures are allowed; however, it is important to note that since 2019, SROs are only permitted ifthey are100% affordable housing projects, elderly and long-term care, emergency shelters, residential facilities, supportive housing, or transitional housing. This change was made in response to a threat of over-proliferation of market-rate SROs that would have been inconsistent with the City’s longstanding commitment to providing a range of housing types. This is not a constraint given the wide range of alternatives available.
j. Supportive/Transitional Housing
Consistent with the State Health and Safety Code, the City defines supportive housing as “housing with no limit on length of stay, that is occupied by the target population, and that is linked to on-site or off-site services that assist the supportive housing resident in retaining the housing, improving their health status, and maximizing their ability to live and, when possible, work in the community.” The target population for supportive housing is defined as persons, including persons with disabilities, and families who are homeless or who are homeless youth.
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While transitional housing is similar to supportive housing, transitional housing units are meant to be for a limited length of stay and “are operated under a program requiring recirculation to another program recipient at some future point in time.” Transitional housing may be designated for homeless or recently homeless individuals or families transitioning to permanent housing, and the classification includes domestic violence shelters. Also, unlike supportive housing, transitional housing has maximum density limitations for beds that is three times the maximum number of dwelling units that would otherwise be permitted and requires a management plan for the facility.
In compliance with Government Code Section 65583, both land uses are considered residential uses and are subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. Therefore, supportive and transitional housing are both permitted uses without discretionary action within the City wherever and however single or multiple-unit dwellings are permitted and even in the IC and OC zone districts where most housing is not currently permitted as demonstrated in Figure E-10.
Additionally, pursuant to recent changes in State law to Government Code Section 65651 (AB 2162), the City must allow 100% affordable housing projects that include at least 25% or 12 units of supportive housing by right where multiple-unit and mixed-use developments are permitted, including nonresidential zones permitting multi-unit uses. Santa Monica is already in compliance with this requirement as all affordable housing projects of any housing type mix are permitted where multi-unit structures are permitted. Additionally, as shown in Figure E-10, Supportive Housing on its own is a permitted use without discretionary action in all multi-unit zones and commercial zones where multi-unit housing is a permitted use.
However, as stated above, through Housing Element Program 2.I the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints.
3. Zoning Regulations and Practices for Persons with Disabilities The City of Santa Monica recognizes the importance of addressing the housing needs of persons with disabilities. This section reviews potential governmental constraints to the development and improvement ofhousing forpersons with disabilities. a. Definition of a Family
Local governments may unintentionally restrict access to housing for households failing to qualify as a “family” by the definition specified in a zoning code. Specifically, a restrictive definition of “family” that limits the number of and differentiates between related and unrelated individuals living together may impermissibly limit the development and siting of group homes for persons with disabilities but not housing forfamilies that are similarly sized or situated.
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Santa Monica’s Zoning Ordinances does not include a definition of “family”, nor is family used in any of the City’s land use classification titles. Instead, it defines the persons who occupy a housing unit as a “household”. A household is defined as follows:
“One or more persons living together in a single dwelling unit, with access to and use of all common living and eating areas and all common areas and facilities for the preparation and storage of food and who maintain a single mortgage, lease, or rental agreement for all members of the household.”
This definition of household does not refer to related or unrelated persons who may occupy a housing unit. Therefore, the zoning regulations do not discriminate against unrelated individuals with disabilities who reside togetherin a congregate or group living arrangement. However, the provision of requiring a “single mortgage, lease, or rental agreement” may inadvertently be a constraint on housing options for persons with disabilities. Therefore, Housing Element Program
2.I will be evaluating all special needs housing types and all provisions related to housing access for persons with disabilities to ensure consistency with State law and to remove any unintended constraints.
b. Definition of Disability
With the adoption of the updated Zoning Ordinance in 2015, Santa Monica incorporated the following definition of “disability” consistent with the Federal Fair Housing Act:
“Physical or mental impairment that substantially limits one or more of a person’s major life activities or a record of having an impairment, but the term does not include current, illegal use of, or an addiction to, a controlled substance. Current users of illegal controlled substances, persons convicted with illegal manufacture or distribution of a controlled substance, sex offenders, and juvenile offenders are not considered disabled under the Fair Housing Act, by virtue of that status.” The addition of this definition provides consistency with Federal law and brings clarity to land use classifications within the Zoning Ordinance.
c. Reasonable Accommodation
Both the Federal Fair Housing Act and the California Fair Employment and Housing Act direct local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning laws and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. One of the primary reasons for a reasonable accommodation procedure is to provide a way – other than through a discretionary entitlement – for residents with disabilities to request a modification from zoning, building, and land use rules, standards, policies, practices, and procedures.
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In the 2015 Zoning Ordinance update, Santa Monica adapted reasonable accommodation procedures (SMMC Chapter 9.49) that specify the applicability of eligible applicants and requests, application requirements, reviewing authority and procedures, findings and decisions, appeal process, and the duration limits of the accommodation. The findings for approval include:
1. That the housing or other property which is the subject of the request for reasonable accommodation will be used by an individual or organization entitled to protection;
2. The request for accommodation is necessary to afford an individual with a disability an equal opportunity to use and enjoy a dwelling or common areas of the premises;
3. The request for accommodation would not impose an undue financial or administrative burden on the City; and
4. The request for accommodation would not require a fundamental alteration in the nature of the City’s land use and zoning or building program.
Generally, a reasonable accommodation is a self-certified process consisting of a simplified application with limited information requested by the City in order to approve a request. On average, the City receives two applications per year, and both the findings above and the overall process have never presented a constraint. To date, a reasonable accommodation has never been denied.
4. Building Codes and Code Compliance
Building codes regulate the construction of dwellings and apply to plumbing, electrical, and mechanical systems. The purpose of building codes and their enforcement is to protect the public from unsafe conditions associated with faulty construction. a. Building Code Implementations
The City of Santa Monica enforces State building code standards for all structures subject to the Code, including the construction and rehabilitation of housing, and has adopted the 2019 California Building Standards Code (based on the 2018 International Building Code), the 2019 California Green Building Standards Code, and the 2019 California Residential Code. For historic resources, the City allows determinations to be made based on the State Historical Building Code. The State Building Standards Code establishes accessibility requirements in Chapters 11A (Housing Accessibility) and 11B (Accessibility to Public Buildings, Public Accommodations, Commercial Buildings and Publicly Funded Housing). Consistent with the Federal Fair Housing Act, the Code requires all multiple-unit structures with four or more units built after March 13, 1991 to provide accessible routes throughout the property, and “adaptable” dwelling units to allow conversion to a fully accessible unit without significant costs and the need to make significant structural modifications. In multiple-unit structures with an elevator, 100% of the units must meet the accessibility requirements, whereas in buildings without an elevator, all of the
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groundfloor units must be accessible. The Code requires compliance withthefollowingseven basic design and construction requirements for accessible routes and unit adaptability:
1. Accessible building entrance on an accessible route
2. Accessible and usable public and common-use areas
3. Usable doors by a person in a wheelchair
4. Accessible route into and through the dwelling unit
5. Light switches, electrical outlets, thermostats, etc. in accessible locations
6. Reinforced bathroom walls for later installation of grab bars
7. Usable kitchens and bathrooms for persons in a wheelchair These accessibility requirements pertain to new construction only and not renovations or remodels. However, the Building Code applies a more stringent standard for publicly funded housing requiring 20% of public funds utilized on renovation, structural repair, alterations, or additions to existing multiple-unit buildings be allocated towards removal of architectural barriers.
Section 504 of the Federal Rehabilitation Act of 1973 adds additional accessibility requirements for projects receiving federal funds such as the HOME Investment Partnership Program (HOME) or Community Development Block Grants (CDBG). In federally assisted new construction or substantially rehabilitated housing with five or more units, 5% of the units, or at least one unit, must be accessible for persons with mobility disabilities. An additional 2% of the dwelling units, or at least one unit, must be accessible for persons with hearing or visual disabilities. These units must be constructed in accordance with the Uniform Federal Accessibility Standards (UFAS) or a standard that is equivalent or stricter. UFAS generally defines an accessible housing unit as a unit located on an accessible route that can be approached, entered, and used by individuals with disabilities. b. Local Amendments
In 2019, along with the adoption of the California Building Code, the City adopted various local amendments. Local amendments provide for higher orders of seismic safety, structural safety, fire safety, occupant safety, and environmental conservation. The local amendments are reasonably necessary given the City’s local climactic, geological and topographical conditions, particularly the specific seismic conditions of Santa Monica with known earthquake faults and the special environmental conditions of the City’s beach community. The majority of the amendments, particularly for the Building Code and Residential Code, were discussed, conceived, and authored by the collaborative group of building officials in Los Angeles County.
City staff participated in each of the committees of this collaborative group, and staff determined that the technical suggestions of the collaborative group were applicable to Santa Monica.
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In accordance with local amendments to the California Energy Code, new buildings in Santa Monica have two design pathways: all-electric design and mixed-fuel design. As an incentive to design all-electric buildings, a higher level of energy efficiency is required for mixed-fuel buildings. All-electric buildings are not subject to higher levels of energy efficiency and may be built to the State’s standard design requirements. For residential projects specifically:
• New single-family, duplex, and multi-family residential buildings up to three stories:
o All-Electric Building: shall be designed to code established by the 2019 CEC. o Mixed-Fuel Building: shall be designed to CalGreen Tier 1 established by the 2019 CEC. CalGreen Tier 1 buildings have additional integrated efficiency and on-site renewable energy sufficient to achieve a Total Energy Design Rating of 10 or less. • New multi-family buildings, four stories and greater:
o All new buildings shall have a solar photovoltaic system with a minimum rating of 2 watts per square foot of the building’s footprint.
o All-Electric Building: shall be designed to code established by the 2019 CEC. o Mixed-Fuel Building: shall be designed to be 5 percent more efficient than the code established by the 2019 CEC. (The change from the current Energy Reach Code, which requires these buildings to be 10 percent more efficient is the result of a cost-effectiveness study.)
In accordance with local amendments to the Green Building Standards Code, major additions to one- and two-unit dwellings shall install a solar photovoltaic system with a minimum total wattage of 1.5 times the square footage of the addition. All major additions to multi-family and non-residential buildings are required to install a solar photovoltaic system with a minimum total wattage of 2 times the square footage of the addition’s footprint.
Local amendments to the 2019 California Energy Code and 2019 California Green Building Standards Code are reasonably necessary because of local climatic, geological, topographic, and environmental conditions. The amendments are consistent with the City’s Climate Action & Adaptation Plan and establish requirements to increase energy efficiency and the use of renewable energy, including in particular solar energy, which will reduce demands for local energy and resources, reduce regional pollution, and promote a lower contribution to greenhouse gases. Cost effectiveness studies prepared by the California Statewide Investor Owned Utilities Codes and Standards Program in conjunction with consultants and cities (collectively known as the “Reach Code Team”), demonstrate that the local amendments are cost-effective and do not result in buildings consuming more energy than is permitted by the 2019 California Energy Code.
In addition to local amendments to the Building Code, Stata Monica has specific High-Rise Safety Code requirements for buildings over 55 feet in height. In contrast, State law (Health & Safety Code Section 13210(b)) classify buildings over 75 feet in height as high-rise. The local
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high-rise amendment was put in place after the 1994 Northridge earthquake when there were multiple building fires and collapses. With limited resources at the time and since the City is surrounded on all sides by the City of Los Angeles, there were inadequate resources coming into the City in a timely manner. Since the City is very compact in many sections, especially in the downtown area, the purpose of this local amendment to the high-rise definition is to provide an extra level of occupant safety and fire protection in the event of a citywide emergency that might overwhelm the Fire Department’s ability to respond. Essentially, buildings over 55 feet high are required to add a higher level of safety to the building to ensure greater reliance on the builtin safety systems. While this can be a cost constraint on housing projects over 55 feet, it is a necessary safety precaution to ensure protection of human life. c. Compliance and Enforcement
Santa Monica’s Building and Safety Division ensures compliance with all State building and accessibility requirements as part of the plan check process. During the construction phase, buildinginspectors conductsitevisitstoensuretheprojectadherestothe approved project plans and requiredaccessibility specifications priorto signing off on the final certificate of occupancy (CofO).
Code enforcement can be a potential fair housing concern because code compliance actions may create disproportionate impacts on protected groups such as minority populations. In Santa Monica, however, code enforcement is triggered by complaints, and the City seeks voluntary code compliance through administrative processes that allow for retroactive compliance. In some cases, proactive campaigns are also undertaken when a widespread problem or a specific life/health/safety concern is identified. In conjunction with inspecting and noticing property owners regarding a violation, Code Enforcement personnel inform property owners of assistance provided through the City’s various housing rehabilitation programs.
5. On- and Off-Site Improvements
Various City departments implement on- and off-site improvement requirements, including standards for street construction, sidewalks, curbs, gutters, on-street parking and bicycle lanes.
Residential development may also necessitate constructing water, sewer, and drainage improvements. All improvements are generally required as conditions of approval and are developer financed. Complying with certain infrastructure improvements may be perceived as a constraint on the provision of housing for all income levels.
For infill projects, the SMMC Section 7.04.800 requires the construction of standard improvements that may include repair of defective sidewalks, construction of standard driveways, and maneuvering areas. The Code also requires dedication and improvement of full-street or alley frontages. The City's respective departments may approve variances from City standards based on hardship considerations on a case-by-case basis per City Code.
Although infrastructure requirements represent a cost to developing housing, these
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improvement standards are not unreasonable nor do they represent a significant constraint.
However, the City recognizes there are issues with infrastructure adequacy in certain areas of the City, including infill areas with aging infrastructure. These infrastructure deficiencies are a recognized constraint for infill development.
6. Entitlement and Development Impact Fees
Similar toother cities throughoutCalifornia,SantaMonicacollects various impacts fees, charges, and taxes on new residential development. Charges for such things as entitlement applications or development impact fees are set atrates designed to recover the cost of permit processing and to provide public services to residents as well as to mitigate certain development impacts (e.g., parks and open space and affordable housing). The City annually reassesses its fees to ensure they reflect the actual cost of providing services with most user fees adjusted annually based on the change in the Consumer Price Index (CPI).
The City has been active in meeting State requirements of Government Code Section 65940.1(a)(1)(A) to increase transparency and predictability of fees. All entitlement application and development impact fees, as well as building permit and plan check estimates, are posted on the City’s Finance Department website. Figure E-14 and E-15 summarize the City’s adopted entitlement application processing fees and potential development impact fees for new housing developments, respectively. The cost of development impact fees is determined by the type of development or uses proposed, the size of the project (square footage or unit count), and the development tier of a project as described above in Section A(1). When a housing development project requires multiple entitlement applications, the City charges 100% of the cost for the highest application fee and 50% of the cost of associated applications filed concurrently or after the initial filing for the project.
It should be noted that while some entitlements are listed in Figure E-14, such as Conditional/MinorUse Permits, Variances, and Modifications, these fees are either not required for typical housing projects within Santa Monica or are self-imposed by a developer. Conditional Use Permits (CUPs) are not required for typical multiple-unit residential projects. CUPs are unusual for residential use classifications in the Zoning Code and a CUP for a residential use has not been requested in the past 10 years.
Application fees, including CUPs, are based on cost recovery of services provided (i.e. staff time spent processing the permit), which typically requires significant analysis and development of conditions to mitigate potential impacts (e.g. noise, circulation, loading) on surrounding land uses. Additionally, as discussed below in Section 7, Entitlement and Permit Processing, housing projects in Santa Monica are largely processed ministerially and will continue to be with implementation of Housing Element Program 1.A, which has removed the need for a Development Review Permit. Furthermore, all application fees and development impact fees are waived for 100% affordable housing projects.
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Figure E-14 City PlanningResidentialDevelopment Application Fees, Fiscal Year 2020-2021 Mostplanningandconstructionfeesandtaxesaredueat buildingpermitissuance,butsomefees and charges such as the in-lieu AHPP fee may be paid at the end of the construction process (e.g., Certificate of Occupancy). In limited cases, off-site improvements may be required to mitigate project impacts (e.g., street, utility, or sewer capacity improvements), to repair public facilities damaged during project construction (e.g., sidewalk and curb reconstruction or alley repaving), and to protect the public health, safety and general welfare of city residents, businesses, and visitors.
Entitlement Application Type Total Fee Amount
Administrative Approval: Non-Downtown $7,990.46
Administrative Approval: Downtown –
Non-residential Projects Up to 10,000 SF $7,990.46
Administrative Approval: Downtown –
Housing Projecting up to 75,000 SF $13,947.51
Architectural Review Board: New Construction $4,563.52
Coastal Zone (Approval in Concept) $190.38
Conditional Use Permit $19,727.12
Deed Restrictions $887.68
Development Review Permit $28,539.79
Final Subdivision Map $1,993.13
Major Modification $5,486.47
Minor Modification $2,027.74
Minor Use Permit $8,065.39
Pre-Submittal Review $3,553.16
Tentative Subdivision Map $9,001.05
Variance $15,120.46
Waiver of Zoning Ordinance $5,486.47
Waiver of Parcel Map $3,042.71
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Figure E-15 Development Impact Fees, Fiscal Year 2020-2021 Transportation Impact Fee Parks and Recreation Development Impact Fee
Land Use
Adopted Fee Fee
Basis Land Use Adopted Fee
Fee
Area 1 Area 2 Area 3 Basis
Residential Residential
SingleUnit $8,901.19 $9,135.43 $9,135.43 per unit SingleUnit $8,584.88 per unit Multi-Unit $3,045.14 $3,864.99 $3,045.60 per unit Multi-Unit (Studio/1BR) $4,652.20 per unit Non-Residential Multi-Unit (2+ BR) $7,493.22 per unit
Retail $24.60 $35.25 $35.25 per SF Non-Residential
Office $11.36 $12.65 $12.65 per SF Office/Creative
Office $2.60 per SF
Medical Office $32.91 $34.90 $34.90 per SF Medical
Office/Hospital $1.43 per SF
Hospital - $17.22 $17.22 per SF Retail/Auto Sales $1.68 per SF Lodging $4.21 $4.21 $4.21 per SF Hotel $3.50 per SF
Industrial $1.40 $1.53 $1.53 per SF Industrial $1.46 per SF Auto Sales
Display $1.40 $1.53 $1.53 per SF - - -
Cultural Arts Contribution Affordable Housing Commercial Linkage Fee
Land Uses Onsite In-Lieu Fee
Basis Land Uses Adopted Fee
Fee
Basis
New Residential/
Commercial 2% of $200 1% of $200 per SF Office $12.60 per SF Commercial Tenant
Improvement 2% of 50 1% of $50 per SF Creative Office $10.78 per SF Childcare Linkage Fee Medical Office $7.75 per SF
Land Use Adopted
Fee
Fee
Basis Hospital $6.91 per SF
Residential $156.54 per unit Retail $10.96 per SF
Office $7.43 per SF Hotel $3.45 per SF
Retail $5.31 per SF Industrial $8.47 per SF
Hotel $3.73 per SF Institutional $11.50 per SF
Santa Monica’s AHPP allows eligible housing projects of three or fewer units to pay an affordable housing fee in-lieu of providing units on-site or off-site. Calculations resulting in a fractional unit of less than 0.75 can also be met through payment of a unit development cost fee.The unit development costfeereflects theaverage cost to the City to develop an affordable housing unit andisadjustedannuallybasedonchanges inlandand construction costs. Figure E16 provides the affordable housing in-lieu fee costs.
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Figure E-16 Affordable Housing In-Lieu Fee, Effective November 1, 2020 Affordable Housing In-Lieu Fees
Apartment Developments $36.49 per sq. ft. of entire project Condominium Developments $42.62 per sq. ft. of entire project Unit Development Cost $382,795.00
As a means of assessing the total cost that fees contribute to development in Santa Monica, Figure E-17 provides a breakdown of individual and cumulative costs of City permit fees, charges, and taxes applicable to three typical housing development types: (1) a mixed-use development, (2) a three-unit condominium development, and (3) a single-unit dwelling. As Figure E-17 shows, total development fees are approximately $27,155.75 per unit ($23.04 per square foot) for the mixed-use development, $124,588.59 per unit ($64.66 per square foot) for the three-unit condominium development, and $35,870 ($10.63 per square foot) for the singleunit dwelling.
Figure E-17 Development Fees Applicable to Prototypical Residential Development Projects Fees Mixed-Use
Development
3-Unit Condo
Development
Single-Unit
Dwelling
Zone MUBL R2 R1
Stories 3 2 2
Market Rate 25 units 3 units 1 unit
Affordable 3 units 0 units N/A
Total Units 28 units 3 units 1 unit
Residential Floor Area 24,000 SF 5,780 SF 3,375 SF
Ground Floor Commercial 9,000 SF Retail N/A N/A
Avg. Unit Size 704 SF per Unit 1,926 SF per unit N/A
Tenure Type Rental Ownership Ownership
# Parking Spaces 49 spaces 6 spaces 2 spaces
Entitlement and Development Impact Fees
Administrative Approval $7,990.46 Exempt Exempt
Subdivision Map Exempt $10,994.63 Exempt
Architectural Review Board:
New Construction $4,563.52 $4,563.52 Exempt
CEQA analysis Exempt Exempt Exempt
Aff. Housing In-lieu Exempt $246,343.603 Exempt
Aff. Housing Comm. Linkage $4,393.96 Exempt Exempt
Parks & Rec. $146,110.38 $14,986.44 Exempt
Transportation Impact Fee $115,085.58 $7,729.98 Exempt
Cultural Arts $66,000.00 Exempt Exempt
Childcare Linkage $52,173.12 $469.62 Exempt
Construction Fees
Plan Check $34,353 $11,156 $7,773
Building Permits/ Inspections $41,581 $10,152 $6,203
Water Meter1 $8,429 $8,429 $8,429
Fireline Meter2 $84,292 $26,973 $0
Wastewater Capital Facilities $128,492 $13,767 $ 4,589
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Fees Mixed-Use
Development
3-Unit Condo
Development
Single-Unit
Dwelling
Other Requirements and Taxes
School Facilities Fee $66,900 $15,201 $8,876
Condo Tax $0 $3,000 $0
Total Fees and Taxes $760,361.02 $373,765.79 $35,870
Total Fees/Unit $27,155.75 $124,588.59 -
Total Fees/ Sq. Ft. $23.04 $64.66 $10.63
1 Assume 1 inch water meter
2 Assumes 4 inch Fireline meter
3 Only required when a developer choses to not provide an on-site affordable unit In 2021, the average cost to develop an apartment unit in Santa Monica is approximately $735,0001, including construction and land costs. Given that cost, the percentage of cumulative development fees the City imposes on an apartment unit is approximately 3.7% of the construction cost. Additionally, using the mixed-use development prototype above, the cost City fees contribute to an 100% affordable housing project is approximately $364,047 (mixeduse development total minus all entitlement and development impact fees) or $13,001.68 per unit. As of November 2020, with the average cost for the City to develop an affordable housing unit at $382,795.00, it can be assumed that applicable City fees amount to approximately 3.4% of the cost to construct an affordable unit.
Similarly, it is estimated that one condominium unitin a three-unit developmentin Santa Monica costs approximately $1.6 million2to develop in some areas of the City. Given this cost, the percentage of cumulative development fees the City imposes is approximately 7.8% of the development cost of one condominium unit. However, it should be noted that the main reason City fees are high for the above prototype is because typically developers of three-unit condominium developments elect to pay an affordable housing in-lieu fee. This fee could be avoided if a developer provided an affordable unit on-site, which would lower the total fee amount to $127,422.79 or $42,474.26 per unit, which is 2.6% of the total development cost for one condominium. Therefore, this fee in a self-imposed constraint and the City provides an alternative to not pay it.
As for single-unit dwellings, the development cost range is too wide and varied to approximate a realistic cost. However, as detailed in Section E of Appendix B, the average price in 2019 for a single-unit dwelling within Santa Monica was $3,966,251. Given this price, the percentage of cumulative development fees the City imposes is approximately 0.9% of the average singleunit dwelling sales price.
Given the percentages that City fees represent of average development and sales prices, combined with the fact that the volume of new housing construction in the last housing cycle exceeds the City’s regional housing need, it can reasonably be concluded that the City’s permit fees and other development charges and taxes do not impose an undue constraint on the 1 From investigation of total development cost for market-rate housing by HR&A in 2021 2 From investigation of total development cost for 3-unit condominium projects by HR&A in 2021
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production of new housing. However, in addition to development standards, Housing Element Programs 1.F and 1.J propose to review all development impact fees applied to housing projects.
7. Entitlement and Permit Processing
Housing development in Santa Monica is subject to varying ministerial and discretionary processes depending on such parameters as size, development tier, and land use. Below is a description of typical processes, thresholds, requirements, and timeframes housing projects may encounter.
a. Processes and Thresholds
New housing developments within Santa Monica are reviewed through one of three processes based on size, use, and location thresholds – Building Permit review, Administrative Approvals, or Development Review Permits. In August 2020, an Interim Zoning Ordinance (IZO) was adopted that temporarily revised the processing thresholds for most housing projects. The intent behind the IZO was to streamline and incentivize housing projects, especially those that are subject to the protections of the Housing Accountability Act (HAA), by making projects that were once discretionary now ministerial. This has had the effect of shortening project approval time as well as allowing for housing projects to be exempt from the environmental review process mandated by the California Environmental Quality Act (CEQA). Housing Element Program 1.A proposes to make these interim process thresholds permanent and to expand the streamlining applicability to housing projects that are granted deviation from certain zoning ordinance objective standards through the minor modification process.
Figure E-18 and E-19 summarize the IZO thresholds and typical processes for housing projects within the City, respectively. With these IZO thresholds, the vast majority of housing projects fall into a ministerial (by-right) process which alleviates the processing time and discretionary review barriers that provide constraints for housing production in Santa Monica.
Figure E-18 Entitlement Application Thresholds
Review
Process Entitlement Development Thresholds
Ministerial
Building Permit
Review Only
• Projects in residential zone districts
• Single-Unit Dwellings
Administrative
Approval
• Projects more than 1,000 sq. ft. in nonresidential zone districts • All 100% affordable housing projects
• Any project that meets the definition of “housing development project” under the HAA, up to Tier 2 maximum limits and meets all objective standards*
Discretionary Development
Review Permit
Projects that exceed:
• Tier 2 maximum limits in the DCP and BAP
• Tier 1 maximum limits for projects that do not meet the definition of “housing development project” under the HAA or do not meet all
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objective standards*
• 10,000 sq. ft of floor area located in Residential Zone Districts • 7,500 sq. ft. of floor area in the NC and OF Zone Districts • 15,000 sq. ft. of floor area located in Nonresidential Zone Districts (Not including NC and OF)
• 30,000 sq. ft. of floor area in projects containing no more than 15% commercial floor area located in Nonresidential Zone Districts (Not including NC and OF)
• 7,500 sq. ft. feet of floor area located in the Pico Neighborhood Area * The Housing Accountability Act defines a “housing development project” as a project that is either (1) residential units only, (2) a mixed-use development consisting of residential and nonresidential uses with at least two-thirds of the square footage designated for residential use, or (3) transitional or supportive housing.
Figure E-19 Housing Development Project Processes
Step in
Entitlement Process
Building Permit
Review Only
Administrative
Approval
Development
Review Permit
Application Submittal X X X
ARB Preliminary Review X (DCP only) X
Staff Administrative Review and Approval X
Planning Commission Review and Approval X
ARB Formal Review and Approval X X X
Plan Check / Building Permit Approval X X X
b. Ministerial Approvals
Housing projects that require either an Administrative Approval or only a building permit are processed ministerially for conformance with objective development standards with no discretion exercised by the Community Development Director, Planning Commission, or City Council, although certain projects are required to receive design review approval by the Architectural Review Board (ARB) [see Section 7(d) below]. Below is a description of these processes.
i. Administrative Approvals
The Administrative Approval (AA) entitlement is intended to allow for the approval of projects which conform to the standards established for the applicable zone district in which the project is located and do not require discretionary review or approval by the Director, Planning Commission, or City Council. AAs provide for an administrative review and assessment of the proposed development project in light of explicit standards which have been designed to ensure that the completed project will be in harmony with existing or potential development in the surrounding area consistent with the goals, objectives, and policies of the LUCE.
Generally, the AA process consists of the following steps:
1. Application submittal
2. ARB preliminary review for Downtown projects only
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3. Staff review and approval
4. ARB review and approval
5. Plan Check/Building Permit approval
For an AA to be issued, only approval from the City Planning, Mobility, and Resource Recovery and Recycling Divisions are required, and the following findings must be made in the affirmative:
1. The proposed development conforms precisely to the development standards for the area and the Santa Monica Municipal Code and General Plan.
2. The proposed development does not require discretionary review or approval as outlined in the Municipal Code.
The typical processing time for an AA is approximately three months, not including building permit or ARB review and approval. This timeframe coupled with the lack of discretionary review does not present a constraint on housing development projects. The lack of discretionary review also means that AA projects cannot be appealed. ii. Building Permit Only Projects
Projects that only require building permit approval consist of single-unit and multiple-unit dwellings in residential districts. However, ARB review is required for all multiple-unit structures and in limited cases, for single-unit dwellings. Building permit review time varies based on project type, but due to the lack of discretionary approval these projects are not constrained by the building permit process. Building permit projects also cannot be appealed. c. Discretionary Approval
Housing developments that fall within the discretionary category for processing are required to obtain approval of a Development Review Permit (DRP). Below is a description of the DRP process and requirements.
i. Development Review Permit
A DRP is intended to allow for the construction of certain projects provided that the building design, siting, and use are compatible with the site and neighborhood, and the project does not result in an adverse impact on the surrounding area. DRPs are reviewed and approved by the Planning Commission, and as part of the review, consideration is given to the location, size, massing, and placement of structures on a site as well as to the location of proposed uses within a project. A DRP review also consists of an evaluation of a project’s compliance with the development standards of the Zoning Ordinance, and approval of a DRP takes into account the potential impacts of a project, as evaluated under the aforementioned aspects of review, and weighs it against the public need for benefits derived from the project.
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Generally, the current DRP process consists of the following steps, subject to compliance with SB 330 limitations on number of hearings:
1. Application submittal
2. ARB preliminary review
3. Planning Commission review and approval
4. ARB review and approval
5. Plan check/Building permit approval
A DRP will only be granted if the Planning Commission determines that the following findings of fact can be made in support of the project as submitted or modified. The inability to make one of the following required findings is grounds for denial of an application.
1. The physical location, size, massing, setbacks, pedestrian orientation, and placement of proposed structures on the site and the location of proposed uses within the project are consistent with applicable standards and are both compatible and relate harmoniously to surrounding sites and neighborhoods;
2. The rights-of-way can accommodate autos, bicycles, pedestrians, and multi-modal transportation methods, including adequate parking and access;
3. The health and safety services (police, fire etc.) and public infrastructure (e.g., utilities) are sufficient to accommodate the new development;
4. The project is generally consistent with the Municipal Code, General Plan, and any applicable Specific Plan;
5. Based on environmental review, the proposed project has no potentially significant environmental impacts or any potentially significant environmental impacts have been reduced to less than significant levels because of mitigation measures incorporated in the project or a Statement of Overriding Considerations has been adopted;
6. The project promotes the general welfare of the community;
7. The project has no unacceptable adverse effects on public health or safety; and
8. The project provides Community Benefits consistent with SMMC Chapter 9.23.
In granting a DRP, the Planning Commission (or the City Council if appealed) must make findings that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or in such modifications thereof, as may be deemed necessary to protect the public health, safety, and general welfare and secure the objectives of the LUCE and the Zoning Ordinance. They may also impose any other conditions as deemed necessary to achieve these purposes and to support the findings for approval.
The typical time to process a DRP takesbetween six to ninemonths not including building permit or ARB review and approval. Given the discretionary process of DRPs, the lack of predictably
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and timing can be a constraint on housing production. Additionally, DRP approvals can also be appealed which results in aproject having an additional public hearing before a higher decisionmaking body (City Council) adding more time and uncertainty to the overall process. However, with the IZO thresholds in place and the intent to make them permanent through Housing Element Program 1.A, DRPs for housing projects are only required in very limited circumstances when a projects is greater than 75,000 square feet in the Downtown Community Plan area.
Additionally, it should be noted that if a project is compliant with the Housing Accountability Act as described further below, the City is unable to deny a housing project.
The DRP process also triggers environmental review requirements under CEQA. In the past, many housing projects were subject to a rigorous environmental review process (such as preparation of an Environmental Impact Report) that could take up to 2 years or more. However, with passage of new CEQA legislation in recent years, most housing projects in the City are determined to be CEQA exempt.
d. Architectural Review Board
The Architectural Review Board’s (ARB) role in the development of housing is to preserve existing areas of natural beauty and cultural importance, and to assure that buildings, structures, signs, or other developments are in good taste, good design, harmonious with surrounding developments and in general contribute to the preservation of Santa Monica’s reputation as a place of beauty, spaciousness, and quality.The ARB’s purview relative to housing production is over all new multiple-unit and mixed-use developments within the City and only single-unit dwellings if they are located on sloped parcels.
Currently, for housing projects in residential zone districts that only require a building permit or for housing developments that only require an AA, the ARB’s review and approval happens either before the building permit process or after the AA is approved. When it comes to housing development projects that require DRPs, in addition to the formal ARB review and approval after the entitlement is approved, a preliminary review takes place prior to the discretionary public hearing in order to provide initial design feedback that can be considered by the Planning Commission. This preliminary review also serves to provide the project applicant feedback on their design as the project advances through the entitlement process.
In order forthe ARB to approve a project, the following findings must be made:
1. The plan for the proposed building or structure is expressive of good taste, good design, and in general contributes to the image of Santa Monica as a place of beauty, creativity, and individuality.
2. The proposed building or structure is not of inferior quality such as to cause the nature of the local neighborhood or environment to materially depreciate in appearance and value.
3. The proposed design of the building or structure is compatible with developments on land in the general area.
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4. The proposed development conforms to the effective guidelines and standards adopted pursuant to Chapter 9.55 – Architectural Review Board, and all other applicable ordinances insofar as the location and appearance of the buildings and structures are involved.
Projects that are subject to ARB review are typically approved on the first or second round of review which can take approximately six weeks to three months. The City does not prohibit applicants from submitting an application for a building permit prior to obtaining ARB approval, but there is risk that the ARB process may result in changes to the building permit application.
While good design is a priority to the City, the ARB process can add a constraint on housing projects as it adds a discretionary process to otherwise ministerial projects or another level or review to projects that are already going through one discretionary process. ARB approvals can also be appealed which results in a project having to go to an additional public hearing at a higher decision-making body (Planning Commission) adding more time and uncertainty to the overall process. Additionally, while the design review process focuses only on project design and cannot be used to reduce density or deny a housing project, the approval findings can be perceived as not objective.
To help remove barriers to some housing projects, the City has made recent revisions to stafflevel ARB review and approval thresholds. Projects such as exterior remodels and the addition of new housing units in the rear of the parcel can now be reviewed and approved by staff.
However, Housing Element Program 1.B stipulates adoption of additional streamlining efforts to expedite ARB review for housing projects. This includes expansions to the staff-level approvals, shifting the design review process to occur before or be concurrent with entitlement review, placing time and hearing limits on projects, review and establish mechanisms to promote approval certainty, and developing objective design standards. Together, these efforts will help remove constraints on housing projects by reducing processing time and will bring increased certainty for housing providers.
e. Use Permits and Other Processes
Additional processes are described below that some residential land use types may need to adhere to.
i. Conditional and Minor Use Permits
As shown in Figure E-10, the only kinds of residential use classifications that require approval of a Conditional Use Permit (CUP) are elderly and long-term care facilities and emergency shelters. Residential use classifications that require approval of a Minor Use Permit (MUP) in some zones are group residential, residential care general, residential care senior, and hospice general. These uses are not typical multiple-unit residential uses in that they typically consist of shared living quarters and provide care for persons in need of personal services, supervision,
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protection, or assistance for sustaining the activities of daily living. These use permits and the processes they require are to help ensure that the uses being proposed are consistent with the purposes of the zone district in which they are located and that special consideration is given to the design, location, and operation of the use in a manner that will not interfere with the use and enjoyment of surrounding properties.
Both use permits are required to be reviewedbya decision-making body (Planning Commission for a CUP and the Community Development Director for a MUP) and can only be granted if the following findings can be made in the affirmative:
1. The proposed use is conditionally allowed within the applicable Zoning District and complies with all other applicable provisions of the Zoning Ordinance and all other titles of the Municipal Code.
2. The proposed use is consistent with the General Plan and any applicable specific plan.
3. The subject parcel is physically suitable for the type of land use being proposed.
4. The proposed use is compatible with any of the land uses presently on the subject parcel if the land uses are to remain.
5. The proposed use is compatible with existing and permissible land uses within the District and the general area in which the proposed use is to be located which may include but not be limited to size, intensity, hours of operation, number of employees, or the nature of the operation.
6. The physical location or placement of the use on the site is compatible with and relates harmoniously to the surrounding neighborhood.
7. Based on environmental review, the proposed project has no potentially significant environmental impacts or any potentially significant environmental impacts have been reduced to less than significant levels because of mitigation measures incorporated in the project or a Statement of Overriding Considerations has been adopted.
8. The proposed use and related project features would not be detrimental to the public interest, health, safety, convenience, or general welfare.
In granting a CUP or MUP, the decision-making body shall require that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or in such modifications thereof, as may be deemed necessary to protect the public health, safety, and general welfare and secure the objectives of the General Plan and the Zoning Ordinance. The decision-making body may also impose any other conditions as may be deemed necessary to achieve these purposes and to support the findings of approval.
Typically, a CUP or MUP is processed concurrently with other associated entitlements that are being proposed but on their own can take approximately three months to process. However, use permit approvals can be appealed which results in a project having to go to an additional
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public hearing at a higher decision-making body (City Council for CUP appeals and Planning Commission for MUP appeals) adding more time and uncertainty to the overall process. These timeframes can add a constraint on certain types of housing that require a use permit, but as shown in Figure E-10, the vast majority of residential land uses are permitted by right and therefore, would not be required to go through any of these processes. However, through Housing Element Program 2.I, the City will be reviewing all special needs housing types and residential land uses to ensure consistency with State law and to remove any unintended constraints.
ii. Subdivision Maps
For some housing projects, such as condominiums or mixed-use developments that have commercial and residential components, developers may choose to subdivide the airspace rights of individual units or uses. For example, this typically happens when a housing developer wants to develop for-sale housing units. Additionally, a developer may also choose to process a subdivision map in order to vest current development standards at time of application.
The process is conducted in two steps: a Tentative Map that is approved by the Planning Commission and a Final Map that is approved by City Council. The Tentative Map may be denied by the Planning Commission on any of the grounds provided by City ordinances or the California Subdivision Map Act. The Planning Commission may deny approval of the Tentative Map if it makes any of the following findings:
1. The proposed map is not consistent with applicable general and specific plans as specified in Government Code Section 65451.
2. The design or improvement of the proposed subdivision is not consistent with applicable general and specific plans.
3. The site is not physically suitable for the type of development.
4. The site is not physically suitable for the proposed density of development.
5. The design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.
6. The design of the subdivision or the type of improvement is likely to cause serious public health problems.
7. The design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements for access or for use will be provided, and that these will be substantially equivalent to ones previous acquired by the public. This subsection shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or
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use of property within the proposed subdivision.
8. The proposed subdivision is inconsistent with any ordinance or law of the City of Santa Monica.
The subdivision process can add a time constraint on a housing project, but a subdivision map is only a requirement if the developer is selecting to develop for-sale units, wants to divide the uses within a building for financing reasons, or wants to vest development standards.. While the processing time for a subdivision map is approximately 50 days, the approval can also be appealed which results in a project having to go to an additional public hearing at a higher decision-making body (City Council). This possibility adds more time and uncertainty to the overall process. However, the requirements of the Subdivision Map Act cannot be waived or amended by local ordinance when a subdivision of airspace or land is a part of the proposed project.
f. State Law
Existing and new State laws have an impact on housing developments and how they are processed. Below is a description of three pertinent laws. i. Senate Bill 330
Senate Bill (SB) 330, “The Housing Crisis Act of 2019”, established a statewide housing emergency to be in effect until January 1, 2025 (“housing emergency period”). During the housing emergency period, the City of Santa Monica, as an urban area, is generally prohibited from enacting any development policy, standard, or condition that would have the effect of the following:
1. Changing the land use designation or zoning to a less intensive use or reducing the intensity of land use within an existing zoning district below what was allowed on January 1, 2018;
2. Imposing or enforcing a moratorium on housing development;
3. Imposing or enforcing new non-objective design standards established on or after January 1, 2020; or
4. Establishing or implementing certain limits on the number of permits issued for housing development projects or the population of Santa Monica.
SB 330 also limits the demolition of existing housing units in conjunction with a housing development project, as that term is defined for purposes of SB 330, unless replacement units are provided and only allows the demolition of affordable, rent-controlled, or other protected units if certain tenant protections are met.
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Additionally, new specific requirements and limitations on development application procedures have been established by SB 330. Housing developers may now submit a “preliminary application” for a housing development project that requires a specified subset of information prior to providing a formal application. Submittal of the preliminary application secures the applicable development standards and fees adopted at that time. The project is considered vested unless the project changes substantially or no formal entitlement application is filed within 180 days. SB 330 also limits the processing time of housing development projects to 60 or 90 days depending on environmental review requirements and limits the number of public hearings to no more than five including Planning Commission, Architectural Review Board, and City Council. To facilitate this process, Santa Monica has developed a preliminary application form consistent with SB 330.
ii. Senate Bill 35
Senate Bill (SB) 35, passed in 2017, requires jurisdictions that have not approved enough housing projects to meet their Regional Housing Needs Allocation (RHNA) to provide a streamlined, ministerial entitlement process for housing developments that incorporate affordable housing.
Pursuant to SB 35, if a jurisdiction has not approved enough market rate or affordable housing units to meet its RHNA, review and approval of proposed projects with at least 10% affordability or 50% affordability must be based on objective standards and cannot be based on subjective design guidelines, respectively. However, to be eligible, projects must also meet a long list of other criteria including prevailing wage requirements for projects over 11 units. In order for applicants to take advantage of SB 35, per Government Code Section 65913.4 (10)(b)(1)(a)(et seq.), they need to submit a Notice of Intent, and jurisdictions need to give Native American tribes an opportunity for consultation.
The City is currently not subject to SB 35 under the 5th Cycle Housing Element reporting period (2013-2021) because the City meet its RHNA targets. Nevertheless, the City will be undertaking the development of objective design standards and written procedures for implementation of SB 35’s streamlined review should the City become subject to SB 35 in the coming 6th Cycle Housing Element reporting period (2021-2029) as part of Housing Element Programs 1.A and 1.B.
It should also be noted that the City has enacted an interim ministerial approval process for nearly all housing projects that meet objective standards of the Zoning Ordinance, and Housing Element Program 1.A proposes to make those interim process thresholds permanent. iii. Housing Accountability Act
The Housing Accountability Act (Government Code Section 65589.5) ( HAA) is a State law that restricts the City's ability to deny, reduce the density of, or make infeasible any housing development project that complies with objective general plan, zoning, and subdivision standards and criteria (collectively, "Objective Standards") in effect at the time that the housing development's application is determined to be complete. The HAA has been in effect since 1982 and has undergone several amendments to further reinforce the state legislature's intent to
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increase the supply of residential housing stock. The most recent amendments went into effect on September 25, 2020.
In essence, the HAA precludes the City from denying or imposing any conditions upon any housing project (including residential units only or mixed-use projects with at least two-thirds of square footage designated for residential use) unless specific findings are made. However, the HAA does not preclude the City from exercising its discretion and imposing design conditions as part of its review as long as any such conditions does nothave the effect of reducing the number of residential units and/or the residential density of this mixed-use project. The City reviews all housing development projects that meet objective LUCE, zoning, and subdivision standards and criteria in accordance with the limitations set forth in the HAA.
As discussed above, the City expanded its ministerial processing thresholds for housing development projects to now include all Tier 2 projects that meet the definition of “housing development project” under the HAA and all Objective Standards. This expansion was to not only acknowledge that the HAA limits the ability to deny or reduce the density of such housing development projects but,also wasa way to further streamline the vast majority of new housing projects in the City. In addition, Housing Element Program 1 A will expand this streamlining to projects that seek and are granted deviation from certain objective standards through the ministerial Minor Modification process.
8. Local Measures, Propositions, Rent Control Law, and Ordinances The following section focuses on key policies in Santa Monica which serve to promote the production and preservation of housing for all residents, many of which have been in place during prior Housing Elements cycle. As evidenced by the robust housing development the City has seen in recent years, these policies are not impeding housing production and should not prevent the City from achieving its quantitative housing goals. a. Santa Monica City Charter Section 615
Santa Monica Charter Section 615 sets forth processes for adoption of ordinances by the City Council. On November 6, 2018, Santa Monica voters approved Measure SM, which amended Charter Section 615 to require five affirmative votes of the City Council in order to adopt or approve an amendment to either the LUCE or the DCP that would increase any maximum height limit or floor area ratio. All members of the City Council that are eligible to vote must be present to vote on an adoption or an amendment to increase height or floor area ratio pursuant to Measure SM. Measure SM includes express exemptions for 100% affordable housing projects and development on property owned by the Santa Monica-Malibu Unified School District or successor school district in the City. The provisions of Measure SM are set to expire on November 6, 2028.
The City Council has not considered any adoptions or amendments to the LUCE or DCP that would be subject to the provisions of Measure SM since it was adopted in November 2018.
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Housing Element Programs 1.F and 1.J propose to revise the City’s development standards to incentivize housing projects over commercial development which will likely result in proposed increases in height or floor area ratio subject to the requirements of Measure SM. However, because the amendments to Charter Section 615 enacted by Measure SM expressly exempt 100% affordable housing projects, the provisions of Measure SM will not serve as a constraint on the development of 100% affordable housing projects.
b. Rent Control
Santa Monica Rent Control was adopted by the voters in April 1979 in response to a shortage of housing units, low vacancy rates, and rapidly rising rents. The law was intended to alleviate the housing shortage and to ensure that owners received no more than a fair return. Regulations were adoptedby the Rent Control Board to implement and enforce the Rent Control Law.
Changes to the City Charter can only be made by the voters, whereas changes to the implementing Regulations are made by the Board.
The City’s Rent Control Law does the following:
• Controls the amount that may be charged for a rental unit during a tenancy and provides remedies for the collection of excess rent.
• Determines the amenities and services that are included as part of the rent and provides remedies for removal or reduction of those amenities. • Limits the reasons why tenants may be evicted.
• Limits removal of controlled units from rental market.
The following units are covered underthe Law:
• Most residential rental buildings in the City constructed prior to April 10, 1979 and certain units constructed after that date (e.g., those on properties on which a rentcontrolled building stood within the last five years) are covered by Rent Control. • In addition to apartment buildings, Rent Control also applies to some single-unit dwellings and condominiums used as rentals.
• Duplexes and triplexes where one unit is occupied by the owner are eligible for an exemption from rent control.
The services of the Rent Control Agency are financed by a per unit annual registration fee charged to owners of controlled rental units. Owners who are in compliance with the law may pass through half of the fee to the tenant(s) on a monthly basis. The Rent Control Board provides waivers of Rent Control registration fees to units occupied by their owners, subsidized by HUD (Section 8 or HOME program), or occupied by low-income tenants who are at least 62 years old or who are disabled. There are also fee waivers for condominiums and single-unit dwellings on
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which rent restrictions have been lifted pursuant to the Costa-Hawkins’ Rental Housing Act and in mobile home parks forunits where tenants have signed long-term leases. i. Vacancy Decontrol
The Costa-Hawkins Rental Housing Act, passed by the State Legislature in 1995, has had a significant impact on local rent affordability. Under this State law, a unit’s rent is decontrolled at the end of a tenancy. The owner can set a new rent for the next tenancy which is then recontrolled using the new rent as the base leading some to characterize Costa- Hawkins asa system of “vacancy decontrol-recontrol.”The following highlights some of the major effects Costa Hawkins’s has had on the Santa Monica rental market during its 22 years of implementation (1999- 2020)3:
• Since the passage of Costa-Hawkins, nearly 20,000 controlled units have received vacancy increases, representing 73% of the City’s total rent-controlled housing stock.
Market-rate rents are on average roughly double that of long- term controlled rents. • Median rents for decontrolled-recontrolled apartments have gone up by well over 200% between 1999-2020
• 84% of Santa Monica’s rental units that have now been re-rented at least once were affordable to low income households (<80% AMI) prior to Costa Hawkins with 73% of the rental stock decontrolled-recontrolled as of 2020 due to tenant turnover. Even moderate-income households (<120% AMI) are challenged to afford the majority of rental housing in the community.
The impact of this increase in rents on lower income households is significant. For example, many young people earning entry-level pay will be unable toafford to live in Santa Monica, and those living on fixed incomes—principally seniors and the disabled—will likely be unable to continue to live here if they lose theirlong-term rent-controlled housing.
As passed by Santa Monica voters, the Rent Control Law provides Just Cause Eviction protections to help protect existing tenants in rent-controlledhousing fromunfair evictions. The voters expanded these protections in 2010 through Measure RR to most residential tenants regardless of rent control status. The City Council has also enacted Tenant Anti-Harassment laws to protect all renters in the city.
ii. Just Cause Eviction
Santa Monica’s Rent Control Law establishes “Just Cause Eviction” provisions and defines procedures that a property owner must follow to lawfully evict a tenant. These local provisions 3 Santa Monica Rent Control Board, 2020 AnnualReport, March 2021
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are in addition to State regulations on landlord and tenant rights and responsibilities. The Rent Control Law identifies the following permissible grounds for eviction:
• Fault-Based Evictions
o Nonpayment of rent
o Materially and substantially breaching the lease
o Causing or permitting a substantial nuisance or damage to the unit o Being convicted of using the unit for an illegal purpose o Refusing to renew or extend the lease on the same terms as the original lease when lawfully asked to do so by the landlord
o Refusing to grant the landlord reasonable access to the unit to make necessary or agreed-upon repairs or improvements, or show the property for sale o Subletting in violation of the lease
• No Fault Evictions
o The landlord seeks possession of a unit in good faith for use and occupancy by herself or himself, or her or his children, parents, grandparents, brother, sister, father-in-law, mother-in-law, son-in-law, or daughter-in-law o The landlord seeks to recover possession to demolish or otherwise remove the controlled rental unit from rental residential housing use after having obtained all proper permits from the City of Santa Monica.
o The landlord seeks to recover possession of the unit to remove the rental unit permanently from rental housing use pursuant to the Ellis Act enacted by the State Legislature.
In November 2010, Santa Monica voters passed Measure RR amending the City Charter to further strengthen tenant protections against eviction in the following three ways:
• Extending “just cause” eviction protections to all tenants in multi-unit apartment buildings that are permanently exempt from rent control, as well as two- and threeunit owner-occupied properties, and newly constructed rental units. • Requiring owners to give tenants a reasonable opportunity to correct an alleged lease violation, nuisance activity, or failure to provide lawful access before serving a threeday notice to perform or quit. • Forbidding owners to evict for owner occupancy any tenant who has occupied a rental unit for at least five years and is 62 or older, disabled, or terminally ill, unless the owner (or qualified relative intending to occupy the unit) meets at least one of these same criteria.
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The strengthened eviction protections under MeasureRR have had a noticeable impact. From 2005 to 2010, the Rent Control Board received on average copies of 109 eviction notices per year for reasons other than non-payment of rent. By comparison, the Board received on average 85 notices annually after Measure RR took effect (excluding 2020 when eviction moratoria related to the COVID-19 pandemic reduced the number to just 31). iii. Tenant Harassment Protections
In 2002, the CityCouncil adopted a Tenant Harassment Ordinance to protect tenants in rentcontrolled units from landlords’conductin derogation oftenants’rights. The ordinance prohibits the following acts by landlords if they are done with the intent to harass:
• Taking away services provided for in the lease (such as parking or laundry) • Failure to perform repairs and maintenance required by law • Entering the apartment without proper notice
• Using lies or intimidation intended to make a tenant move out • Giving a “3-day notice” or other eviction notice that is based on false charges where the landlord does not intend to take the case to court
• Threatening the tenant, by word or gesture, with physical harm • Intentionally disturbing a tenant’s peace and quiet
• Interfering with a tenant’s right to privacy
• Refusing to acknowledge receipt of a tenant’s rent payment without justification • Violating any law which prohibits discrimination based on race, gender, sexual preference, sexual orientation, ethnic background, nationality, religion, age, parenthood, marriage, pregnancy, disability, Acquired immunodeficiency syndrome (AIDS), or occupancy by a minor child
In December 2011, the City Council extended these tenant harassment protections to all tenants covered by just cause eviction rules. Tenant harassment complaints are referred to the City Attorney’s Office forinvestigation and enforcement of the law. As a neutral enforcer of the law, the City cannotrepresenttenants directly and refers tenants requiring representation to Legal Aid (located near City Hall) and the Santa Monica Bar Association. iv. Relocation Assistance
Under the City’s Municipal Code, a property owner is required to pay relocation assistance to a tenant when terminating a tenancy for any of the following reasons:
• The owner seeks to withdraw all rental units from the rental market as provided for under the Ellis Act
• The owner seeks to recover possession of a rental housing unit for use by the owner or
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family member
• The landlord seeks to demolish or otherwise withdraw a rental housing unit from residential rental housing use, including units that were illegally converted to residential use, after having obtained the proper permits from the City Santa Monica had not increased its permanent relocation benefit amounts (other than cost of living increases) since2007,duringwhichtimerentlevels inthe city had increased and vacancies had decreased. In December 2011, the City Council adopted increased relocation fees. In addition, the City established augmented relocation amounts to households with seniors, disabled persons, and children because these households are particularly vulnerable. It increased the assistance amounts again effective February 2019 to mitigate the financial impacts of involuntary displacement and to keep pace with living costs. Figure E-20 presents the City’s adopted relocation amounts effective July 1, 2020. The fees are adjusted each July to reflect increases in the cost of living.
Figure E-20 Residential Relocation Fee Amounts, Fiscal Year 2020/2021 v. Rent Control Dispute Resolution
The Rent Control Law provides processes for filing of petitions, complaints, and applications to resolve disputes between landlords and tenants.
• Excess rent complaints are reviewed by staff, and the owner is given a chance to resolve the complaint. Complaints which are unable to be resolved administratively are referred to the Hearings Division for mediation and/or hearing. • Owner-occupied exemption applications are reviewed by staff and granted or denied by the Rent Control Board. If staff review indicates an exemption may be recommended to be denied, or if a tenant challenges the granting of an exemption, it is referred to the Hearings Division for an evidentiary hearing and for preparation of a recommendation to the Board.
• The Hearings Division provides mediation services as part of the decrease and excess rent processes, as well as for issues involving lack of maintenance, loss of housing services, and unreasonable construction impacts. Mediators have been very Unit Size Fee Amount Augmented Fee Amount*
Single or Studio $16,500 $17,200
One bedroom $22,700 $24,250
Two or more bedrooms $31,550 $33,650
Source: City of Santa Monica, Ordinance #2383
*Eligible households include those with a senior citizen, occupant with a disability, or an occupant with whom a minor child resides.
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successful in settling a large percentage of these cases.
The City has found that mediation may be particularly useful when a building is purchased. For example, new owners may want to fix up the building and make improvements in the common areas yet may be unaware of how the Rent Control Law affects those changes such as proper notice being required before entering the tenants’ units or the tenants being entitled to certain amenities. The tenants maybe concerned about changes to their home and disruptions to the longstanding practices or “culture” of a building and may not know how to communicate their concerns effectively. Mediation is often appropriate and helpful in this type of situation. c. State of California, Article 34
Article 34 of the State Constitution requires local jurisdictions to obtain voter approval for specified “low rent” housing projects that involve certain types of public agency participation.
Generally, a project is subject to Article 34 if more than 49% of its units will be rented to lowincome persons. If a project is subject to Article 34, it will require an approval from the local electorate. This can constrain the production of affordable housing since the process to seek ballot approval for affordable housing projects can be costly and time consuming with no guarantee of success. Local jurisdictions typically place a measure or referendum on the local ballot that seeks “general authority” to develop a certain number of low-income units during a given period of time. If the electorate approves general parameters for certain types of affordable housing development, the local jurisdiction will be able to move more quickly in response to housing opportunities that fall within those parameters.
Incompliancewith thisarticle,theCityofSanta Monicaputareferendum (Proposition N) before the voters in 1978 in order to win approval to “develop, finance, or rehabilitate, but not own or operate within the city, housing for rental to low- and moderate-income persons, no less than 50% of which shall be reserved for persons age 60 or older, not to exceed in total throughout the city, 1% of the dwelling units in the city.” On November 3, 1998, Santa Monica’s voters approved Proposition I, which provides the City with an annual authorization to develop, construct, acquire, and finance low- income housing units including senior housing. The City’s annual authorization is equal to 1/2 of 1% of the total dwelling units existing in the city at the end of the prior fiscal year. Any portion of an annual authorization that is not used may be carried overinto future for up to three additional years.
To date, the City has never exceeded any annual Proposition I low-rent housing production limits. The Suitable Sites Inventory includes a number of City-owned sites that are considered to have the highest potential to accommodate the production of affordable housing. Housing Element Program 2.E proposes to explore means of maximizing housing potential on these sites subject to a public process. The City estimated the realistic capacity of these sites with consideration to existing constraints (such as lease terms, financial feasibility, etc.). Based on this estimate and applying a density factor of 150 units/acre, the City estimates that these Cityowned sites have the potential for accommodating for 1,693 units.
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Due to the high cost of construction in Santa Monica, the City’s financial assistance to an affordable housing developer consisting solely of land conveyance is not likely sufficient to construct a 100% affordable housing project without additional sources of government funding (typically federal tax credits) which are typically awarded on a competitive basis. In theory, however, if sufficient funding were available to construct all 1,693 units on City-owned property, the Proposition I limitation on the annual cap of affordable dwelling units that could be produced with each conveyance would need to be considered. This would require coordination to ensure that the conveyances of City-owned property are staggered to fall below the Proposition I limits or, alternatively, the City Council could place a measure on the ballot to increase the cap. However, based upon the current “cushion” of Proposition I authority (due to affordable housing development below the annual Proposition I thresholds in the last three fiscal years) and assuming that government funding remains constrained at historical levels, it does not appear realistic to assume that Article 34/Proposition I would be a likely constraint on affordable housing development for City-owned sites during the 6th Cycle of the City’s proposed Housing Element.
d. Home Sharing (Short-Term Rental) Ordinance
In response to the increase in vacation rentals due to the popularity of Airbnb and other online platforms, the City desired to reaffirm its long-standing prohibition of vacation rentals in Santa Monica while allowing individuals to be able to rent a spare room in their homes for periods of thirty days or less (“home-sharing”). Therefore, on May 12th, 2015, the City adopted the "HomeSharing Ordinance" adding Chapter 6.20 to the SMMC to expressly adopt and confirm its longstanding prohibition against short-term vacation rentals and establish regulations for home-sharing. This law became effective on June 12th, 2015, and was subsequently amended by ordinances adopted on January 24, 2017, June 27, 2017, and September 24, 2019. The HomeSharing Ordinance allows eligible residents (owners and long-term residents) to apply for a home-sharing permit and business license so that they can home-share their primary residence. In addition, the September 24, 2019 amendments to the ordinance contain listing and advertising requirements, restrictions on the number of group bookings, occupancy and visitor vehicle limitations, and other prohibitions. These amendments took effect on October 24, 2019 and apply to all home-shares including those operating under business licenses obtained prior to the effective date of the ordinance.
The Home-Sharing Ordinance provides for regulations of two types of Short-Term Rentals:
• “Home-Sharing” – The rental of 30 consecutive days or less of one or more bedrooms in the home that is the primary residence of the host while the host lives on-site in the home throughout the visitor’s stay. The Home-Sharing Ordinance authorizes homesharing. • "Vacation Rental” – A vacation rental is the rental of 30 consecutive days or less of a home, in whole or in part, for exclusive transient use. The visitor enjoys the exclusive private use of the unit. The Home-Sharing Ordinance restates and clarifies the City’s
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longstanding prohibition against Vacation Rentals.
The City’s Home-Sharing Ordinance does not present a constraint on the production or preservation of housing.
e. Residential Leasing Requirements Ordinance
To protect the City’s rental housing stock for use as long-term permanent housing, the City enacted a Residential Leasing Requirement Ordinance on September 8, 2020. The ordinance established the following new leasing requirements which apply to all rental housing units in Santa Monica:
• Units must be rented only to natural persons
• Units must be rented only to tenants intending the unit to be their primary residence • Units must be rented for an initial term of not less than 1 year • Units must be rented unfurnished
Subsequent to adoption, on October 13, 2020 the requirements were amended to allow the following limited exemptions to the residential leasing regulations:
• Leases of owner-occupied rental housing units for more than 30 days and less than a year no more than twice a year for a total period of 6 months. This would not apply to a unit that had been the subject of an Ellis Act or owner-move-in eviction within the last ten years.
• Leases that provide temporary relocation for tenants who are subject to a temporary relocation order under the City’s tenant projection laws. • Leases of ADUs and JADUs for which plans are submitted for plan check before December 2020 for more than 30 days and less than one year. This would only apply if the ADU or JADU is located on a parcel with an owner-occupied single-unit dwelling and the owner of the single-unit dwelling resides onsite throughout the duration of the lease.
The City’s Medium-Term Housing Ordinance does not present a constraint on the production of housing and helps preserve the City’s rental housing supply.
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f. City Anti-Discrimination Ordinances
Santa Monica maintains the following anti- discrimination protections within its Code:
i. Sexual Orientation or Domestic Partnership
Chapter 4.40 of the Municipal Code prohibits housing discrimination against persons based upon sexual orientation or domestic partnership. Specifically, the Code prohibits unlawful real estate practices, generally defined as the refusal to treat persons fairly in the sale, lease, or rental of housing; the provision of credit or insurance; the advertisement of housing; and the provision of tenant services. In addition, the Code prohibits evictions against any tenant on the grounds that he or she has breached a rental agreement if the alleged breach arises from an increase in the number of occupants due to the domestic partnership of the tenant provided that the occupancy by the tenant’s domestic partner and children of the domestic partneris otherwise lawful.
ii. Persons Living with AIDS
Passed by the City Council in 1988 as one of the first ordinances in California to address AIDS discrimination, Chapter 4.52 of the Municipal Code prohibits housing discrimination against a person with AIDS, a history of AIDS, or those regarded as having or transmitting AIDS.
Specifically, the Code prohibits unlawful real estate practices, which are generally defined as the refusal to treat persons fairly in the sale, lease, or rental of housing; the provision of credit or insurance; the advertisement of housing; and the provision of tenant services. The only exception applies to the rental or leasing of any housing unit in which the owner or lessor or any member of his or herfamily occupies one of the living units and it is necessaryfor the owner or lessor to use a bathroom or kitchen facility in common with the prospective tenants. iii. Families with Children
Chapter 4.28 of the SMMC establishes the following actions as unlawful for any person offering for rent, leasing, orlisting any housing accommodation, or anyauthorized agent or employee of such person:
• Refuse to rent or lease a housing accommodation, allow access to or use of the common areas and facilities, serve a notice of termination of tenancy, commence an unlawful detainer action or otherwise deny or withhold a housing accommodation on the basis of age, parenthood, pregnancy, or the actual or potential occupancy of a minor or child.
• Advertise, represent, or include in any contract with regard to a housing accommodation offered by that person a statement that indicates any preference, limitation, or discrimination with respect to age, parenthood, pregnancy, or the potential actual occupancy of a minor child.
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• Include in any rental agreement or lease for a housing accommodation a clause providing that as a condition of continued occupancy, the tenants shall remain childless or shall not bear children or otherwise not maintain a household with a person or persons of a certain age.
• Threaten to commence or commence eviction proceedings against any tenant head of household on the grounds of breach of a rental agreement due to an increase in the number of occupants arising out of the marriage of the tenant, or the birth, adoption, or change of legal custody of a minor child of whom the tenant head of household or his or her spouse is the parent or legal guardian.
Exceptions to this chapter include housing designed and operated exclusively for senior adults and their spouses, or any nursing, convalescent, or retirement home. g. Rent Control Bootleg Unit Ordinance
In the past, City regulations regarding the status of certain units that had been illegally created and then registered with Rent Control caused conflict. To address this, the City passed an ordinance in 2008 that set forth terms to allow these “bootleg units” to become legal, nonconforming. Pursuant to SMMC Section 9.27.090, a “bootleg unit” is defined as “a rental unit registered with the Santa Monica Rent Control Board, which was built or created without City planning or building permits.” Typically, these units do not meet applicable development standards, but the ordinance allows for the unit to not be required to meet setback and density requirements if the unit is or can be made habitable pursuant to the Building Code. While the legalization of these units might require the addition of parking for the unit, if the Community Development Director determines it is not feasible, the requirement may be waived. The Rent Control Bootleg Unit Ordinance does not present a constraint on housing as it provides a path forward to legalize existing units.
h. Water Neutrality Ordinance
In response to the State emergency proclamations in 2014 and the Governor’s drought-related executive orders in 2014 and 2015, the City developed a water neutrality ordinance in order to counterbalance increasing potable water demand from new development. Adopted in 2017, the City’s water neutrality ordinance, which is codified in SMMC Section 7.16.050 (the “Water Neutrality Ordinance”), imposes a land use requirement that new development offset net new potable water demand through on-site water saving measures or, alternatively, by installing equivalent off-site improvements (such as water saving toilets and shower heads) or paying an in-lieu offset fee, which is used by the city to fund off-site improvements.
The City of Santa Monica is an urban water supplier. Urban water suppliers are required to prepare and implement an Urban Water Management Plan (UWMP) and a Water Shortage Continency Plan (WSCP) in accordance with California Water Code, §10610-10656 and §10608.
The Water Neutrality Ordinance is an effective water conservation tool that is considered an
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integral part of the City’s UWMP and WSCP. These plans support the City’s long-term resource planning to ensure that adequate water supplies are available to meet existing and future water needs. The City’s UWMP and WSCP were last updated and adopted by the City Council on June 8, 2021.
The Water Neutrality Ordinance applies to new development, including new housing development. A 1:1 offset of the new potable water demand is required for new development, however, the ordinance allows a lower offset of 0.5:1 for new affordable housing development and new ADUs
New development projects with projected usage equal to or less than their calculated baseline water demand (i.e. the average annual water demand the previous five years) are not required to offset water usage. Therefore, these projects are not impacted by the Water Neutrality Ordinance at all since they do not generate net new water demand.
In reviewing the Water Neutrality Offset Fees assessed to multi-family and mixed-used developments over the past four years, the actual fee assessed in comparison to the development's job value is minimal or insignificant. Thirty-six projects were analyzed with an average valuation of approximately $7.2 million. For these thirty-six projects, the average Water Neutrality Offset Fee assessed was $67,585, or less than 1% of the valuation for the development.
City staff is not aware of any development project that has been reduced in scope or not built due to Water Neutrality Offset Fees, nor has any project appealed the fees due to undue hardship.
In addition to the minimal Offset Fee to project valuation percentage described above, the following factors also contribute to minimizing or reducing any perceived constraints of Water Neutrality compliance on housing developments:
• When older developed sites are redeveloped, the impact of Water Neutrality Offset Fees on the development can be insignificant or non-existent as the redevelopment will use new high-efficiency water saving fixtures (e.g., low flow toilets and high efficiency faucets) that will replace older, higher water consumption fixtures. • Projects that choose to, or may be required to in the future, use recycled water, will have a significant reduction in potable water demand, resulting in a corresponding reduction, or elimination, of the Water Neutrality Offset Fee.
• 100% Affordable Housing projects have a reduced offset of 50% of the projected new potable water demand, thus lowering the Water Neutrality Offset Fee accordingly. • ADU projects (conversions or additions) for both single-unit and multi-unit properties are exempt from Water Neutrality Offset Fees if the total water demand for the parcel (including the demand created by the new ADU) is below the property’s Water Conservation Threshold.
• If an ADU project is not exempt from the Water Neutrality Offset Fee (per the previous bullet), the new water demand offset is reduced to 50%, thus lowering the Water Neutrality Offset Fee accordingly.
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Water Neutrality Fees are assessed on a case-by-case basis since the baseline water usage (the average annual water demand the previous five years) is specific to each site and its land use. The City recognizes that there may be potential sites where the Water Neutrality Offset Fee could potentially pose impactful constraints such as redeveloping an existing parking lot (i.e., where the baseline is typically zero) or a single-story commercial site for housing purposes (i.e., a change of use with a relatively low baseline for the new project). The City is in the process of evaluating potential impacts and identifying mitigation measures (e.g., reduced offsets, default baseline values), if necessary, in such cases and balance that with water supply availability to ensure the community has access to a reliable and affordable water supply.
B. NON-GOVERNMENTAL CONSTRAINTS
State law [California Government Code, Section 65583(a)(6)] requires Housing Elements to contain an analysis of nongovernmental constraints to the maintenance, improvement, or development of housing for all income levels including cost of construction, the price of land, and the availability of financing. Potential nongovernmental constraints are largely determined by market conditions over which local jurisdictions have little control. However, local governments can influence market conditions and their associated costs even if only indirectly.
1. Construction Costs
A number of factors, such as the type of construction, site conditions, application of parking, unit size, fire safety requirements, and amenities, all impact the cost of housing. In general, multipleunit housing projects are less expensive to construct than single-unit housing. However, construction costs vary significantly depending on the size of the unit and the number and quality of amenities offered. These include features such as parking supply, swimming pools, rooftop gardens, gyms, and other less obvious decisions based on the types of flooring, appliances, light fixtures, and quality of cabinetry and woodwork.
Based on recently completed affordable housing projects built in the City, Santa Monica Housing Office data indicate that total development costs average $480,000 per unit4. Ofthese total costs,it is estimated that $300,000, or 69%, are “hard costs”related to construction. Total development costs have increased in the past several years due to labor and material availability constraints. Based on construction cost estimates prepared by a third-party City consultant and interviews with market-rate developers, total development costs of apartment projects are approximately $799,000 per unit. Of these total costs, it is estimated that $413,000, or 52%, are “hard costs” related to construction5. Though construction costs comprise a large portion of the total development costof a project, the costs in Santa Monica are not atypical 4 November 20, 2019 HR&A Feasibility Analysis
5 HR&A Advisors and MGAC 2021
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compared to Los Angeles County and therefore, would not constitute an actual constraint on housingproduction.
2. Land Costs and Availability
Land costs include the cost of acquiring land. Land costs typically account for a large share of the total housing production costs. In Santa Monica, one of the primary market constraints to producing market rate and affordable housing is land cost. This is directly attributable to the City’s desirable location and limited availability of vacant and developable land for residential development. Land costs can vary depending on which area of the City the project is located, ranging from $690 per square footin Downtown to $430-$435on LincolnBoulevard/Main Street and the Boulevards. Land costs on recent affordable housing projects in the city averaged $180,000 per unit6 comprising 37% of the total unit development cost. Land costs for marketrate apartment projects are approximately $233,000 per unit comprising 29% of the total unit development cost7.
The persistent demand for housing and competition for limited available land has kept Santa Monica residential land values high for many years. The combination of non-governmental constraints (e.g. high land costs) and governmental constraints (low-density development standards) are a constraint to new residential development. It is often challenging to find sites that are large enough to accommodate projects at a preferred development scale (i.e., 60- to 100-unit projects at four to five stories). To the extent that total development costs can be reduced through changes in zoning, development standards, City-imposed development costs, and/or permit processing time, affordability goals can be better accomplished.
3. Availability of Financing
The availability of financing is a critical factor that can influence the cost and production of housing. There are generally two types of financing used in the multi-unit housing market: (1) construction financing used for initial site preparation and construction; and (2) permanent financing used to purchase existing buildings or to pay off more-expensive construction financing. Both of these products are generally distinguished from financing available to purchasers of single-unit dwellings as they are commercial real estate products, and there is less government involvement to stabilize rates and availability of debt.
The availability and cost (i.e., interest rates) of financing can substantially impact housing production either because it adds cost to a project or because it reduces the value or attractiveness of the sale/purchase of a completed project. Generally, the cost of development in Santa Monica and associated risks present challenges for developers to secure financing for new multiple-unit buildings. The COVID-19 pandemic has also had an impact broadly on the 6 November 20, 2019 HR&A Feasibility Analysis
7 HR&A Advisors and MGAC 2021
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availability of financing although less so for multiple-unit developments. While interest rates remain reasonably low, lenders have been underwriting projects more conservatively during the pandemic leading to tightened credit despite affordable interest rates. These impacts are likely to ease as pandemic conditions continue to improve and the economy recovers.
4. Requests for Housing Development at Reduced Densities State law requires the Housing Element to include an analysis of requests to develop housing at densities below those anticipated in the sites inventory. In Santa Monica, density is controlled differently between residential and nonresidential zone districts. In residential zones, density limitations are traditionally prescribed, whereas in nonresidential zones, density is controlled through a combination of building height and FAR development standards. Through a review of projects within these different zone types, projects in residential zones have typically been developed at or below density maximums. This is largely due to when the City’s Affordable Housing Production Program (AHPP) requires affordable units to be provided on site versus when a developer can pay an in-lieu fee. While this can be viewed as a constraint on housing production, it must be weighed against the need for affordable housing. However, Housing Element Program 2.C proposes to reevaluate the City’s AHPP in comparison to achieving the City’s housing goals., and Programs 1 F and 1 J will ensure that housing development projects remain feasible, taking into consideration any AHPP requirements. As for the City’s nonresidential zones, it is rare for developers to not maximize the allowable development potential of a parcel,and therefore, it can be assumed that developers are not under-densifying their developments. Additionally, as described throughout this appendix, the City has implemented several measures to streamline housing projects, which limits or removes the City’s discretion to reduce densities.
The sites inventory analysis takes into account past production trends when calculating the capacity for residential redevelopment amongst various zone districts throughout the City.
5. Length of Time Between Project Approval and Applications for Building Permits
State law requires an analysis of the length of time between receiving approval for a housing development and submittal of an application for a building permit. On average, the time between these two stages of a housing project varies between three to six months for smaller projects, and sometimes up to a year or more for larger mixed-use projects. This time between approval and applying for a building permit can be contributed to the applicant preparing necessary construction drawings, finalizing construction financing, and retaining various contractors, amongst other actions.
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Packet Pg. 691 Attachment: Appendix E Constraints Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F:
Report on Suitable Sites
Inventory Analysis
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Packet Pg. 692 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-1 City of Santa Monica 2021-2029 Housing Element
Introduction
Santa Monica’s Regional Housing Needs Allocation for the October 2021 through October 2029 planning period is 8,895 units broken down as follows:
Income Level % of AMI* Units % of RHNA
Allocation
Very Low 31-50% 2,794 31%
Low 51-80% 1,672 19%
Moderate 81-120% 1,702 19%
Above Moderate 120%+ 2,727 31%
Total 8,895 100%
Source: http://SCAG.ca.gov.gov/Housing/rhna.htm
* AMI – Area Median Income.
Note: SCAG’s RHNA does not include the income level of Extremely Low Income (ELI) (0-30% AMI) units, which are required by the City’s AHPP. ELI units produced in the City are counted towards SCAG’s Very Low Income category.
The housing element of the general plan must include an inventory of land suitable and available for residential development to meet the locality’s regional housing need allocation (RHNA) by income level. This inventory is known as the Suitable Sites Inventory (SSI) and is used to demonstrate that there is sufficient land at appropriate densities and development standards to accommodate the RHNA at the income levels specified. This document has been prepared to outline the methodology used for identifying potential housing sites for the City of Santa Monica’s 6th Cycle Housing Element SSI. The methodology follows State Housing Element Law and the guidance of the Housing Element Site Inventory Guidebook prepared by the Housing and Community Development Department (June 2020).
Overview of the City’s Suitable Sites Inventory
Per State law, the City’s SSI consists of sites that are reasonably likely to be redeveloped into residential during 6th Cycle planning period. The SSI includes sites with approved/pending projects, underdeveloped sites that were identified, and non-site-specific accessory dwelling unit potential. A total of 340 sites are identified.
Under current zoning, the SSI has an anticipated unit potential of 7,596 units with capacity for 4,064 affordable units. Therefore, the City will have an anticipated shortfall of 1,109 lower income units and 1,003 moderate units. State law dictates that if sufficient capacity to meet the RHNA cannot be demonstrated based on existing zoning,the City is required to rezone sites on the inventory by October 15, 2024 to demonstrate the ability to meet sufficient capacity. The rezoning programs are Programs 1.F, 1.J, 1.K, and 4.A. With these rezoning programs, the City’s
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Packet Pg. 693 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-2 SSI capacity is estimated to be approximately 13,600 units which includes capacity for 8,044 lower income units and 1,901 moderate income units.
Methodology for Suitable Sites Inventory
The City of Santa Monica maintains a comprehensive land use inventory that includes details for every parcel within City limits. The methodology for the Suitable Sites Inventory consists of a multistep process that narrows down the list of suitable sites from the City’s Land Use Inventory. The Land Use Inventory was first created in 2010 during preparation of the City’s Land Use and Circulation Element, and is a master inventory of each parcel in the City that identifies existing uses, ownership, building age, zoning, and other information. The Land Use Inventory is updated every two years using assessor land use information, the City’s building permit database (for demolitions and new construction), and site visits to confirm existing uses.
The SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning and general site constraints such as historic designations and land use. After screening out unavailable sites, City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, market factors, physical attributes, ownership, and other local knowledge by City Staff.
Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. The methodology is described step by step below:
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Packet Pg. 694 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-1 City of Santa Monica 2021-2029 Housing Element
Step 1: Identify Available Multi-Unit Residential Zoned Parcels • Difficult to identify Single Unit parcels for SSI
Step 2: Site Screening
• Properties with Residential Unlikely to
Redevelop (rent control units, condos,
multifamily, SB330 replacement
requirements)
Step 3: Assess Suitability of Sites
Review Residential Potential with Consideration to:
• Parking lots (or A-lots) associated with
Commercial fronting parcels
• Parking lots associated with religious
institutions
• Vacant sites
City Land Inventory
1. Filter out: Single Family,
Ocean Park Single
Family, Ocean Park
Duplex, Residential
Mobile Home
Residential Parcels Commercial and City Parcels
2. Remove properties
based on Site
Constraints & Other
Known Factors
Screened Commercial and City Parcels
4. Assess
Suitability of Sites
based on Factors
Step 3: Categorize Potential Sites
Categorize Potential Sites that have highest
potential for turnover
Step 1: Identify Available Commercial Zoned Parcels & City Owned Properties • Ensures No Net Loss
• Consistent with Housing Preservation goals and policies • Consistent with LUCE Neighborhood Protection goals and policies Step 2: Site Screening
Remove sites based on Factors That Impede Residential Redevelopment • Government Open Space
• Historic Landmarks
• Affordable Housing & Condominiums
• Unique land uses (cemetery, hospital, parks, libraries, fire/police stations etc)
• Under Construction or Recently Constructed Projects
• Newer buildings (constructed post 1980)
• Right-of-ways (such as medians/transportation corridors) Step 4: Assess Suitability based on Site Specific Evaluation Review Residential Redevelopment Potential with Consideration to:
• Physical Attribute - Sites with these factors are most suitable:
• Sites of 15,000 sf or more
• Corner parcels
• Existing Use - Sites with these factors are most suitable:
• Parking lots (if site is completely or partially developed as parking)
• One story building
• Vacant (no tenants) or Less than 2 Tenants
• Redevelopment Potential – Sites with these factors are most suitable • AVR less than 0.5
• Ownership by known housing provider
• Developer interest based on current or past discussions with City staff
• Other Local Knowledge – Sites are removed if
• Existing tenants have longevity (eg, well known successful tenant with long term lease)
• Significant improvements and investments have occurred on the site within the past 4 years
1. Approved/Pending Projects
2. Prior SSI properties
3. Downtown Community Plan
buildout
4. City Owned Sites
5. Vacant & Parking Lots
6. Auto Dealership Inventory Lots
7. Recently sold/for sale
8. Large parcels (15,000 sf +)
9. Development Potential of 20K sf
10. Remaining parcels less than 0.5 ILR
3. Categorize
Potential
Sites
SSI Sites
*Identified as high potential sites meeting the
suitability factors of Existing Use, Physical Attribute, and Development Potential
2. Remove
properties if there
are existing
residential uses
Screened Residential Parcels
3. Assess
Suitability of Sites
SSI Sites
*Identified as A lots associated with commercial
fronting parcels or those associated with religious
institutions
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Packet Pg. 695 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-3 City of Santa Monica 2021-2029 Housing Element
Step 1: Identify Available Commercial and Residential Parcels As a first step in the SSI process, parcels that are not available for residential redevelopment due to zoning were removed from consideration. Parcels in the City’s single unit zones (R1, OP1, and OPD) were filtered out from the SSI process for the following reasons:
• Lack of vacant parcels in these zones
• Difficulty in identifying specific parcels for the inventory since there are no known factors that could assist in determining which parcels would be redeveloped. • Even if parcels were identified, redevelopment would likely consist of demolition and replacement of existing on-site units
• Parcels in the Residential Mobile Home (RMH) and Open Space (OS) districts are also removed from the SSI process since these parcels are protected by the City for low income housing and open space uses respectively.
Step 2: Site Screening for Non-Suitable Parcels
As a second step in preparing the SSI, parcels in the City that are not potential candidates for housing development during the Housing Element planning period were screened out based on a set of criteria. Since housing development on residential and commercial parcels are influenced by different sets of factors, residential and commercial parcels were separately screened.
Commercial Parcels
In general, commercial parcels meeting any of these criteria were determined to not be suitable as a housing site and screened out from the SSI:
• Historic Designations: Designated historic resources, including Landmarks and/or Structures of Merits, are protected by the City’s Landmark Ordinance and the California Environmental Quality Act. Demolition of historic resources are only permitted with a Certificate of Hardship. While there have been instances where new residential development is proposed on larger parcels in conjunction with the preservation or adaptive reuse of historic resources, such instances are uncommon.
Therefore, the presence of historic resources is presumed to preclude new housing development on the site.
• Under Construction or Recent Construction Projects: Parcels that are under construction or have recently completed projects are not available for redevelopment into housing and therefore, are screened out from the SSI process. • Commercial Entitlements: Parcels that have approved or pending entitlements for solely for commercial uses are screened out from the SSI process since these parcels will be redeveloped into commercial.
• Government or Institutional Uses: Parcels that have unique land uses such as governmental or institutional uses are unavailable for redevelopment and are also screened out from the SSI process. These include parcels with uses such as the Civic Center government uses (Santa Monica City Hall, Los Angeles County Courthouse, Civic Auditorium), UCLA and Providence Saint John hospitals, Santa Monica Cemetery,
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Packet Pg. 696 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-4 SMUUSD schools, Santa Monica College, public parks, utilities, libraries, police/fire stations, transportation infrastructure/Metro Expo Light Rail and the Santa Monica Airport. The City and institutions are unable to remove these uses in this housing element cycle as they are necessary to serve the community. • Residential Uses: The City filtered the inventory to remove parcels that are currently occupied by residential uses. In particularly, parcels developed with affordable housing, condominium units, and rent control units are highly unlikely to be redeveloped. Affordable housing is protected by long term deed restrictions, and therefore were screened out. Condominium units are common interest properties with multiple owners, and therefore, are screened out due to infeasibility of acquiring all condo ownership parcels. Rent control units are governed by the City’s Rent Control laws that limit the removal of such units and are therefore screened out from the inventory.
• Newer Buildings: Parcels with newer buildings developed post 1980 are highly unlikely to be redeveloped as supported by a review of current approved and pending projects (see Attachment 1, Table 2).
Residential Parcels
The City screened the inventory to remove residential parcels that are currently occupied by residential uses. This approach is conservative since the City’s general plan emphasizes the protection of existing residential units and because parcels with residential uses are governed by SB330 unit replacement requirements. Furthermore, parcels developed with affordable housing, condominium units, and rent control units are unlikely to be redeveloped. Affordable housing is protected by long term deed restrictions, condominium units are common interest properties with multiple owners, and rent control units are governed by the City’s Rent Control laws that limit the removal of such units.
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Packet Pg. 697 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-5 City of Santa Monica 2021-2029 Housing Element
Step 3: Categorizing Sites
After screening out parcels that are not available for redevelopment, the remaining list of sites were categorized.
Commercial Parcels
Based on this first set of screening criteria, 1,368 potential commercially zoned sites and Cityowned sites were initially identified. These sites were then categorized according to the figure below:
Figure F-1 Category of Potential Commercially Zoned and Mixed Use Zoned Sites Category Description Count of Parcels Land SF
1 Approved and Pending Housing
Projects
172 3,222,092
2 Prior SSI Sites 46 1,015,545
3 DCP Buildout 12 180,263
4 City-Owned Sites 106 3,723,505
5 Parking Lots 116 1,026,709
6 Auto Inventory Lots 41 407,651
7 Parcels with recent/active sales 47 385,129
8 Underutilized Sites (20,000 excess
sf development potential)
183 5,953,899
9 Large Parcels (15,000 sf+) 66 2,268,697
10 Remaining Sites less than 0.5 ILR 579 3,721,870
Category 1 Sites: Pending/Approved Housing Entitlements The RHNA projection period for the 2021-2029 Housing Element begins on June 30, 2021.
Therefore, pipeline housing projects that are pending or have received approved entitlements butdid not receive a building permitas of July 1, 2021are expected to counttoward the 6thCycle RHNA.
Category 2 Sites: Prior Sites listed in the 2013-2021 5th Cycle Housing Element 83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have undergone entitlements but the remaining have not. These are categorized as Category 2 Sites.
Category 3 Sites: Downtown Buildout Sites
As part of the Downtown Community Plan (DCP), sites in the Downtown were identified for potential redevelopment. A number of these sites have already undergone pending and
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Packet Pg. 698 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-6 approved entitlements (captured in Category 1), and as such, are eliminated from further consideration. In addition, a small number were previously identified in the prior SSI for the 5th Cycle Housing Element (hence are captured in Category 2). The remaining DCP sites are classified as Category 3.
Category 4 Sites: City-owned Sites
An important strategy for the City to meet its RHNA targets is the utilization of existing City owned sites for housing, particularly affordable housing. All City owned sites that are not currently developed with open space/parks, community centers, civic uses, utilities, etc. are categorized as Category 4 sites. Public parking structures such as Parking Structure (PS) #3, PS#1, PS#2, and PS#4 are reviewed in this category since these structures require seismic retrofit improvements for their continued operation. Additionally,the City’s parking lots on Main Street are reviewed as potential housing sites.
Category 5 Sites: Parking Lots
There are no vacant sites in the City as it is highly urbanized. No vacant sites are located in the commercial and mixed use zones. However, a number of sites in the City are developed as surface parking lots. Surface parking lots are very underutilized and represent the greatest opportunity for new housing without displacement of existing uses. Redevelopment of these lots are considered with the commercial uses they serve.
Category 6 Sites: Auto Inventory Lots
These are parcels currently being utilized almost entirely as auto inventory surface lots, with the majority occurring on the eastern end of Santa Monica Boulevard. Auto dealerships have indicated interest in turning over these large surface lots into redevelopment opportunities as they are rethinking their sales operations.
Category 7 Sites: Recent/Active Sales
Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites (such as Loopnet), a number of properties have recently sold during 2019-2021 or have active sales listings. These sites could have redevelopment potential.
Category 8 Sites: Underutilized Sites (20,000 sf excess development potential) Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to have a net new development potential of 20,000 sf or greater (based on their existing built area compared against the maximum floor area permitted).
Category 9 Sites: Remaining Large parcels
Category 9 sites are all remaining sites that are 15,000 sf and larger.
Category 10 Sites: Remaining Parcels with 0.5 ILR or less Category 10 sites are all the remaining sites (not meeting Category 1-9) with an improvements to land value ratio (ILR) of 0.5 or less.
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Packet Pg. 699 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-7 City of Santa Monica 2021-2029 Housing Element
Residential Parcels
For residentially-zoned parcels, sites that were not screened out are categorized as religious institutional uses, or parking lots. Approximately 38 parcels were identified as parking lots that are associated with religious institutions and 97 parcels are surface parking lots for adjacent street fronting commercial uses.
Figure F-2 Category of Potential Residentially Zoned Sites Category Description Count of Parcels Land SF
11 Religious Institutions 38 555,589
12 A-Lots and Residentially Zoned Parking Lots 97 911,847 Category 11 Sites: Religious Institutions
Category 11 sites are properties of religious congregations (churches, synagogues, etc.).
AB1851 was passed in 2020 to remove an important barrier to housing construction on lands owned by a religious institution. The law states that a jurisdiction cannot deny a housing project proposed by a religious institution on the sole basis that it will remove parking. A number of religious institutions with large surface parking lots are located throughout the City. These lots could play an important part in providing affordable housing. Program 4.B of the Housing Element would amend the Zoning Ordinance to create special standards for housing projects on sites owned by community assembly uses so that these sites would be incentivized for the production of housing.
Category 12 Sites: A-Lots and Residentially Zoned Parking Lots “A-Lots” are residentially-zoned (R1/R2/R3/R4) parcels with an “A” Off-Street Parking Overlay.
Within the City, there are 42 A-lots. Zoning regulations prevent their use to enable the expansion of associated commercial uses, but also effectively prevent their redevelopment for housing. Additionally, there are other residentially-zoned parcels without the A-Lot overlay that are similarly developed as surface parking lots. These surface parking lots are intended to support the parking needs of commercial corridors and neighborhood commercial areas, and to serve as a buffer between commercial and residential uses. The existing multi-unit residential zones have density caps of 4-6 units regardless of the size of the property, which limits their capacity for housing potential.
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Packet Pg. 700 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-8 Step 4: Evaluating Suitability of Nonvacant Sites for Housing Potential Government Code section 65583.2(g)(1) requires that, where non-vacant sites comprise over 50% of the Suitable Sites Inventory, existing uses are presumed to impede development unless findings with substantial evidence are provided that the use is likely to be discontinued. Santa Monica is a dense, urban coastal community and is entirely built out with little to no vacant land remaining. Therefore, the methodology used to identify the suitability of non-vacant sites for housing potential must consider factors such as site physical characteristics, existing uses, improvements to land value ratio, ownership, development interest, location and context, local knowledge, and environmental constraints.
Methodology
Once all the screened sites were categorized,
all individual sites in Category 1-10 were
reviewed by the City’s Housing Policy team
using Google Streetview, City Accela permit
database, and if necessary, in-person site
visits. All of the sites are non-vacant, and have
an existing use or are developed as parking
lots. The City focused the list of non-vacant
sites to those that are underutilized and
primarily located within the mixed use and
commercial districts where the City has encouraged housing. These districts include, but are not limited to, the Downtown districts, the Bergamot Area, and the corridors of Santa Monica Boulevard, Wilshire Boulevard, Colorado Avenue, Broadway, and Lincoln Boulevards. Recent project applications that have been filed by the City support the assumption that there is a strong housing demand in these districts.
Each site was analyzed to determine its likelihood and suitability for residential redevelopment based on a set of site-specific factors. These factors were selected based on City Staff’s experience and long standing knowledge of the current projects in the pipeline and development interest in certain areas of the City. Interviews with local developers and architects from the Housing Production Technical Working Group and the general public confirmed also informed the factors and assumptions in the Site Inventory. The criteria and factors for the City’s Housing Element site inventory was presented to the public, Planning Commission, and City Council where all agreed these are appropriate criteria.
The City also verified its assumptions by analyzing recent project application since adoption of the LUCE to assess development trends. Since July 2010, 152 residential and mixed use residential development applications have been received for more than 5,553 new housing units – all of which have occurred on non-vacant sites. A review of these past and current housing projects support the use of these site specific factors (see Attachment B), which are described below:
Per HCD, a vacant site is a site without any
houses, offices, buildings, parking lot, or other
significant improvements on it. The City of
Santa Monica is a dense, urban coastal
community and is entirely built out with no
vacant land remaining. Nonvacant,
underutilized sites will be relied on to achieve
the 6th Cycle RHNA. This is supported by past
residential development trends which has
primarily consisted of new multi-unit buildings
replacing older one-story buildings on infill
sites (see Attachment 1).
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Packet Pg. 701 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-9 City of Santa Monica 2021-2029 Housing Element
• Site Physical Characteristics - Sites were reviewed for physical characteristics that could make them more amenable to residential development, such as size, location relative to the urban grid, and shape of the site.
o Size: Based on a review of past and current housing projects (see Attachment 2), housing projects have occurred on commercial and mixed used zoned sites that are as small as 7,500 sf. This includes 100% affordable housing projects where site sizes have ranged from 7,500 sf to 30,000 sf.
Housing development trends in the City indicate that a site that is 15,000 sf is generally considered sufficiently sized for residential redevelopment in the mixed-use, commercial zones (see Attachment 2). Since the majority of the housing projects (more than 90%) have occurred on sites that are 15,000 sf or greater, City staff used a size threshold of 15,000 sf for the SSI process. Sites as small as 7,500 sf may be appropriate for certain projects such as those in the Downtown and/or 100% affordable housing projects which do not require parking.
Individual parcels less than 15,000 sf are unlikely to be developed. However, if two smaller adjacent parcels share common ownership, there could be potential for housing development depending on the remaining factors. The City does not have any restrictions on lot consolidations for the commercial or mixed use zoning districts, and consolidation is a common practice. Housing developers have historically consolidated lots for development and such consolidations are administratively approved as part of the plan check process. o Corner Parcels or Parcels with Alleys: As a general policy, the City’s General Plan discourages vehicular access from the main boulevard. Therefore, based on City staff experience as well as current trends of development, sites with corner parcels are more likely to be redeveloped given that vehicular access can be taken from the side street or from the alley.
o Other Factors: Sites were reviewed for any other potential physical characteristics that could preclude residential development, such as narrow depth/width, grade, and other physical constraints such as lack of access. • Existing uses – Due to the built up nature of the City, past and currently proposed housing projects have all occurred on non-vacant sites. These sites were built or proposed on sites with existing uses consisting of older buildings or surface parking lots as listed in Attachment B. Using Google Streetview supplemented with site visits as necessary, existing uses on the site were assessed to determine its future viability and likelihood for the uses to be discontinued. Based on past experiences as well as review of approved/pending projects (see Attachment 1, Table 2), City staff determined that sites with these existing uses are most suitable:
o Parking lots (if site is completely or partially developed as parking) - Sites that are developed as parking lots are considered more likely to be redeveloped than sites with existing building improvements.
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Packet Pg. 702 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-10 o One story building - Sites that are developed with one story buildings are also more likely to be redeveloped as they are considered underutilized. o Vacant (no tenants) or Less than 2 Tenants - Similarly, sites that are vacant or have only a single tenant are more likely to turn over than multiple tenant sites. • Redevelopment Potential – Sites were also reviewed using redevelopment potential factors such as the improvements to land ratio based on assessor’s value of land to improvements ratio, ownership information, and known developer interest. o Improvements to Land Value Ratio - A low improvements to land value ratio (ILR), which is the ratio of improvement value to the land value, is a strong indicator of the likelihood that a site has a high probability of being redeveloped.1 A review of current pending and approved projects show that these projects have occurred almost all on commercial/mixed use zoned parcels with ILR less than 0.5 (see Attachment 1, Table 2).
o Ownership – Ownership of properties was also considered in the analysis. As previously stated, if two smaller adjacent parcels share common ownership, there is a high potential for housing development. The City does not have any restrictions on lot consolidations for the commercial or mixed use zoning districts, and will continue to facilitate consolidation through administrative lot tie agreements as part of the plan check process. Therefore, adjacent parcels that are held by the same owner could be developed jointly as evidenced in the City’s list of approved and pending projects (see Attachment 1, Table 2).
Furthermore, parcels that are owned by known housing developers, for example, are very likely to be redeveloped. Several underutilized sites in the City are owned by State entities, institutions, and public utility companies that have the potential to accommodate housing, including the Department of Motor Vehicles (DMV) site at 2235 Colorado Ave, Santa Monica Municipal Unified School District (SMMUSD) former district offices at 1651 16th St, and the University of California, Los Angeles (UCLA)-owned parking lots at 1521 & 1601 Santa Monica Blvd. The City initiated discussions with these entities to inquire about their potential interest in housing development. Both the DMV and UCLA indicated that they had no plans for future housing on their properties. However, the SMMUSD indicated their intent and interest in developing housing for their staff at their former district offices (see Attachment 4). If State controlled sites are included in the SSI, HCD requires documentation be provided that shows that housing can be accommodated with the Housing Element planning cycle.
1 The Institute of Urban and Regional Development (IURD) at the University of California, Berkeley suggests that a ratio of improvement value to land value that is below 1.0 is an appropriate factor to identify potential housing sites on infill commercial properties.
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Packet Pg. 703 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-11 City of Santa Monica 2021-2029 Housing Element
o Known Developer Interest – If a developer has expressed interest in developing a site either through a pre-submittal meeting with the City or through general inquiry, then there is a higher likelihood that the site will be redeveloped. • Location and Context – The location of the site was also considered in terms of its access to schools, jobs, transit, residential amenities such as parks/open space, health care services, and retail shops such as grocers. Many of the sites south of Olympic Boulevard lack access to these amenities and services, and, as such, were determined to not be suitable. Additionally, existing/past housing development trends in the site surrounding area were considered – reviewing if the project is located in an area where there is significant residential growth.
• Other Local Knowledge – City Staff have in-depth local knowledge of properties that could preclude site development. For example, specific parcels were removed if:
o Existing tenants have longevity (eg, well known successful tenant with long term lease) - For example, uses that are more unique in a particular location (such as a successful grocer in a residential neighborhood, a popular restaurant, long-standing reputable business, etc.) have demonstrated longevity, and, as such, may be considered an impediment to redevelopment of the site.
o Significant improvements and investments have occurred on the site within the past 4 years – Where there has been significant investments and improvements that have been made to a site, the site is unlikely to be redeveloped in the near term.
• Environmental and Infrastructure Constraints –HCD requires that cities identify any environmental constraints (e.g., fault hazard zones, flood areas, landslide zones, very high fire hazard severity zones) and infrastructure limitations that have the potential to impact the development viability of the identified sites. These constraints can include natural resources, hazards/safety concerns, or lack of sufficient infrastructure capacity. All parcels included in the sites inventory were reviewed for any known environmental constraints, such as flood zones, steep slopes, and other possible constraints to development feasibility. The sites included in the inventory are not constrained by topography, known environmental factors, or other site-specific constraints that would limit development. As summarized in Attachment 3, environmental concerns do not pose a constraint to housing production. Infrastructure upgrades would be necessary to accommodate the development of 8,895 units in the next 8 years but these are anticipated to occur with the City’s Capital Improvements Program or in conjunction with housing projects. Therefore, infrastructure systems do not pose a constraint to housing.
Evaluation
City staff reviewed the current status of each site and evaluated the sites using the factors above. Sites were given a rating of whether they had low, medium, medium high, and high
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Packet Pg. 704 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-12 potential for housing redevelopment. The table below show the qualifying factors for each rating. Staff did extensive research on the site, reviewing physical conditions, existing uses and other factors and removed any identified sites with demonstrated impediments. Finally, staff also conducted additional market research to support assumptions around parcel turnover at thesites. In general, as shown in the table, high potential sites include those that are adequately sized or have common ownership with adjacent parcels, are occupied with single tenants, are underutilized and occupied with aging, one story buildings, and are located in proximity to other recent housing projects.
Figure F-3 Sites Inventory Evaluation Factors
Factors Utilized Redevelopment Potential
High Medium
High
Medium Low
Physical Attribute
Sites of 15,000 sf or more x x x
Corner parcels x x
Existing Use
Parking lot or One Story x x
Vacant or Less than 2
tenants
x
Redevelopment Potential
ILR less than 0.5
At least
one
x
Ownership by Developer
Known Developer Interest
Location
Near transit/amenities x x x
Other Local Knowledge
Existing uses have longevity x
Recent investments x
The Suitable Sites Inventory is comprised of 341 high potential sites categorized as follows.
Category 1 Sites: Pending/Approved Housing Entitlements As of May 2022, there were approximately 2,594 approved units (of which 637 are affordable) and 2,550 pending units (of which 420 are affordable). All approved and pending projects are considered high potential sites.
Category 2 Sites: Prior Sites listed in the 2013-2021 5th Cycle Housing Element The parcels listed in the 5th Cycle 2013-2021 Housing Element were re-evaluated to determine suitability for housing potential. Parcels were determined to have low potential if they are inadequately sized (less than 7,500 sf), have undergone recent tenant improvements, or are occupied with newer tenants (indicating long term leases). Remaining sites were evaluated and considered high potential if they are adequately sized and if there is a low ILR of less than
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Packet Pg. 705 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-13 City of Santa Monica 2021-2029 Housing Element
1.0 FAR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or unoccupied, etc).
Category 3 Sites: Downtown Buildout Sites
As part of the Downtown Community Plan (DCP), sites in the Downtown were identified for potential redevelopment. All these sites have low ILR and have older buildings, indicating high potential. The Downtown is one of the most attractive areas for housing development due in part to higher development standards for housing, access to a variety of amenities, proximity to transit, and no parking minimums. In general, the limiting factor is site size. Based on discussions with developers from the Housing Element Housing Production working group, single lot parcels (generally consisting of 7,500 sf) are infeasible to develop. Therefore, sites within the DCP that are 7,500 sf or smaller were eliminated. The remaining DCP sites are considered high potential.
Category 4 Sites: City-owned Sites
City staff reviewed all City-owned land to determine if there is potential for housing development. A number of City-owned sites have the highest potential to accommodate the production of affordable housing. These sites do not have long-term leases with outside parties that extend beyond the 6th Cycle Housing Element planning period and do not have existing uses that are non-City operated, and therefore are considered high potential. High potential City-owned sites include the parcels serving as the parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Public Parking Structure 3, and the Bank of America/Chase bank site at 4th Street/Arizona.
Category 5 Sites: Parking Lots
As previously stated, there are a number of sites in the City that are developed as surface parking lots. Many of these lots serve one-story commercial uses. These surface parking lots were considered in conjunction with the commercial uses they serve, if any. Sites were considered high potential if they are adequately sized, if there is common ownership with adjacent commercial parcels they serve, the existing buildings on the site are more than 40 years old, there is known developer interest, and if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, on-site business is not well known in the community, etc.).
Category 6 Sites: Auto Inventory Lots
Santa Monica has a number of auto dealerships with large surface parking lots used for auto inventory. In some cases, auto dealerships span multiple parcels with some on adjoined lots and some on separate lots. Some of the parcels serve as inventoryparking for used cars or new cars. Sites were considered high potential if they are adequately sized, there is common ownership with adjacent parcels, there are other multiple parcels located elsewhere that are also owned by the same owner (if so, they can adequately serve as inventory for both used and new cars), or if there has been known developer interest.
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Packet Pg. 706 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-14 Category 7 Sites: Recent/Active Sales
Properties that have recently sold during 2019-2021 or have active sales listings were evaluated and considered high potential if they are adequately sized and located in an area where residential has occurred or occurred nearby. Recently sold sites that are occupied with new tenants were excluded and determined to have low potential.
Category 8 Sites: Underutilized Sites (20,000 sf excess development potential) Category 8 sites have a net new development potential of 20,000 sf or greater (based on their existing built area compared against the maximum floor area permitted). Sites were evaluated and considered high potential if they are adequately sized and if there is a low ILR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc).
Category 9 Sites: Remaining Large parcels
Category 9 sites are all remaining sites that are 15,000 sf and larger. Sites were evaluated and considered high potential if they are adequately sized and if there is a low ILR, the existing buildings on the site are more than 40 years old, there is known developer interest, or if the existing use doesn’t appear to have longevity (e.g., existing aging one story building, single tenant or vacant, etc.).
Category 10 Sites: Remaining Parcels with 0.5 ILR or less Category 10 sites are all the remaining sites (not meeting Category 1-9) with an improvements to land value ratio (ILR) of 0.5 or less.
Based on the assessment of sites using the above factors and methodology, there are 137 parcels that have approved and pending projects for residential development (Category 1) and 185 non-vacant commercial/mixed use zoned parcels (Categories 2-10) in the City identified to have high potential for residential redevelopment. An additional 22 residentially zoned sites developed as surface parking lots are identified as having high potential, and therefore are also included in the SSI. The Housing Element includes Program 1.C to adopt standards that will incentivize A-Lots and residentially zoned parking lots to be developed in support of multi-unit housing development. Together these 340 parcels comprise approximately 5.2 million sf of land area and are included in the SSI.
Figure F-4 Summary of Commercial and Mixed Use Zoned Sites in SSI High Potential for Redevelopment
Category Description Total Land Area Count of Parcels
1 Approved and Pending Housing Projects 1,921,522 138
2 Prior SSI Sites 466,371 21
3 DCP Buildout 94,015 7
4 City-Owned Sites 778,481 24
5 Vacant Sites/Parking Lots 164,891 21
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Packet Pg. 707 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-15 City of Santa Monica 2021-2029 Housing Element
6 Auto Storage Lots 206,212 23
7 Parcels with recent/active sales 168,576 17
8 Underutilized Sites (20,000 excess sf development
potential)
767,643 30
9 Large Parcels (15,000 sf+) 135,267 6
10 Remaining Sites with less than 0.5 ILR 210,996 31
Grand Total 4,913,974 318
Figure F-5 Summary of Residentially Zoned Sites in SSI
High Potential Residentially Zoned Sites
Category Description Total Land Area Count of Parcels
11 Religious Institutions 149,307 7
12 A-Lots/Residentially Zoned Parking Lots 168,609 15
Grand Total 317,916 22
Reliance on Nonvacant Sites to Accommodate more than 50 percent of RHNA The City of Santa Monica is a dense, urban coastal community and is entirely built out with little to no vacant land remaining. As such, this Housing Element relies on nonvacant sites to accommodate 100 percent of its RHNA for lower income households. Based on analysis of the factors discussed above for each category of sites (such as age of buildings, known developer interest, low ILRs, size of sites, development trends, market conditions, ownership information), the City anticipates that the existing uses on the SSI sites will likely be discontinued during the planning period. Pursuant to Government Code Section 65583.2(g)(2), as part of its resolution adopting this Housing Element, the City will include findings stating that uses on nonvacant sites identified in the SSI to accommodate the RHNA for lower income is likely to be discontinued during the planning period.
Replacement of Affordable Units
Excluding approved and pending housing projects (Category 1 sites), two sites on the SSI have existing residential uses. As required by Government Code Section 65915(c)(3), this Housing Element includes Program 3.A, which would require new housing projects on sites with existing residential units or within the last 5 years, that have or had residential units that are lower income, rent control, or affordable units to replace those units at the same or lower income level.
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Packet Pg. 708 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Map
F- 1 Suitable Sites Inventory
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Packet Pg. 709 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-17 City of Santa Monica 2021-2029 Housing Element
Step 5: Realistic Capacity Analysis of Suitable Sites
Per Government Code Section 65583.2(c), the SSI must include a calculation of the realistic residential development capacity of the sites. To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, HCD recommends that a jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA.
Category 1 – Approved and Pending Projects
As previously stated, as of May 2022, there were approximately 2,594 approved units (includes 637 affordable) and 2,550 pending units (includes 420 affordable). These sites are listed in Appendix A. A review of the past 5th Cycle Housing Element show that 15% of approved and pending projects are withdrawn, have had permit approvals expire, or have not pulled building permits within 8 years of project approval (i.e., housing element cycle). It is not possible for City staff to predict which specific approved and pending projects would be withdrawn or ultimately not developed. Eliminating some projects and not others would be arbitrary and speculative.
However, based on information from the prior Housing Element cycle, a 15% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 2,205 approved units and 2,168 pending units that are projected to be counted towards the 6th Cycle Housing Element.
Figure F-6 Approved and Pending Projects Housing Capacity # of Units # Units Counted for SSI
(w/ 10% discount)
Category 1 Approved 2,594 2,205
Category 1 Pending 2,550 2,168
Category 4 – City-Owned Sites
The City-owned sites determined to have the highest potential to accommodate the production of affordable housing include parcels serving as parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Parking Structure 3, and the site at 4th Street/Arizona. All parcels are developed as public parking or have uses with expiring lease terms during this 6th Cycle planning period, which provide for the most housing development potential. Furthermore, these sites do not have any existing residential uses. However, the existing density standards and FARs limit housing potential. For example, the public parking parcel on Main Street is zoned R3 and has a density cap of 5 units on a parcel. Therefore, this 6th Cycle Housing Element includes Program 2.E, which would commit City-owned sites for the development of affordable housing through a public process, which would include necessary rezoning to accommodate the estimated realistic capacity for these sites. To determine the estimated realistic capacity, the City engaged with HR&A advisors and local architects who consideredexisting constraints, including, but not limited to, lease terms for commercial uses on the property located at 4th/Arizona and Property Management Agreement with associated annual leases at the Bergamot Arts Center, financial feasibility, available funding sources, etc.
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Packet Pg. 710 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-18 Based on an assumption that affordable housing would likely not be greater than 6-7 stories (due to increasing costs associated with construction type – e.g., Type 3 vs. Type 4 construction), it is estimated that the City-owned sites could accommodate a density of 150 units per acre. Therefore, applying a density factor of 150 units/acre, City-owned sites have the potential for accommodating 1,880 units. To ensure that City-owned SSI sites can be counted towards meeting the RHNA, Program 2.E commits the City to plan for a targetof1,880affordable units across City-owned sites which may include, but shall not be limited, to rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments.
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Packet Pg. 711 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-19 City of Santa Monica 2021-2029 Housing Element
Figure F-7 City-Owned SSI Sites
Address Parcel Nos. GP Designation Zoning Existing Use
Existing Base
Allowable
Density or FAR
Proposed
Density
with
Program
2.E
Land Area
(sf)
Unit
Capacity
with
Program
2.E
Other Info
1146 16th St 4281005900 Low Density
Residential R2
Public parking
lot 8 behind
Café Zella
1 unit/2000 sf
or 4 units
(whichever
less)
150
units/acre 7,500 26 No leases – parking is
City operated
1217 Euclid St 4282004900
Medium
Density
Residential
R3 Public parking
lot 7
1 unit/1500 sf
or 5 units
(whichever
less)
150
units/acre 7,500 52 No leases– parking is
City operated
1217 14th St
4282003900 Medium
Density
Residential
R3
Public parking
lot 12 behind
Petco
1 unit/1500 sf
or 5 units
(whichever
less)
150
units/acre
22,500
52 No leases– parking is
4282003901 City operated
Main St between
Ocean Park Blvd
and Kinney St
4288009900
High Density
Residential R3/R4
Public parking
lots 9, 10, and 11
on Main St
(excludes
alleys)
1 unit/1500 sf
or 5 units
(whichever
less)
150
units/acre 167,388 577
No leases– parking is
City operated; but
replacement parking
will be necessary
(Coastal Zone)
4288010900
4288014901
4288011900
4288012902
4288013905
4288015901
1333 4th St
4291011909
Bayside
Conservation BC
Bank of
America; Chase
bank
2.25 FAR 150
units/acre 52,489 181
Bank of America’s
lease ends in 2026 and
Chase Bank has
requested to extend
their lease to 2026 and
terminate alongside
the BofA lease.
4291011910
1324 5th St
4291011900
Neighborhood
Village NV Public parking
lot 27 2.25 FAR 150
units/acre 52,470 181 No leases– parking is
City operated 4291011901
4291011902
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Packet Pg. 712 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Address Parcel Nos. GP Designation Zoning Existing Use
Existing Base
Allowable
Density or FAR
Proposed
Density
with
Program
2.E
Land Area
(sf)
Unit
Capacity
with
Program
2.E
Other Info
4291011903
4291011904
4291011905
4291011908
1318 4th St
4291012900
Bayside
Conservation
BC
Parking
Structure 3 2.25 FAR 150
units/acre 30,000 104
City Council
authorized exclusive
negotiation
agreement on
1/22/2022 with EAH for
development of
affordable housing;
Demolition began
March 2022
4291012901
2500 Olympic
4268013919
Conservation
Arts Center
CAC
Bergamot Arts
Center1
1.0 FAR 150
units/acre 205,000 707
Property Management
Agreement until April
2027. City has annual
leases with 30
businesses (expiring
12/31) that will be
renewed each year
until redevelopment
4268014900
Total Estimated Capacity
1,880
1 The 205,000 sf land area accounts for half of the Bergamot Arts Center parcel being occupied by an existing leased R&D building which precludes housing development on this portion of the site
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Packet Pg. 713 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-21 City of Santa Monica 2021-2029 Housing Element
Category 11 and 12- Religious Congregations and Parking Lots Surface parking lots located in the multi-unit residential zoning districts have the ability to accommodate housing. These include parking lots associated with religious congregations and parking lots associated with street-fronting commercial uses.
Discussions with religious congregation leaders have indicated that there is a strong desire to develop affordable housing on the parking lots of sites owned by religious congregations.
Program 4.B in this Housing Element would amend the Zoning Ordinance to allow housing projects on these religious congregation sites to be developed to unlimited density, no minimum parking requirements, and an additional 33 feet of building height, provided that 50% of the units are provided as affordable. However, based on discussions with affordable housing developers, it is unlikely that affordable housing projects will be built greater than 5 stories. Therefore, housing capacity of sites owned by religious congregations were analyzed assuming a height of 5 stories.
Surface parking lots in residential zones have housing potential but their potential is limited by existing residential unit caps. The Housing Element includes Program 1.C which would amend the Zoning Ordinance to eliminate the maximum unit caps within these residentially-zone surface parking lots and to create special standards for housing projects on these sites.
The capacity analysis applies the following factors to calculate realistic capacity of Category 11 and 12 sites:
• Typical Density: Parking lots owned by religious congregations would be developed with affordable housing projects and as such, would be afforded new development standards that would give it increased height as compared to other sites in the residential zones. However, as stated above, such projects would likely be limited by the number of stories. Affordable housing developers have indicated that they will likely build no more than 5-6 stories due to construction costs and prevailing wages requirements for projects constructed at greater heights. Therefore, the capacity analysis assumes a maximum of 5 stories for parking lots associated with religious congregations. For surface parking lots, the capacity analysis assumes removal of the unit caps and applies the density factors of the underlying zones as well as the maximum building height.
• Realistic capacity of Site: Application of the maximum parcel coverage permitted based on the underlying multi-unit zoning.
• Land Use Controls and Site Improvements: Incorporation of the Zoning Ordinance’s requirements for unit size and unit mix requirements which could reduce maximum residential yield.
• Infrastructure Availability and Environmental Constraints: No application of environmental constraints and infrastructure constraints, per the discussion in Attachment 3.
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Packet Pg. 714 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) • Income levels: Some religious congregational leaders have indicated that there may be a need to provide some market rate units as part of housing redevelopment to ensure revenue. Therefore, these sites assume 50% of the total unit capacity could be accommodated at affordable low-income levels consistent with Program 4.B.
With this methodology, Category 11 sites yielded an estimated housing capacity of 257 units and Category 12 sites yielded an estimated housing capacity of 96 units.
Figure F-8 Example Capacity Calculation for Multifamily Parcel Site
Attribute
Zoning R2
Site Area (SF) 10,000
Typical
Density
Max # Stories 5
Density unlimited
Realistic
Capacity
Parcel Coverage (Maximum % of site area) 0.45%
Ground Floor Parcel Coverage Floor Area (GSF) 6,750 SF
Land Use
Controls
Upper Story Parcel Coverage
(% of ground floor parcel coverage) 90%
Upper Story Floor Area [(6,750 SF*.90)*4 stories] = 24,300 SF Capacity Total Floor Area 31,050 SF
Average GSF per Unit based on Unit Mix requirements 1,050 Max # of Units 30
All Remaining Sites – Categories 2, 3, 5, 6, 7, 8, 9, 10 The City of Santa Monica’s General Plan and Zoning Ordinance implements a Zoning Ordinance using floor area ratios (FAR) and heights to determine maximum development. The Housing Elementincludes Programs 1.F and 1.J, which would amend the Downtown Community Plan and Zoning Ordinance to establish new increased FARs and heights for housing projects. • Assumptions of Residential Probability vs Commercial
Development Trends – In the past decade, development in Santa Monica has trended towards new residential development rather than new commercial development (see graphic below). This is particularly true in the Downtown district, where housing projects are incentivized with greater FARs than commercial projects. Housing is in high demand in the southern California region, particularly in Santa Monica, which has seen a significant increase in development applications for residential and mixed use projects.
This trend is expected to continue to increase during the timeframe of the Housing Element. The City allows standalone, multi-unit residential development as a use permitted by-right (without discretionary approvals) in most mixed-use, commercial, and industrial zones throughout the City. These zones also allow for a broad range of other nonresidential uses. For example, a review of project applications in the City revealed that approximately 15% of projects were commercial only while the
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Packet Pg. 715 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-23 City of Santa Monica 2021-2029 Housing Element
overwhelming majority were residential or mixed-use with a large residential component. As such, the City developed assumptions for the realistic capacity for the likely mix of residential and non-residential (e.g., retail, office, hotel, employment) projects on commercially and mixed use zoned sites.
Market Conditions - The Housing Element will continue to incentivize commercial projects over residential projects across the City through Program 1.J, which will rezone the mixed-use and commercial zoning districts with higher maximum allowable FAR and height for housing projects. The FARs for housing projects will be at least 75% greater than the commercial FARs. Financial feasibility testing conducted by the City’s economic consultant indicates that with the new higher FARs and heights, housing projects will be more likely to occur than commercial projects. All the sites selected on the SSI will be rezoned with the new higher FARs and heights for housing projects. Therefore, it is highly likely that the sites will be redeveloped for residential rather than commercial. However, to be conservative,
Availability of Regulatory Incentives – The City has also most recently adopted regulatory incentives to encourage residential development, including adopting an Emergency Interim Ordinance on March 10, 2020, allowing 100% affordable housing projects and housing projects up to Tier 2 maximums that are subject to the protections of the Housing Accountability Act to be reviewed through a by-right administrative process.
Program 1.A would make this streamlining provision permanent and expand the 4 7 7
8 4
10 19
17 23
15 18
4 4
2 4
3 1
3 6
2 2
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 # OF PROJECTS
APPLICATION YEAR
Number of New Construction Commercial and Residential
Projects by Application Year
Residential Commercial
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Packet Pg. 716 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) applicability to other housing projects, including projects that are granted minor modifications.
• Site Capacity Calculation
To assess the housing capacity of the remaining Category 2-10 sites that have been identified for the SSI, the realistic capacity of the sites was assessed by applying the new rezoned heights and FAR for housing projects as listed in Programs 1.F and 1.J. The capacity analysis applies the following factors to calculate realistic capacity of sites within Category 2, 3,5, 6, 7, 8, 9, and 10:
Typical Density: The maximum allowable Tier 1 FARs for housing project is utilized for the site capacity analysis. This assumption is supported by past production trends which demonstrate that all residential developers will utilize the maximum FAR for residential and mixed-use projects, especially given high land cost and construction cost. Attachment 1 provides a list of approved and pending projects which show that almost all developers have proposed the maximum allowable FAR. Additionally, in the past (prior to the City’s 2017 adoption of the Downtown Community Plan), a couple of approved housing projects were processed as development agreements and therefore, proposed FARs exceeded the established maximum FARs in the Zoning Ordinance. For the purposes of this SSI analysis, Tier 2 FARs and Tier 3 FARs (which are greater than Tier 1) are not utilized since these are considered elective and require project developers to contribute community benefits.
Realistic capacity of Site: The capacity analysis assumes that 80% of the site area will be developed given setback and open space requirements based on a review of past housing projects.
Land Use Controls and Site Improvements: Incorporation of the Zoning Ordinance’s requirements for active ground floor use (for example retail) and unit mix requirements which could reduce maximum residential yield. Commercial Likelihood: To account for the possibility that commercial use could be built, a 15% discount factor was applied to the capacity calculation. The 15% is based on the percentage of commercial projects vs residential projects that have occurred in the past 8 years. With this discount factor, the assumed capacity on the sites in the inventory is significantly lower than the actual housing development potential that is allowed on the sites per the Zoning Code and General Plan. For example, a 0.23 acre site that is zoned MUBL (Mixed Use Boulevard Low) with a max FAR of 2.25, has a maximum development potential of 22 units. However, this site is a mixed use-zoned site that allows 100% commercial projects, so to account for market feasibility and the potential for commercial development on the site, the inventory only counts 19 units on the parcel.
Infrastructure Availability and Environmental Constraints: No application of environmental constraints and infrastructure constraints, per the discussion in Attachment 3.
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Packet Pg. 717 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F
-25 City of Santa Monica 2021
-2029 Housing Element
Site Capacity Calculation
Step 1: Apply
Max FAR to site
area
Maximum Building Floor Area
Step 2: Apply Site
Coverage Factor
(80% buildable)
Realistic Buildable Floor Area
Step 4: Apply Unit
Mix Requirement
Residential Floor Area
Step 3: Assume
Ground Floor
Commercial
Max # of Units
Step 5: Apply
Commercial
Probability Factor
Realistic Number of Units
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Packet Pg. 718 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-26 Figure F-9Example Capacity Calculation for Mixed Use and Commercial Parcel Site Attribute Zoning MUB
Site Area (SF) 10,000
Typical Density
Tier 1
Max Proposed FAR 2.25
Max SF 22,500
Realistic Capacity Building Coverage (% of Site Area) 80% Land Use Controls
Ground Floor Area (GSF) 8,000 SF
Ground Floor Use Retail
Commercial Floor Area (NSF) 6,960 SF
Capacity Upper Floor Uses Residential
Residential Floor Area (NSF) 15,540 SF
Average NSF per Unit based on Unit Mix
requirements 688
Max # of Units 22 units
Commercial Probability 15% 19 units
Max Density Capacity
Max # units/acreage of site
(19 units/0.23 acres) =
83 units/acre
The unit capacity that resulted with this calculation was spot checked against the typical densities of housing projects that have occurred in the past 10 years which is shown in the table below.
Figure F-10 Typical Densities of Housing Projects by Zoning since LUCE City Areas Zoning District
Housing
Current Tier 1
FARs
Parcel Sizes of
Housing Projects
(SF)
% of Max FAR or
Density1 Typical
Densities
Units/acre
Bergamot BTV 1.75 35,000 92% 77-110
MUC 1.50 20,000 –145,000 95-100% 103-107
CCS 1.50 -- -- --
CAC 1.0 -- -- --
Blvd MUBL 1.50 7,500-203,000 88-150% 58-129
MUB 1.50 7,500 82-135% 52-197
GC SMB 1.25 13,000 100-125% 79-108
GC Lincoln/
Pico
1.50 14,000-32,000 92-150% 63-114
NC 1.50 15,000-30,000 100-137% 97-113
NC (Main,
Montana)
1.00 -- -- --
Industrial IC Not -- -- --
Office OC Not -- -- --
Hospital HMU 1.50 -- -- --
Downtown LT 1.50 15,000-37,000 80-100% 87-192
NV 2.25 7,500-18,500 89-100% 116-349
BC 2.25 15,000 189% 160
TA 2.25 7,500 – 108,000 100-163% 161-390
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Packet Pg. 719 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-27 City of Santa Monica 2021-2029 Housing Element
OT2 2.25 -- -- -
WT 1.50 15,000 100% 122
Multi-family OF
1 unit/1500 sf 23,000-45,000 100% 41-80
OP2 1 unit/2000 sf 4,700-11,000 100% 22
OP3 1 unit/1500 sf 7,500-18,000 100% 29
OP4 1 unit/1250 sf 24,500 100% 35
R2
2,000 (or 4
total units)*
7,500-29,000 100% 22
R3
1,500 (or 5
total units)*
5,000-22,000 100% 29
R4
1,250 (or 6
total units)*
19,000 200% 74
Step 6: Assessing Appropriateness of Sites to Accommodate Lower Income levels
For the City of Santa Monica,
California Government Code
Section 65583.2 states that a
density of 30 units per acre is
appropriate to enable lower
income housing. In the City’s
mixed-use and commercial
districts, the Zoning Ordinance uses
FAR rather than the density factor
of units per acre. Therefore, to
determine how many units per acre
are possible on each SSI site, the
number of units possible was first
calculated based on the current
Tier 1 FARs and new allowable FARs
established in Programs 1.A and 1.J.
The number of units was then
translated into units/acre based on
the parcel size of each site. Under
current development standards
and with the rezoning in Programs
1.F and 1.J, all the SSI sites that are
zoned mixed-use or commercial
can accommodate housing at
greater densities than default density of 30 unitsper acre. Therefore, per HCD, all the mixed-use and commercial zoned sites are considered as having capacity for Low-Income units.
Accommodating for Very Low-and Low-Income Housing
The State uses the density allowed on a site as a “proxy” for determining whether a site can accommodate housing at
lower-income levels.
• Very Low- and Low-Income. State law establishes a
“default density standard” of 30 units per acre for
lower-income units in the City of Santa Monica. This
means that if a site’s zoning allows for a density that is greater than 30 units per acre, the zoning is
considered appropriate to accommodate the RHNA
for lower income households. Under current standards
and with the rezoning in Programs 1.F and 1J, all the
non-vacant, commercially zoned sites in the SSI can
accommodate housing at greater densities than
default density of 30 units. Therefore, per HCD, these
sites can be identified as lower-income sites that have the capacity to accommodate lower-income units.
• Moderate-income. Since all the identified SSI sites that are commercially zoned can accommodate lowerincome units, the City has also determined that each of these sites can accommodate moderate-income
housing since units affordable to lower-income
households would also be affordable to moderateincome households.
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Packet Pg. 720 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-28 Step 7: Summary of Capacity to Accommodate the RHNA
Without rezoning, the sites in the inventory can accommodate 7,596 units, resulting in a shortfall in total capacity which includes a shortfall in lower income capacity. While HCD requires that only candidate sites need to be rezoned to accommodate the shortfall, the HE includes programs to rezone entire districts, rather than individual sites. This approach is conservative and allows for the potential for candidate sites to be removed or sites to be added over the Housing Element cycle. With rezoning, the sites in the inventory can accommodate 13,600 units.
All of the sites are non-vacant, and almost all are consolidated sites. The City will continue to administratively process lot tie agreements as part of the plan check process. After accounting for consolidation, only 4 sites identified in the SSI accommodate less than 15 units (inclusive of lower income). These sites are vacant parcels located in the R2/R3 zones which have a density limit of 4 to 5 units.
Capacity to Accommodate the RHNA by Income Under Current Zoning Based on current FARs and densities in the City’s Zoning Ordinance, Bergamot Area Plan, and Downtown Community Plan, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate 7,596 units, a shortfall of 15% below the City’s RHNA of 8,895 units. This includes a shortfall of 1,109 units in all lower-income categories (ELI, VI, and LI) and 1,003 units in the moderate income category.
Figure F-11 Summary of Capacity Analysis – Under Current Zoning Standards Total Capacity Capacity for Affordable Units
# Units
Total
Affordable
Capacity ELI VLI LI Moderate
Category 1 Approved 2,205 637 127 162 148 148
Category 1 Pending 2,168 420 24 321 41 41
Category 4 City Sites 808 808 269 269 269 -
Category 11 Religious Sites 29 0 0 0 0 0
Category 12 Parking Lots 61 0 0 0 0 0
All Remaining Categories 1,950 1,950 488 488 488 488
ADUs 376 249 56 8 162 23
Total 7,596 4,064 964 1,247 1,146 700
RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702
Shortfall (1,299) (2,104) (433) (150) (526) (1,003)
-15%
Capacity to Accommodate the Shortfall of Sites by Income Under Proposed Rezoning
Programs 1.F and 1.J would amend the Zoning Ordinance, LUCE, and associated specific and area plans to allow for increased FARs and heights in the mixed use and commercial districts in the City in order to incentivize greater housing production. Additionally, Program 4.A would
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Packet Pg. 721 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-29 City of Santa Monica 2021-2029 Housing Element
amend the Zoning Ordinance, LUCE, and associated specific and area plans to add multi-unit housing as a permitted use in non-residential zones where housing is currently prohibited.
Under current zoning, the City has a shortfall of 1,109 lower income units. The City-owned sites can accommodate 1,880 lower income units, sufficient to meet this shortfall. To ensure compliance with Government Code section 65583.2, subdivisions (h) and (i), the HE includes Program 1K which requires that development on City-owned sites identified in the SSI must be at minimum 50% residential uses and flexibility to have 100% residential use. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses.
With the rezoning programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate at least 13,600 units providing a 53 percent buffer above the City’s RHNA of 8,895 units as shown in Figure F-8.
The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing. The land inventory includes capacity for 2,521 extremely low, 2,891 very low income, 2,703 low income, and 1,901moderate income units. Figure F-9 provides a summary breakdown of the SSI by zoning and income levels.
Figure F-12 Summary of Capacity Analysis – With New Development Standards Under HE Rezoning Programs
Total
Capacity Capacity for Affordable Units
# Units
Total
Affordable
Capacity ELI VLI LI Moderate
Category 1 Approved 2,205 637 127 347 148 15
Category 1 Pending 2,168 420 24 224 41 131
Category 4 City Sites 1,880 1,880 627 627 627 -
Category 11 Religious Sites 257 130 32 32 32 34
Category 12 Parking Lots 96 9 - - 9 -
All Remaining Categories 6,619 6,619 1,655 1,655 1,655 1,655 ADUs 376 249 56 8 162 23
Total 13,600 9,944 2,521 2,819 2,703 1,901
RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702
Buffer +4,705 +3,776 + 1,124 + 1,495 + 1,031 +199
53%
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Packet Pg. 722 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-30 Figure F-13 Summary of SSI Sites Capacity by Zoning
(excludes Category 1 Approved/Pending Projects)
City Areas Zoning District
# Units
Capacity
Lower
Income
Moderate
Income
Above
Moderate
Bergamot Area Plan BTV 156 39 39 78
CCS 25 6 6 13
MUC 888 223 217 448
CAC 707 707 - -
Blvd GC 967 254 225 488
MUB 1,334 334 325 675
MUBL 2,368 604 574 1,190
NC 157 40 35 82
Downtown NV 381 233 48 100
BC 285 285 - -
LT 270 72 63 135
Industrial IC 54 14 13 27
Office Campus OC 59 15 13 31
Multifamily R2 306 109 26 171
R3 655 604 8 43
R4 99 99 - -
Total 8,852 3,674 1,626 3,552
Comparison of the RHNA with Adopted City Plan Projections With the adoption of the LUCE in 2010, the City had originally anticipated the addition of 4,955 new housing units in the City by 2030, but that forecast was increased by 2,326 units after adoption of the Downtown Community Plan in 2017. Considering that approximately 2,200 units have been constructed since 2010 and approximately 1,000 units are under construction, the remaining growth anticipated through 2030 under current plans is 4,081 units. The 6th Cycle Housing Element RHNA of 8,895 units is more than twice than the planned amount of units anticipated under City plans and zoning.
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Packet Pg. 723 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-31 City of Santa Monica 2021-2029 Housing Element
Step 8: Assessment of Sites to Affirmatively Furthering Fair Housing This section analyzes the distribution of sites in the inventory by fair housing metrics and provides a comparison to the distribution of existing households in the City within each census tract. A disproportionately high number of units are within the mid-City and Downtown area, which reflects the City’s General Planning strategy of focusing new housing in areas served by transit, consistent with planning best practices and state guidelines for reducing greenhouse gas emission emissions. Census tracts in the mid-City and Downtown have a higher share of low-income units within it compared to other unit income categories. In contrast, a relatively low share of all units, including low-income units, are identified within the North of Montana and Northeast neighborhoods, which are discussed in Chapter 2 as being higher-resourced, whiter, and more wealthy. These areas are being underrepresented in the SSI given limited opportunity for high-density growth. Additional units are anticipated in these areas through lower-scale development such as Accessory Dwelling Units or “missing middle” housing, but are not reflected on the site inventory. The R2/R3/R4 zones also has a lower share of units allocated to it compared to its proportion of existing housing stock, but this reflects the city’s focus on preserving existing housing, particularly rent-controlled housing.
Effects of Sites on Segregation and Integration
The City’s suitable sites inventory was evaluated to determine how sites planned for future development could further affect patterns of segregation and integration relative to racial concentrations and income levels. As previously discussed in Chapter 2, the City is generally more homogenous than the other nearby cities in Los Angeles. Within Santa Monica, there are more predominant populations of Hispanic/Latino residents in the Pico Neighborhood while the remaining areas of the City are predominantly White. Most of the identified sites are in the Downtown and in Mid-City, which have predominantly White households. The table below shows that the census tracts with most of the available lower-income sites identified in the SSI are in areas with white predominance. About 11 percent of the lower-income capacity is identified in census tracts with a Hispanic/Latino majority. The distribution of low income and moderate unit capacities correspond generally to existing racial patterns. Therefore, the sites would not exacerbate ongoing patterns of segregation by race in the City.
Figure F-14 Sites Distribution by Racial Predominance
Racial Predominance White Hispanic
Total City Existing % 78% 13%
SSI Lower Income Units 89% 11%
SSI Moderate Income Units 88% 12%
SSI Above Moderate Unit 96% 4%
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Packet Pg. 724 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-32 Map F-2 Distribution of Sites by Racial Predominance
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Packet Pg. 725 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-33 City of Santa Monica 2021-2029 Housing Element
Map F-3 Site Capacity Increases by Racial Predominance
Relative to segregation based on household income, the sites are distributed across a number of census blocks with various median household income levels (Map F-3). The census tracts with most of the available lower-income SSI sites havelower median income levels. This is mostly due to the availability of land suitable for higher density development along the I-10 freeway such as the Downtown and Bergamot Plan areas. Development on the identified sites in the inventory has the potential to add housing of all income levels, including low-income housing. There are 115 sites identified in the census tracts with more than 55% low- to moderate-income populations, which include the Downtown, Pico Neighborhood and the Bergamot Area. While development of low-income housing on these sites could moderately exacerbate ongoing patterns of segregation, it is very unlikely that all these sites would develop as low-income particularly given the higher land cost in the Downtown. Furthermore, these sites are located in areas that are the most accessible to the Metro E light-rail stations, jobs, and other resources including schools (Santa Monica College). Therefore, while the Sites Inventory does not actively improve conditions, the sites would not exacerbate ongoing patterns of segregation by race in the City.
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Packet Pg. 726 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-34 Figure F-15 Sites Distribution by Median Income
Map F-4 Distribution of Sites by Median Household Income Median Income
Less than
$69K
$69K to
$81K
$81K to
$107
$107 to
$136,500 > $136,500
Existing Citywide
Households 21% 4% 42% 30% 3%
SSI Lower Income Units 54% 8% 26% 12% 0%
SSI Moderate Income
Units 59% 11% 17% 13% 0%
SSI Above Moderate
Unit 65% 3% 14% 18% 0%
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Packet Pg. 727 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-35 City of Santa Monica 2021-2029 Housing Element
Map F-5 Site Capacity Increases by Median Income
Figure F-16 Sites Distribution by Lower Moderate Income Households Lower Moderate Income
Households 0-25% 25.1-35% 35.1% to 45% 45.1% to 55% 55.1% + Existing Citywide
Households 14% 13% 52% 4% 17%
SSI Lower Income Units 2% 9% 35% 13% 41%
SSI Moderate Income Units 2% 10% 28% 16% 43%
SSI Above Moderate Unit 4% 14% 17% 6% 60%
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Packet Pg. 728 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-36 Map F-6 Distribution of Sites by Low to Moderate Income Households
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Packet Pg. 729 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-37 City of Santa Monica 2021-2029 Housing Element
Map F-7 Site Capacity Increases by Low to Moderate Households Effects of Sites on Displacement Potential and Disproportionate Housing Needs Reflecting the geographic analysis above, the tracts designated as more stable or exclusive, which are primarily located in the North of Montana and Northeast neighborhoods, are underrepresented in the inventory. While not large in numbers, the sites inventory do show some unit capacity in these areas, representing a small step towards opening up these areas to new housing at all income levels and reducing gentrification and displacement pressure from other areas in the City. Additionally, the sites inventory show a greater proportion oflower income and moderate income capacity within areas that are classified as “advanced gentrification” or “at risk”. This has a greater potential to protect vulnerable residents from being displaced under changing market pressures and ensure that these areas do not become exclusive. The identified sites would not exacerbate disproportionate housing needs. As described in Chapter 2, the significant contributing factors to disproportionate housing needs in the City are:
displacement due to economic pressures, high housing cost, lack of affordable accessible housing, and land/zoning laws that limit density. The sites would not contribute to these factors but rather would result in improved conditions since housing development on these sites would
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Packet Pg. 730 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-38 minimize displacement of existing rent controlled units, 2 provide new housing choice and
affordability to high opportunity areas, produce new inclusionary affordable units as part of the City’s Affordable Housing Production Program, and contribute to increased residential density.
Figure F-16 Sites Distribution by Displacement Potential Displacement
Typology
Advanced
Gentrification
Stable
Moderate At Risk
Becoming
Exclusive
Stable
Exclusive
Existing Citywide
Households 10% 17% 35% 17% 21%
SSI Lower Income
Units 25% 25% 31% 15% 3%
SSI Moderate
Income Units 29% 22% 37% 9% 3%
SSI Above Moderate
Unit 16% 48% 17% 4% 15%
2 With the exception of two sites, sites that have existing residential uses included in the SSI consist of approved/pending housing projects. The other two sites were included in the SSI because of identified developer interest. All remaining sites in the inventory are developed with commercial uses or surface parking.
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Packet Pg. 731 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-39 City of Santa Monica 2021-2029 Housing Element
Map F-8 Sites Capacity Increases by Displacement Potential Effects of Sites on Access to Opportunity
As shown in the Figure F-9 below, the identified sites would increase housing opportunities throughout the City, furthering fair housing in areas of high resources and opportunity. The identified sites would have access to low-cost transportation, jobs, and neighborhood-serving commercial uses that serve residential. Additionally, almost all of the identified sites (with the exception of the approved/pending projects) are on properties that are developed with underutilized commercial buildings and/or parking lots and therefore, would generally, minimize displacement potential. With the proposed development standards in Program 1.J, the identified sites would all have sufficient densities to accommodate lower-income units.
Additionally, the City’s Affordable Housing Production Program requires housing projects to include inclusionary, affordable units, thereby expanding housing opportunities for lowerincome households.
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Packet Pg. 732 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-40 Figure F-9 Map of Sites within High Resource Areas
In terms of environmentally healthy areas, the census tracts that represent the North of Montana and Northeast neighborhoods generally have a higher (more healthy) environmental index than the remaining areas of the City. Similar to the discussion above, these areas are underrepresented in the sites inventory as they have the least housing capacity.
Figure F-17 Sites Distribution by Environmental Health Index
Least Healthy Most Healthy
Environmental
Health Index 0 1 to 4 5 to 6 7 to 8 9 to 19
Existing Citywide
Households 37% 34% 10% 16% 3%
SSI Lower Income
Units 27% 58% 11% 4% 0%
SSI Moderate
Income Units 15% 70% 11% 4% 0%
SSI Above Moderate
Unit 49% 31% 4% 16% 0%
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Packet Pg. 733 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F
-41 City of Santa Monica 2021
-2029 Housing Element
MapF-10 Sites Capacity Increases by Environmental Health Index
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Packet Pg. 734 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-42 Attachment 1 – Approved and Pending Housing Projects
The table below provides a list of approved (not yet constructed) and housing projects pending review in the City of Santa Monica.
All projects are located on non-vacant sites that are developed with existing buildings or surface parking lots. All housing projects with 4 or more units are required to meet the inclusionary requirements in the City’s Affordable Housing Production Program, Santa Monica Municipal Code Chapter 9.64, providing either on-site or off-site affordable housing units. These affordable housing units (Extremely Low Income, Very Low Income, Low Income, and Moderate) are required to be deed restricted for a term of no less than 55 years.
Table 1 - Approved and Pending Housing Projects as Broken Down by Affordability
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
12/7/2010 10FIM002 2 Unit Multifamily 1021 Grant Street market rate 2 Approved R2 6/1/2015 15ARB-0038 3-Unit Condos 610 California
Ave
market rate 3 Approved R2
5/11/2016 05TM-009 15-Unit Condominium 1211 12th St market rate 9 Approved R3 5/11/2016 05TM-009 15-Unit Condominium 1211 12th St VLI 4 Approved R3 6/1/2016 16ENT-0011 5-Unit Condos 1840 17th St LI 1 Approved R2 6/1/2016 16ENT-0011 5-Unit Condos 1840 17th St market rate 4 Approved R2 7/13/2016 16ENT-0072 3-Unit Condos 1422 20th St market rate 3 Approved R2 7/13/2016 16ENT-0071 3-Unit Condos 1420 20th St market rate 3 Approved R2 6/21/2017 16ENT-0041 3-Unit Townhomes 1121 22nd St market rate 3 Approved R2 6/21/2017 17ENT-0027 3-Unit Condos 1649 Centinela
Ave
market rate 3 Approved R2
10/18/2017 15ENT-0266 Mixed Use 1430-1444 Lincoln Blvd market rate 100 Approved MUB 10/18/2017 17ENT-0105 3-Unit Condos 1900 20th St market rate 3 Approved R2 11/28/2017 16ENT-0143 Mixed Use 1313-1325 6th St market rate 64 Approved NV 12/6/2017 16ENT-0098 Mixed Use (Upscale
furniture building)
1437-1443 Lincoln Blvd LI 6 Approved MUB
12/6/2017 16ENT-0115 Mixed Use DRP 601-611 Wilshire Blvd market rate 37 Approved MUB 12/6/2017 16ENT-0115 Mixed Use DRP 601-611 Wilshire Blvd ELI 3 Approved MUB
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Packet Pg. 735 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-43 City of Santa Monica 2021-2029 Housing Element
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
12/6/2017 16ENT-0098 Mixed Use (Upscale
furniture building)
1437-1443 Lincoln Blvd market rate 34 Approved MUB
1/1/2018 17ENT-0286 3-Unit Condos 2512 7th St market rate 3 Approved OP2 2/7/2018 16ENT-0102 Mixed Use 1318 Lincoln Blvd market rate 39 Approved MUB 2/7/2018 16ENT-0102 Mixed Use 1318 Lincoln Blvd ELI 4 Approved MUB 4/4/2018 11DEV014 Mixed-Use DRP 1650-1660 Lincoln Blvd ELI 8 Approved MUB 4/4/2018 11DEV014 Mixed-Use DRP 1650-1660 Lincoln Blvd market rate 90 Approved MUB 6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica
Blvd
VLI 5 Approved MUBL
6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica
Blvd
LI 2 Approved MUBL
6/21/2018 16ADM-0050 Mixed Use 2901-2907 Santa Monica
Blvd
market rate 44 Approved MUBL
7/5/2018 18ENT-0199 Mixed Use (Fritto misto) 601-609 Colorado Ave market rate 104 Approved TA 7/5/2018 18ENT-0199 Mixed Use (Fritto misto) 601-609 Colorado Ave Moderate 36 Approved TA 7/27/2018 18ENT-0077 Condos 1443 18th St market rate 11 Approved MUBL 8/1/2018 17ARB-0043 Apartments 1754 10th St market rate 3 Approved R2 10/12/2018 18ARB-0221 100% Affordable Housing 1342 Berkeley ELI 8 Approved R2 11/7/2018 18ENT-0005 Mixed Use (bowling
alley)
216-248 Pico Blvd VLI 9 Approved MUBL
11/7/2018 18ENT-0005 Mixed Use (bowling
alley)
216-248 Pico Blvd market rate 93 Approved MUBL
11/7/2018 18ENT-0005 Mixed Use (bowling
alley)
216-248 Pico Blvd LI 3 Approved MUBL
1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St LI 7 Approved TA 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St market rate 14 Approved TA 1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St SRO 38 Approved TA 1/31/2019 19ENT-0041 SRO Mixed Use Project
with Commercial
1338-1342 5th St SRO 80 Approved NV
1/31/2019 19ENT-0041 SRO Mixed Use Project
with Commercial
1338-1342 5th St market rate 20 Approved NV
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Packet Pg. 736 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-44
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
1/31/2019 19ENT-0041 SRO Mixed Use Project
with Commercial
1338-1342 5th St LI 14 Approved NV
1/31/2019 19ENT-0041 SRO Mixed Use Project
with Commercial
1338-1342 5th St ELI 6 Approved NV
1/31/2019 19ENT-0039 SRO Mixed Use Project 1437 5th St ELI 4 Approved TA 3/6/2019 18ENT-0182 Mixed Use 1618 Stanford market rate 43 Approved MUC 3/6/2019 18ENT-0182 Mixed Use 1618 Stanford ELI 4 Approved MUC 4/18/2019 223 Auto Dealership 1802 Santa Monica
Blvd
market rate 0 Approved GC
4/18/2019 17ENT-0297 Mixed Use 1707 Cloverfield market rate 58 Approved BTV 4/18/2019 17ENT-0297 Mixed Use 1707 Cloverfield ELI 5 Approved BTV 4/23/2019 15ENT-0300 Mixed Use Project 1828 Ocean Ave VLI 16 Approved OF 4/23/2019 15ENT-0297 Mixed Use Project 1921 Ocean Front Walk
market rate 22 Approved OF
4/23/2019 15ENT-0300 Mixed Use Project 1828 Ocean Ave market rate 67 Approved OF 5/15/2019 15ENT-0310 21-Unit
Condominium/2020
Virginia
2002-2008 21st St market rate 19 Approved R2
6/14/2019 19ENT-0054 3-Unit Condos 1802 Delaware
Ave
market rate 3 Approved R2
7/9/2019 19ENT-0130 3-Unit Condos 122 Strand St market rate 3 Approved OP3 9/4/2019 17ENT-0298 Mixed Use 2906-2918 Santa Monica
Blvd
market rate 42 Approved MUBL
9/4/2019 17ENT-0298 Mixed Use 2906-2918 Santa Monica
Blvd
ELI 4 Approved MUBL
9/6/2019 19ENT-0128 Addition of 4 units 1410 5th St market rate 4 Approved TA 10/2/2019 19ENT-0258 3-Unit Condos 949 10th St market rate 3 Approved R2 10/4/2019 18ENT-0129 Mixed Use 100%
affordable housing
711 Colorado Ave ELI 17 Approved TA
10/4/2019 18ENT-0129 Mixed Use 100%
affordable housing
711 Colorado Ave Moderate 39 Approved TA
10/21/2019 18ENT-0211 Mixed Use 1425-1427 5th St market rate 92 Approved TA
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Packet Pg. 737 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-45 City of Santa Monica 2021-2029 Housing Element
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
11/7/2019 18ENT-0244 Mixed Use 3223 Wilshire Blvd market rate 49 Approved MUB 11/7/2019 18ENT-0244 Mixed Use 3223 Wilshire Blvd ELI 4 Approved MUB 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St Moderate 8 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St ELI 5 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St VLI 5 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St LI 7 Approved TA 11/12/2019 18ENT-0210 Mixed Use 1543-1547 7th St market rate 75 Approved TA 11/14/2019 186 Commercial building 3280 Lincoln Blvd market rate 1 Approved GC 12/4/2019 16ENT-0118 Mixed Use 3030 Nebraska
Ave
ELI 9 Approved MUC
12/4/2019 16ENT-0118 Mixed Use 3030 Nebraska
Ave
market rate 174 Approved MUC
12/9/2019 19ENT-0425 3-Unit Condos 918 5th St market rate 3 Approved R2 12/19/2019 19ENT-0256 Mixed Office/SFR 1348 10th St market rate 1 Approved GC 1/15/2020 19ENT-0267 Condos 1432 17th St market rate 6 Approved R2 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St market rate 32 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St LI 14 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St SRO 79 Approved TA 1/30/2020 19ENT-0042 SRO Mixed Use Project 1415-1423 5th St ELI 9 Approved TA 2/13/2020 18ENT-0206 SRO Project with
Commercial
701 Colorado Ave SRO 35 Approved TA
2/13/2020 18ENT-0206 SRO Project with
Commercial
701 Colorado Ave market rate 14 Approved TA
2/13/2020 18ENT-0206 SRO Project with
Commercial
701 Colorado Ave LI 6 Approved TA
2/13/2020 18ENT-0206 SRO Project with
Commercial
701 Colorado Ave ELI 4 Approved TA
3/23/2020 18ENT-0283 SRO Mixed Use Project
with Commercial
1323 5th St market rate 8 Approved NV
3/23/2020 18ENT-0283 SRO Mixed Use Project
with Commercial
1323 5th St SRO 35 Approved NV
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Packet Pg. 738 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-46
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
3/23/2020 18ENT-0283 SRO Mixed Use Project
with Commercial
1323 5th St Moderate 3 Approved NV
3/23/2020 18ENT-0283 SRO Mixed Use Project
with Commercial
1323 5th St LI 6 Approved NV
3/23/2020 19ENT-0040 SRO Mixed Use Project
with Commercial
1437 6th St ELI 3 Approved NV
3/23/2020 19ENT-0040 SRO Mixed Use Project
with Commercial
1437 6th St market rate 35 Approved NV
3/23/2020 19ENT-0040 SRO Mixed Use Project
with Commercial
1437 6th St SRO 8 Approved NV
3/23/2020 19ENT-0040 SRO Mixed Use Project
with Commercial
1437 6th St LI 6 Approved NV
4/4/2020 20ENT-0020 100% Affordable Housing 1819 Pico Blvd LI 47 Approved NC 4/4/2020 20ENT-0020 100% Affordable Housing 1819 Pico Blvd market rate 1 Approved NC 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St VLI 10 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St Moderate 16 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St LI 14 Approved TA 4/14/2020 18ENT-0212 100% Affordable Housing 1514 7th St ELI 10 Approved TA 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St Moderate 13 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St LI 10 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St VLI 7 Approved NV 4/14/2020 18ENT-0200 100% Affordable Housing 1238 7th St ELI 7 Approved NV 4/15/2020 20BLD-1044 New Duplex 2409 28th St market rate 2 Approved R2 4/22/2020 18ENT-0229 Mixed Use (Performance
Bicycles)
501 Broadway market rate 75 Approved TA
4/22/2020 18ENT-0229 Mixed Use (Performance
Bicycles)
501 Broadway VLI 19 Approved TA
4/30/2020 19ENT-0085 Mixed Use 1448 7th St Moderate 1 Approved NV 4/30/2020 19ENT-0085 Mixed Use 1448 7th St LI 1 Approved NV 4/30/2020 19ENT-0085 Mixed Use 1448 7th St market rate 6 Approved NV 5/20/2020 20ENT-0063 3-Unit Condos 2425 20th St market rate 3 Approved R2
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Packet Pg. 739 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-47 City of Santa Monica 2021-2029 Housing Element
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
5/30/2020 20ENT-0045 5-Unit Condos 1949 17th St LI 1 Approved R2 5/30/2020 20ENT-0045 5-Unit Condos 1949 17th St market rate 4 Approved R2 6/15/2020 20ARB-0138 duplex 2714 Highland market rate 2 Approved OP2 6/17/2020 20ENT-0073 3-Unit Condos 817 16th St market rate 3 Approved R2 7/20/2020 20ENT-0019 3-Unit Condos adjacent
to Landmark
2501 2nd St market rate 3 Approved OP2
8/24/2020 20ENT-0079 100% Affordable Housing 1413 Michigan Ave VLI 57 Approved NC 8/24/2020 20ENT-0079 100% Affordable Housing 1413 Michigan Ave market rate 1 Approved NC 9/13/2020 11DEV-003 Miramar Hotel Project
DA
1133 Ocean Ave market rate 60 Approved OT - ELS
10/21/2020 20ENT-0164 Condos 1510 Franklin St market rate 3 Approved R2 11/16/2020 20ENT-0011 Mixed Use 1512 Euclid St market rate 8 Approved MUBL 11/16/2020 20ENT-0011 Mixed Use 1512 Euclid St LI 2 Approved MUBL 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd market rate 24 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd VLI 1 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd LI 1 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd Moderate 3 Approved LT 12/9/2020 20ENT-0163 Mixed Use 1427-31 Lincoln Blvd ELI 1 Approved LT 12/14/2020 20ENT-0280 2-Unit Condos 1514 Princeton market rate 2 Approved R2 12/14/2020 18ENT-0243 remodel to 5 of 6
live/work condo
1643 12th St market rate 0 Approved IC
12/22/2020 20ARB-0213 Triplex addition to SFR 1902 Euclid St market rate 3 Approved R2 1/19/2021 20ENT-0238 100% affordable housing
for Miramar
1127-1129 2nd St VLI 21 Approved WT
1/19/2021 20ENT-0238 100% affordable housing
for Miramar
1127-1129 2nd St ELI 6 Approved WT
1/19/2021 20ENT-0238 100% affordable housing
for Miramar
1127-1129 2nd St LI 15 Approved WT
1/20/2021 19ENT-0235 3-Unit Condos on
Landmark property
1527 17th St market rate 3 Approved R2
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Packet Pg. 740 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-48
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
2/23/2021 20ENT-0293 6 unit condos 1319 Centinela
Ave
market rate 6 Approved R2
6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway market rate 206 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway ELI 17 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway VLI 17 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway LI 26 Approved TA 6/16/2021 20ENT-0241 Mixed Use (Von's) 710 Broadway Moderate 29 Approved TA 2/28/2013 13DEV004 Hotel/Mixed Use DA
(Ocean Avenue Project)
101-129 Santa Monica
Blvd
market rate 82 Pending OT - ELS
2/28/2013 13DEV004 Hotel/Mixed Use DA
(Ocean Avenue Project)
101-129 Santa Monica
Blvd
VLI 18 Pending OT - ELS
2/11/2021 21ENT-0035 Mixed-Use 1101 Wilshire Blvd VLI 11 Pending MUB 2/11/2021 21ENT-0035 Mixed-Use 1101 Wilshire Blvd market rate 82 Pending MUB 1/8/2013 13DEV001 Mixed Use 1431 Colorado Ave market rate 42 Pending MUBL 1/8/2013 13DEV001 Mixed Use 1431 Colorado Ave LI 8 Pending MUBL 5/22/2018 18ENT-0136 Mixed Use 1437 7th St VLI 13 Pending NV 5/22/2018 18ENT-0136 Mixed Use 1437 7th St market rate 52 Pending NV 4/13/2021 21ENT-0091 Mixed Use 1524 7th St affordable
housing**
20 Pending TA
4/13/2021 21ENT-0091 Mixed Use 1524 7th St market rate 80 Pending TA 8/6/2020 20ENT-0196 Apartments 1546 9th St market rate 9 Pending R3 8/4/2016 16ENT-0112 3-Unit Condos 1665 Appian Way market rate 3 Pending OF 3/31/2020 20BLD-1218 New addition of 2 units 1958 20th St market rate 2 Pending R2 4/13/2021 21ENT-0093 Mixed Use 3025 Olympic Blvd market rate 307 Pending MUC 4/13/2021 21ENT-0093 Mixed Use 3025 Olympic Blvd affordable housing**
38 Pending MUC
11/27/2018 18ENT-0362 Mixed Use 525 Colorado Ave market rate 30 Pending TA 11/27/2018 18ENT-0362 Mixed Use 525 Colorado Ave VLI 10 Pending TA 1/8/2013 13DEV002 Mixed Use 603 Arizona Ave market rate 39 Pending NV 1/8/2013 13DEV002 Mixed Use 603 Arizona Ave VLI 8 Pending NV
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Packet Pg. 741 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-49 City of Santa Monica 2021-2029 Housing Element
APPROVAL OR
APPLICATION
DATE
PROJECT ID PROJECT DESCRIPTION ADDRESS STREET AFFORDABILITY LEVEL*
UNITS PROJECT
STATUS
ZONING
10/2/2020 20ENT-0234 3-Unit Condos 734 12th St market rate 3 Pending NC 9/12/2019 19ENT-0340 Mixed Use Building 825 Santa Monica Blvd
market rate 41 Pending GC
9/12/2019 19ENT-0340 Mixed Use Building 825 Santa Monica Blvd
VLI 7 Pending GC
* Affordable units are required to be deed restricted for a term of at least 55 years. **Affordability level to be determined
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Packet Pg. 742 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-50 Table 2 - Approved and Pending Projects by Age of Building, Improvements Land Ratio (ILR), Existing Use Consolid
ated Site
Project ID Address AIN Zoning
District
Land
Area
Existing Use Building
Age
ILR
A 18ENT-0244 4266001046 MUB 6522 parking lot for Aah's 0 0.000 A 18ENT-0244 3223 WILSHIRE BLVD 4266001045 MUB 13063 one-story Aah's retail store 1955 0.108 AA 1431 LINCOLN BLVD 4282027019 LT 7512 one-story comic book store 1983 0.130 AA 20ENT-0163 1427 LINCOLN BLVD 4282027020 LT 7501 one-story comic book store 1956 0.024 AC 22ENT-0037 1527 LINCOLN BLVD 4282028019 LT 7494 former tile store; vacant retail building 1945 0.310 AC 22ENT-0037 1533 LINCOLN BLVD 4282028018 LT 7510 former tile store; vacant retail building 1952 0.429 AM 4289019022 MUBL 5601 vacant one story bowling alley 0 0.000 AM 216 PICO BLVD 4289019023 MUBL 5613 vacant one story bowling alley 1962 0.057 AM 228 PICO BLVD 4289019021 MUBL 5621 vacant one story bowling alley 0 0.000 AM 248 PICO BLVD 4289019017 MUBL 5590 vacant one story bowling alley 0 0.000 AM 254 PICO BLVD 4289019016 MUBL 5611 vacant one story bowling alley 0 0.000 AM 21ENT-0219 234 PICO BLVD 4289019019 MUBL 28008 vacant one story bowling alley 1959 0.096 AO 19ENT-0041 1342 5TH ST 4291011019 NV 7509 parking lot 0 0.000 AO 19ENT-0041 1342 5TH ST 4291011020 NV 7485 parking lot 0 0.000 AR 19ENT-0039 1445 5TH ST 4291019016 TA 7498 vacant one-story multitenant retail building 1946 0.016 AR 19ENT-0039 1445 5TH ST 4291019017 TA 7511 parking lot next to vacant retail 0 0.002 AT (blank) 4291021009 LT 3751 parking lot 0 0.000
AT 1438 LINCOLN BLVD 4291021008 LT 3752 parking lot 0 0.000 AT 1444 LINCOLN BLVD 4291021010 LT 7491 parking lot 0 0.000 AT 15ENT-0266 1430 LINCOLN BLVD 4291021006 LT 7507 parking lot 0 0.000 AT 15ENT-0266 1432 LINCOLN BLVD 4291021007 LT 7492 parking lot 0 0.000 AU 1500 LINCOLN BLVD 4291022003 LT 7500 one-story Von's with parking lot 0 0.003 AU 1500 LINCOLN BLVD 4291022025 LT 22450 one-story Von's with parking lot 0 0.003 AU 1518 LINCOLN BLVD 4291022004 LT 7500 one-story Von's with parking lot 0 0.003 AU 1526 LINCOLN BLVD 4291022005 LT 7500 one-story Von's with parking lot 0 0.003 AU 1534 LINCOLN BLVD 4291022006 LT 7500 one-story Von's with parking lot 0 0.003 AU 20ENT-0241 710 BROADWAY 4291022026 TA 52450 one-story Von's with parking lot 1995 0.179 AX 22ENT-0011 1553 4TH ST 4291025028 TA 7474 Vacant bank site across DT station 0 0.001 AX 22ENT-0011 1555 4TH ST 4291025012 TA 7497 Vacant bank site across DT station 1973 0.013 AY 20ENT-0238 1127 2ND ST 4292021010 WT 7517 parking lot 0 0.003
8.B.i
Packet Pg. 743 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-51 City of Santa Monica 2021-2029 Housing Element
Consolid
ated Site
Project ID Address AIN Zoning
District
Land
Area
Existing Use Building
Age
ILR
AY 20ENT-0238 1129 2ND ST 4292021009 WT 7490 parking lot 0 0.003 BG 22ENT-0006 1152 21ST ST 4276007021 MUB 3491 rear parking lot for NOMA sushi and Veggie grill (2025 wilshire)
0 0.019
BG 22ENT-0006 2025 WILSHIRE BLVD 4276007027 MUB 14987 one story Veggie grill 1969 0.096 BL 1115 WILSHIRE BLVD REAR 4281020029 MUB 13949 rear parking lot 1927 0.181 BL 21ENT-0035 1101 WILSHIRE BLVD 4281020012 MUB 8559 one-story JP bar 1922 0.191 BN 1819 SANTA MONICA BLVD 4276029011 GC 14986 Honda auto inventory lot 0 0.000 BN 21ENT-0227 1350 19TH ST 4276029010 GC 7495 Honda auto inventory lot 0 0.001 BN 21ENT-0229 1342 19TH ST 4276029009 R2 8991 Honda auto inventory lot 0 0.001 BO 2911 SANTA MONICA BLVD 4267011022 MUBL 6501 one story retail building 1926 0.200 BO 16ADM-0050 1347 YALE ST 4267011021 MUBL 3266 one-story retail building 1926 0.248 BO 16ADM-0050 1349 YALE ST 4267011020 MUBL 9368 one story multitenant retail building, two story apartment building w parking lot
1923 0.111
BP 1543 LINCOLN BLVD 4282028010 LT 7497 one story vacant auto repair 1947 0.128 BP 1547 LINCOLN BLVD 4282028009 LT 7499 one story vacant auto repair 1999 0.435 BP 22ENT-0037 1537 LINCOLN BLVD 4282028011 LT 7496 one story vacant auto repair 1945 0.245 BS 15ENT-0310 2002 21ST ST 4274026001 R2 7533 one-story apartments 0 0.101 BS 15ENT-0310 2008 21ST ST 4274026003 R2 7130 one-story apartments 0 0.107 BT 19ENT-0328 1840 14TH ST 4283030018 NC 7524 100% affordable housing under construction 1962 0.258 BT 19ENT-0328 1844 14TH ST 4283030017 NC 7485 100% affordable housing under construction 1922 0.496 BT 19ENT-0328 1848 14TH ST 4283030016 NC 7525 100% affordable housing under construction 1968 0.003 BU 19ENT-0042 1415 5TH ST 4291019021 TA 7494 two story multitenant retail building 1980 0.000 BU 19ENT-0042 1423 5TH ST 4291019020 TA 7525 two story multitenant retail building 1966 0.000 BV 18ENT-0210 1543 7TH ST 4291022014 TA 7500 parking lot 1990 1.725 BV 18ENT-0210 1547 7TH ST 4291022013 TA 7500 parking lot 0 0.000 BW 1547 6TH ST 4291023011 TA 7505 one-story multi-tenant building, restaurant, office 1986 0.000 BW 18ENT-0199 609 COLORADO AVE 4291023010 TA 14982 one-story multi-tenant building, restaurant, office 1984 0.167 BX 16ENT-0115 601 WILSHIRE BLVD 4292005029 WT 10010 vacant one and two story buildings 1977 0.071 BX 16ENT-0115 611 WILSHIRE BLVD 4292005026 WT 4997 vacant one and two story buildings 1922 0.143 BY 11DEV014 1650 LINCOLN BLVD 4290002008 LT 16220 one-story retail, boxing fitness building 1954 0.000 BY 11DEV014 1660 LINCOLN BLVD 4290002006 LT 7570 one-story retail, boxing fitness building 1954 0.000 BZ 16ENT-0098 1437 LINCOLN BLVD 4282027018 LT 7485 one-story retail building 1949 0.000 BZ 16ENT-0098 1443 LINCOLN BLVD 4282027028 LT 7510 one-story retail 1959 0.000
8.B.i
Packet Pg. 744 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-52 Consolid
ated Site
Project ID Address AIN Zoning
District
Land
Area
Existing Use Building
Age
ILR
C 22ENT-0007 2501 WILSHIRE BLVD 4276001026 MUB 14319 one-story commercial building with multiple retailers; corner parcel; with rear residential
parking lot
1951 0.138
C 22ENT-0007 2515 WILSHIRE BLVD 4276001025 MUB 6164 one-story multi-tenant commercial building 1941 0.486 C 22ENT-0007 2525 WILSHIRE BLVD 4276001027 MUB 10347 one-story commercial building, Starbucks, Urgent Care, Postal Store; common ownership; corner
parcel with rear residential parking
1970 0.435
CA 16ENT-0143 1313 6TH ST 4291009021 NV 15010 parking lot 0 0.000 CA 18ENT-0283 1323 5TH ST 4291010029 NV 7512 parking lot 0 0.000 CH 22ENT-0014 1902 WILSHIRE BLVD 4276013020 MUB 4989 one story retail/restaurant building (Thai dishes, salon, medical office)
1939 0.328
CH 22ENT-0014 1908 WILSHIRE BLVD 4276013030 MUB 24993 one-story retail/restaurant building (Thai dishes, salon, medical office)
1925 0.201
CI 21ENT-0228 1921 WILSHIRE BLVD 4276008014 MUB 15015 one-story retail building (GAP) 1975 0.406 CI 21ENT-0228 1933 WILSHIRE BLVD 4276008015 MUB 10520 one-story retail building (GAP) 1958 0.333 E 20ENT-0311 2906 SANTA MONICA BLVD 4267018026 MUBL 21314 vacant two story office 1969 0.792 E 20ENT-0311 2918 SANTA MONICA BLVD 4267018003 MUBL 7021 vacant parking lot 1965 0.117 P 21ENT-0226 1347 18TH ST 4276029026 GC 7512 Honda dealership with surface inventory 1969 0.001 P 21ENT-0226 1801 SANTA MONICA BLVD 4276029048 GC 14984 Honda dealership with surface inventory 1953 0.018 S 825 SANTA MONICA BLVD 4282010012 GC 7505 Toyota dealership 0 0.000 S 21ENT-0261 825 SANTA MONICA BLVD 4282010013 GC 7491 Toyota dealership 1951 0.010 S 21ENT-0261 825 SANTA MONICA BLVD 4282010014 GC 7502 Toyota dealership 1951 0.002 05TM-009 1211 12TH ST 4282005053 R3 15008 one story apartment buildings 0 0.000 09FIM003 1434 14TH ST 4282022027 R3 7500 (blank) 1925 0.221 10FIM002 1021 GRANT ST 4284015017 R2 6491 (blank) 1928 0.421 11DEV-003 1133 OCEAN AVE 4292028001 OT 190963 Miramar Hotel 1938 0.532 13DEV001 1431 COLORADO AVE 4282034009 MUBL 22485 one-story marble store 1923 0.009 13DEV004 129 SANTA MONICA BLVD 4291014024 BC 30000 parking lot 1871 0.019 15ARB-0038 610 CALIFORNIA AVE 4292005022 R2 5002 (blank) 1912 0.209 15ENT-0297 4289025005 OF 23222 vacant parking lot next to Casa del mar hotel 0 0.000 15ENT-0300 4290020045 OF 45314 parking lot 0 0.002
16ENT-0011 1840 17TH ST 4283032008 R2 7490 (blank) 1955 0.250 16ENT-0041 1121 22ND ST 4276005022 R2 6114 (blank) 1924 0.029 16ENT-0060 (blank) 4275006026 HMU 6242 parking lot owned by Saint John's 0 0.003 16ENT-0102 1318 LINCOLN BLVD 4291008025 LT 15003 parking lot 0 0.000
8.B.i
Packet Pg. 745 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-53 City of Santa Monica 2021-2029 Housing Element
Consolid
ated Site
Project ID Address AIN Zoning
District
Land
Area
Existing Use Building
Age
ILR
16ENT-0112 1665 APPIAN WAY 4290018018 R3 4430 residential 1914 0.375 16ENT-0118 (blank) 4268010017 MUC 64297 one-story light industrial/creative office 0 0.002 16ENT-0205 2102 5TH ST 4289010006 OP2 5661 (blank) 1911 0.024 17ARB-0043 1754 10TH ST 4283018002 R2 7511 (blank) 1922 0.250 17ENT-0027 1649 CENTINELA AVE 4268006016 R2 6313 single family dwelling 1948 0.250 17ENT-0048 436 PIER AVE 4287027065 OP2 7480 (blank) 1911 0.250 17ENT-0105 1900 20TH ST 4274019056 R2 7575 single family dwelling 0 0.000 17ENT-0286 4287003017 OP2 7973 (blank) 0 0.000
17ENT-0297 1707 CLOVERFIELD BLVD 4268014013 BTV 76562 parking lot of Extra Space sotrage 1955 0.658 18ARB-0221 1342 BERKELEY ST 4267012009 R2 7858 Vacant lot 0 0.000 18ENT-0077 1443 18TH ST 4275010016 MUBL 7500 Vacant lot 1957 0.004 18ENT-0129 711 COLORADO AVE 4291022012 TA 7500 construction staging site 0 0.000 18ENT-0136 1437 7TH ST 4291021029 NV 14991 three story office building 1983 1.223 18ENT-0182 1618 STANFORD ST 4268002005 MUC 20016 one story office building 1950 0.201 18ENT-0200 1238 7TH ST 4291006006 NV 7500 one-story office 1912 0.001 18ENT-0206 1557 7TH ST 4291022021 TA 7500 one story brick office building 1959 0.028 18ENT-0211 1427 5TH ST 4291019019 TA 15007 one-story vacant retail building 1954 0.000 18ENT-0212 1514 7TH ST 4291023002 TA 7504 construction staging parking site 0 0.000 18ENT-0229 501 BROADWAY 4291019027 TA 15007 one-story vacant retailer (Black tux) 0 0.000 18ENT-0362 525 COLORADO AVE 4291024014 TA 7483 one-story creative office 1960 0.000 19ENT-0039 1437 5TH ST 4291019018 TA 7484 parking lot 0 0.000 19ENT-0040 1437 6TH ST 4291020016 NV 7497 one story residence 0 0.000 19ENT-0235 1527 17TH ST 4275012020 R2 7500 single dwelling unit 1923 0.053 19ENT-0258 949 10TH ST 4281025014 R2 7484 (blank) 1916 0.250 19ENT-0267 1432 17TH ST 4282019007 R2 7504 (blank) 1959 0.083 19ENT-0425 918 5TH ST 4292015004 R2 7520 (blank) 1910 0.250 20ARB-0138 2714 HIGHLAND AVE 4287019012 OP2 4708 (blank) 1912 0.273 20ARB-0213 1902 EUCLID ST 4283028010 R2 7499 (blank) 1940 0.228 20BLD-1044 2409 28TH ST 4270004017 R2 9005 (blank) 1937 0.125 20BLD-1218 1958 20TH ST 4274019001 R2 7609 (blank) 0 0.133 20ENT-0011 1512 EUCLID ST 4282032003 MUBL 7500 vacant single family home 0 0.250
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Packet Pg. 746 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-54 Consolid
ated Site
Project ID Address AIN Zoning
District
Land
Area
Existing Use Building
Age
ILR
20ENT-0019 2501 2ND ST 4287010011 OP2 6478 (blank) 0 0.077 20ENT-0020 1819 PICO BLVD 4274017019 NC 13510 parking lot for religious institution 1950 0.383 20ENT-0045 1949 17TH ST 4274015020 R2 7747 Vacant lot 0 0.000 20ENT-0063 2425 20TH ST 4273019001 R2 6746 one story single family unit 1928 0.331 20ENT-0073 817 16TH ST 4281001021 R2 7481 one story single family dwelling 0 0.403 20ENT-0079 1413 MICHIGAN AVE 4283013024 NC 17992 Vacant lot 1905 0.069 20ENT-0164 1510 FRANKLIN ST 4267027057 R2 8118 two story single family unit 1924 0.310 20ENT-0234 734 12TH ST 4280025015 NC 4802 one story single family dwelling 1926 0.250 20ENT-0280 1514 PRINCETON ST 4267022010 R2 4999 one story single family dwelling 1940 0.250 20ENT-0293 1319 CENTINELA AVE 4267014026 R2 9274 two story single family unit 1929 0.488 21ENT-0027 1448 7TH ST 4291020008 NV 7498 two story apartment buildings w parking lot 1952 0.067 21ENT-0143 1546 9TH ST 4282028007 R3 7503 one story single family unit 1909 0.250 22ENT-0002 1302 6TH ST 4291010027 NV 18521 two story office 1978 0.129 22ENT-0012 2537 LINCOLN BLVD 4284008016 GC 19239 closed car wash 1965 0.167 22ENT-0013 2601 LINCOLN BLVD 4285001030 MUBL 203990 one story Gelsons shopping center; multiple tenants
1956 0.349
22ENT-0047 1333 7TH ST 4291008018 NV 7510 small site; single dental tenant; long standing owner/tenant
1978 1.333
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Packet Pg. 747 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-55 City of Santa Monica 2021-2029 Housing Element
Attachment 2 - FAR and Size of Sites for Past and Current Housing Projects HCD states that a parcel smaller than 0.5 acre (21,780 sf) is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic orfeasible. The City of Santa Monica is a small, compact city with parcel sizes that range across the City. Parcels in the Bergamot Plan area, Office Campus districts, and Industrial Conservation zones are generally larger (more than 30,000 sf). On the main commercial corridors, sites range between 10,000 sf to 15,000 sf. However, in the Downtown area, parcels are as small as 7,500 sf. As shown in the Table below, past and current multifamily housing projects (including 100% affordable housing projects) on mixed use and commercially zoned sites that are 15,000 sf are common. Generally, only in the Downtown have multi-unit housing projects occurred on sites less than 7,500 sf. As shown in the table, past and current housing projects in commercial and mixed use zones generally propose the maximum FAR or greater (through a development agreement). Therefore, the below development trends for housing projects demonstrate that development of housing affordable to lower income households on smaller commercial and mixed use sites within Santa Monica is typical, realistic, and feasible.
PROJECT ID PROJECT
TYPE
ADDRESS STREET ZONING SITE SIZE
(SF)
FAR FAR
(ALLOWABLE)
% OF
MAXIMUM
FAR
STORIES MARKET
RATE UNITS
AFFORDABLE
UNITS
TOTAL
UNITS
UNITS/ACRE
BUILT/PROPOSED
20ENT-0238 100%
Affordable
Housing
1127-1129 2nd St WT 14.984 2.75 2.75 100% 5 - 42 42 122 18ENT-0200 100%
Affordable
Housing
1238 7th St NV 7.486 3.50 3.50 100% 6 - 37 37 215
18ENT-0212 100%
Affordable
1514 7th St TA 7.493 4.00 4.00 100% 8 - 50 50 291
18ENT-0357 100%
Affordable
1445-1453 10th St MUBL 13.495 2.00 2.00 100% 4 1 39 40 129 18ENT-0105 100%
Affordable
1820-1826 14th St NC 15 1.75 1.75 100% 3 - 39 39 113
19ENT-0328 100%
Affordable
1834-1848 14th St NC 30.06 1.75 1.75 100% 4 1 72 73 106 12AA-002 100%
Affordable
Housing
520 Colorado Ave TA 6.26 1.90 2.00 95% 5 - 34 34 237
18ENT-0129 100%
Affordable
711 Colorado Ave TA 7.48 4.00 4.00 100% 7 - 56 56 326
19ENT-0014 100%
Affordable
2120 Lincoln Blvd GC 14.16 2.00 2.00 100% 4 1 36 37 114 07AA-007 100%
Affordable
1447 Lincoln Blvd LT 23 1.8 (1.3
+0.5)
1.80 100% 5 - 97 97 188
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Packet Pg. 748 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix
F | Report on Suitable Sites Inventory Analysis F-56
PROJECT ID PROJECT
TYPE
ADDRESS STREET ZONING SITE SIZE
(SF)
FAR FAR
(ALLOWABLE)
% OF
MAXIMUM
FAR
STORIES MARKET
RATE UNITS
AFFORDABLE
UNITS
TOTAL
UNITS
UNITS/ACRE
BUILT/PROPOSED
15ENT-0306 100%
Affordable
1626 Lincoln Blvd MUB 27.808 1.78 2.75 65%5- 64 64 100
20ENT-0020 100%
Affordable
1819 Pico Blvd NC 21.524 1.99 2.00 100%41 47 48 97
09AA-007 100%
Affordable
2802 Pico Blvd NC 16.2 1.50 1.5 (NC) + 3
units (R2)
100%40 33 33 89
22ENT-0001 100%
Affordable
1211-1215 19th St MUB 7.5 2.81 2.25 125%6- 34 34 197
22ENT-003 100%
Affordable
1333 7th St NV 7.5 5.064 127%8- 38 38 221
21ENT-0269 100%
Affordable
1634 20th IC 19.8 3.95 2.25 176%7- 78 78 172
12DEV001 Market
Rate
1318-1324 2nd St BC 15 3.10 1.77 / 2.0 155%4 45 10 55 160 17ENT-0275 Market
Rate
1235 5th St NV 7.35 3.50 3.50 100%5 185 23 136
18ENT-0283 Market
Rate
1323 5th St NV 7.496 3.50 3.50 100%6 439 52 302
19ENT-0041 Market
Rate
1338-1342 5th St NV 14.985 3.50 3.50 100%6 100 20 120 349 19ENT-0042 Market
Rate
1415-1423 5th St TA 14.961 4.00 4.00 100%8 111 23 134 390 18ENT-0211 Market
Rate
1425-1427 5th St TA 15 4.00 4.00 100%8 92- 92 267
19ENT-0039 Market
Rate
1437 5th St TA 7.489 4.00 4.00 100%8 52 11 63 366
16ENT-0143 Market
Rate
1313-1325 6th St NV 15 3.10 3.50 89%6 64- 64 186
19ENT-0040 Market
Rate
1437 6th St NV 7.5 3.50 3.50 100%6 439 52 302
11DEV008 Market
Rate
13177th St NV 15 3.57 1.6 / 2.0 (3.75
DA)
179%5 516 57 166
05AA-015 Market
Rate
1427 7th St NV 15 1.87 2.00 94%5 435 48 139
18ENT-0136 Market
Rate
1437 7th St NV 14.991 NA 2.0-6 52 13 65 189
8.B.i
Packet Pg. 749 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F
-57 City of Santa Monica 2021
-2029 Housing Element
PROJECT ID PROJECT
TYPE
ADDRESS STREET ZONING SITE SIZE
(SF)
FAR FAR
(ALLOWABLE)
% OF
MAXIMUM
FAR
STORIES MARKET
RATE UNITS
AFFORDABLE
UNITS
TOTAL
UNITS
UNITS/ACRE
BUILT/PROPOSED
21ENT-0027 Market
Rate
1448 7th St NV 7.5 3.50 3.50 100%5 155 20 116
18ENT-0210 Market
Rate
1543-1547 7th St TA 14.962 4.00 4.00 100%8 75 25 100 291 18ENT-0206 Market
Rate
701 Colorado Ave TA 7.481 4.00 4.00 100%8 49 10 59 344
14AA-001 Market
Rate
1347 19th St GC (C4) 7.5 1.00 0.80 125%23-3 17
11DEV007 Market
Rate
702 Arizona Ave NV 15 3.00 3.0 (DA) 100%4 405 45 131
13DEV-008 Market
Rate
500 Broadway TA 67.5 4.00 4.00 100%7 249- 249 161
18ENT-0229 Market
Rate
501 Broadway TA 14.975 4.00 4.00 100%8 75 19 94 273
06DR-003 Market
Rate
525 Broadway TA 37.5 1.90 2.00 95%6 115 10 125 145
20ENT-0241 Market
Rate
710 Broadway TA 108.5 2.75 / 4.0 2.75 / 4.0 (split
zone)
100%8 206 89 295 118
17ENT-0095 Market
Rate
2225 Broadway MUBL 9.7 1.75 1.75 100%3 132 15 67
18ENT-0362 Market
Rate
525 Colorado Ave TA 7.5 5.4 4.00 137%8 30 10 40 232
18ENT-0199 Market
Rate
601-609 Colorado Ave TA 22.5 4.00 4.00 100%8 104 36 140 271 13DEV001 Market
Rate
1431 Colorado Ave TA 22.6 1.99 4.00 50% 428 50 96
07DEV-005 Market
Rate
2930 Colorado Ave MUC 148.966 2.20 2.20 (DA) 100%5 318 38 356 104 17ENT-0096 Market
Rate
1450 Cloverfield MUBL 19.6 1.75 1.75 100%3 323 35 78
17ENT-0297 Market
Rate
1707 Cloverfield BTV 74.065 1.85 2.00 92%4 585 63 37
20ENT-0011 Market
Rate
1512 Euclid St MUBL 7.5 1.45 1.50 97%382 10 58
16ENT-0102 Market
Rate
1318 Lincoln Blvd MUB 14.982 2.25 2.75 82%5 394 43 125
8.B.i
Packet Pg. 750 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix F | Report on Suitable Sites Inventory Analysis F-58
PROJECT ID PROJECT
TYPE
ADDRESS STREET ZONING SITE SIZE
(SF)
FAR FAR
(ALLOWABLE)
% OF
MAXIMUM
FAR
STORIES MARKET
RATE UNITS
AFFORDABLE
UNITS
TOTAL
UNITS
UNITS/ACRE
BUILT/PROPOSED
20ENT-0163 Market
Rate
1427-31 Lincoln Blvd LT 15 2.25 2.25 100% 5 24 6 30 87
15ENT-0266 Market
Rate
1430-1444 Lincoln Blvd MUB 30 2.75 2.75 100% 5 100 - 100 145 16ENT-0098 Market
Rate
1437-1443 Lincoln Blvd MUB 15.044 2.25 2.75 82% 5 34 6 40 116 12DEV017 Market
Rate
1560 Lincoln Blvd MUB 37.5 2.73 2.75 (DA) 100% 5 80 20 100 116 12DEV011 Market
Rate
1601 Lincoln Blvd MUB 33.154 2.34 2.25 (DA) 104% 5 71 19 90 118 16ENT-0036 Market
Rate
1613-1637 Lincoln Blvd MUB 69.096 2.25 2.25 100% 5 176 15 191 120 16ENT-0058 Market
Rate
1641-1645 Lincoln Blvd MUB 20.905 2.25 2.25 100% 5 61 5 66 138 11DEV014 Market
Rate
1650-1660 Lincoln Blvd MUB 31.065 2.25 2.25 (DA) 100% 5 90 8 98 137 16ENT-0035 Market
Rate
2903-2931 Lincoln Blvd GC 32.277 1.84 2.00 92% 4 43 4 47 63 20ENT-0079 Market
Rate
1413 Michigan Ave NC 18 2.06
(w/SDB)
1.75 118% 4 1 57 58 140
16ENT-0118 Market
Rate
3030 Nebraska Ave MUC 74.185 1.42 1.50 95% 4 174 9 183 107 15ENT-0300 Market
Rate
1828 Ocean Ave OF 45.12 1.81 2.0 91% 4 67 16 83 80
15ENT-0297 Market
Rate
1921 Ocean Front Walk OF 23.258 1.7 2.0 83% 4 22 - 22 41 18ENT-0005 Market
Rate
216-234 Pico Blvd MUBL 55.689 1.75 1.75 100% 3 93 12 105 82 08AA-002 Market
Rate
519 Santa Monica Blvd NV 14.9 1.90 2.00 95% 5 36 4 40 116 19ENT-0340 Market
Rate
825 Santa Monica Blvd GC 22.5 1.50 1.50 125% 3 52 4 56 108 18ENT-0038 Market
Rate
2822 Santa Monica Blvd MUBL 28.487 1.75 1.75 100% 3 46 4 50 76 16ADM-0050 Market
Rate
2901-2907 Santa Monica Blvd MUBL 19.122 1.50 1.50 100% 3 44 7 51 116
8.B.i
Packet Pg. 751 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F
-59 City of Santa Monica 2021
-2029 Housing Element
PROJECT ID PROJECT
TYPE
ADDRESS STREET ZONING SITE SIZE
(SF)
FAR FAR
(ALLOWABLE)
% OF
MAXIMUM
FAR
STORIES MARKET
RATE UNITS
AFFORDABLE
UNITS
TOTAL
UNITS
UNITS/ACRE
BUILT/PROPOSED
17ENT-0298 Market
Rate
2906-2918 Santa Monica Blvd MUBL 28.309 1.68 1.75 96%3 424 46 71 15ENT-0313 Market
Rate
3008 Santa Monica Blvd MUBL 14.307 1.74 1.75 100%3 224 26 79 18ENT-0182 Market
Rate
1618 Stanford MUC 19.969 1.70 1.70 100%5 434 47 103
16ENT-0115 Market
Rate
601-611 Wilshire Blvd MUB 14.952 2.25 2.25 100%4 373 40 117 06DR-020 Market
Rate
2300 Wilshire Blvd C6 40.6 1.48 1.50 99%3 30- 30 32
19ENT-0028 Market
Rate
2729 Wilshire Blvd MUB 7.5 1.25 1.25 100%2819 52
18ENT-0244 Market
Rate
3223 Wilshire Blvd MUB 19.5 2.25 2.25 100%4 494 53 118
21ENT-0035 Market
Rate
1101 Wilshire Blvd MUB 22.489 3.03
(SDB)
2.25 135%6 82 11 93 180
22ENT-0011 Market
Rate
1553-1555 4th St TA 14.997 2.87 2.25 128%5 546 60 174
22ENT-002 Market
Rate
1302 6th St NV 18.4 3.50 3.5 100%6 737 80 189
21ENT-0091 Market
Rate
1524 7th St TA 15 4.00 2.25 178%8 80 20 100 290
21ENT-0217 Market
Rate
528 Arizona Ave NV 18.5 3.50 3.50 100%6 737 80 188
22ENT-0037 Market
Rate
1527-1547 Lincoln Blvd LT 37.455 2.25 2.25 100%5 1068 114 133 22ENT-0012 Market
Rate
2537 Lincoln Blvd GC 19.2 2.25 1.50 150%4 445 49 111
22ENT-0013 Market
Rate
2601-2645 Lincoln Blvd MUBL 203.25 2.25 1.50 150%5 468 53 521 112 21ENT-0226 Market
Rate
1801 Santa Monica Blvd GC 22.49 1.50 1.50 100%3 41- 41 79 21ENT-0227 Market
Rate
1819 Santa Monica Blvd GC 22.5 1.50 1.50 100%3 41- 41 79 22ENT-0005 Market
Rate
1902 Wilshire Blvd MUB 22.5 2.25 2.25 100%5 71- 71 137
8.B.i
Packet Pg. 752 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Appendix
F | Report on Suitable Sites Inventory Analysis F-60
PROJECT ID PROJECT
TYPE
ADDRESS STREET ZONING SITE SIZE
(SF)
FAR FAR
(ALLOWABLE)
% OF
MAXIMUM
FAR
STORIES MARKET
RATE UNITS
AFFORDABLE
UNITS
TOTAL
UNITS
UNITS/ACRE
BUILT/PROPOSED
21ENT-0228 Market
Rate
1931 Wilshire Blvd MUB 25.5 2.25 2.25 100%5 60- 60 102
22ENT-0006 Market
Rate
2025 Wilshire Blvd MUB 18.5 2.25 2.25 100%4 46- 46 108
22ENT-0007 Market
Rate
2501 Wilshire Blvd MUB 30.8 2.25 2.25 100%4 78- 78 110
8.B.i
Packet Pg. 753 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-61 City of Santa Monica 2021-2029 Housing Element
Attachment 3 - Environmental and Infrastructure Constraints Government Code Section 65583.2(b)(4) requires a general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the jurisdiction. This information need not be identified on a sitespecific basis. Below is a summary of the analysis of potential environmental and infrastructure constraints:
1. Environmental Constraints
a. Fire
The City is highly urbanized and does not include any areas designated as a High or Very High Fire Hazard Severity Zone (FHSZ). The nearest wildfire zones are to the north of the City associated with the Santa Monica Mountains and as such, wildfire risk is very limited within City boundaries. The primary fire hazard risks are man-made and are most likely to occur in commercial and industrial areas where industrial chemicals are used, stored, or transported.
These potential fire risks, however, are mitigated by stringent enforcement of State and Federal regulations related to hazardous materials storage and transport. Fire risks are not considered constraints to housing development since there are existing regulations and plans in place to address such risk.
b. Flooding
FEMA recently updated the City’s flood maps to account for flooding due to climate change and rising ocean levels. Based on the new maps, 85 beach front properties along Pacific Coast Highway in the City are now within a FEMA defined Special Flood Hazard Area (SFHA), which is an area subject to a one percent or greater chance of flooding in any given year. To ensure compliance with FEMA, the City amended Santa Monica Municipal Code Chapter 7.68 (Floodplain Management Regulations) on March 3, 2021. The amended regulations require new construction in the special flood zones to obtain a floodplain development permit and implement safety requirements addressing flood risks. Inundation by tsunami can also affect the low-lying beach front properties of the City. In the event of a tsunami, the City has designated tsunami evacuation routes and has also adopted a Multi Hazard Functional Emergency Plan to reduce risk and prevent loss from large scale emergencies, including tsunamis. Location in a flood zone or tsunami zone are not considered constraints to housing development since there are existing regulations and plans in place to address such risk. c. Fault Rupture and Seismic Hazards
The City of Santa Monica is located in a seismically active area. The closest known fault in the City is the Santa Monica Fault, which is comprised of various segments with several strands that cross through the northeastern portion of the City. The Santa Monica Fault zone was designated in 2018 as an active fault by the California Geological Survey (CGS). A number of SSI sites identified on the eastern end of Wilshire Boulevard and Santa Monica Boulevard are located within this fault zone. The State does not prohibit housing in an active fault zone, but instead
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Packet Pg. 754 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-62 requires that structures built for human occupancy be assessed for potential fault rupture risks.
Consistent with State requirements, the City’s Building and Safety Division requires the submittal of a Fault Rupture Study to assess potential fault rupture risks and implement measures as necessary to mitigate such risks.
Additionally, the design and construction of new buildings are required to be engineered to withstand the seismic ground acceleration that may occur during an earthquake, pursuant to the Santa Monica Building Code which incorporates applicable provisions of the California Building Code (CBC). The City also requires new buildings to submit a Design-Level Geotechnical Report prior to building permit issuance in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design to minimize seismic hazards. Fault rupture risks and seismic hazards are not considered constraints to housing development since there are existing regulations and plans in place to address such risks.
d. Liquefaction
Liquefaction occurs when ground shaking transforms granular material from a solid state to a liquefied state due to earthquake. These soils may acquire a high degree of mobility and lead to structurally damaging deformations. Liquefaction begins below the water table, but after liquefaction has developed, the groundwater table will rise and cause the overlying soil to mobilize. Liquefaction typically occurs in areas where the groundwater is less than 30 feet from the surface and where the soils are composed of poorly consolidated fine to medium sand. The CGS Seismic Hazard Zone Map that covers the City of Santa Monica identifies the beach front areas and a small eastern portion of the City between Olympic Boulevard and Pearl Street as having liquefaction risk. However, according to the City’s Safety Element Geologic Hazards map, the City has varying potential for liquefaction:
• Along the beach
• From the beach, inland to the southwest corner of the city to Marine Park following the lowlands along Lincoln Boulevard
• In the northern industrial corridor
Liquefaction risks are addressed through the City’s building permit process. The design and construction of new buildings are required to be engineered to address potential liquefaction risks, pursuant to the Santa Monica Building Code which incorporates applicable provisions of the California Building Code (CBC). Additionally, the City requires developers of new buildings to submit a Design-Level Geotechnical Report in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. The Geotechnical Report is required to include a sitespecific soils investigation to determine liquefaction potential on the site. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design prior to building permit issuance to minimize liquefaction risks. As such, liquefaction is not considered to be a constraintto housing development since there are existing regulations and plans in place to address this environmental concern.
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Packet Pg. 755 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-63 City of Santa Monica 2021-2029 Housing Element
e. Landslides
The main areas of landslide concern within the City are confined to the areas along Highway 1/Pacific Coast Highway (Hwy 1) below the Palisades bluffs, at the southwestern edge of the City. The City has implemented a number of projects in the past decade to reduce landslide risks and soil instability at the bluffs including the California Incline Bridge Replacement Project and the Santa Monica Palisades Bluff Stabilization Project. The geotechnical reports for these two projects were submitted to the California Coastal Commission, Caltrans, and the City of Santa Monica and each agency concluded that the planned construction improvements on the bluff would be safe and not cause or contribute to erosion or degradation of geologic stability. In addition, several slope stabilization and dewatering measures have been implemented by the City which has decreased rate of erosion and improved the stability of the bluffs. As a result of these measures, landslide risks below the bluffs are considered low.
The properties in the northern portion of the City (near the Santa Monica Mountains) and in the Bryn Mawr Avenue residential area near Marine Park are characterized by steeper slopes. The design and construction of new buildings are required to be engineered to minimize landslide risks and soil instability, pursuant to the Santa Monica Building Code which incorporates the applicable provisions of the California Building Code (CBC). The City also requires new buildings to submit a Design-Level Geotechnical Report prior to building permit issuance in accordance with the requirements of the City’s Guidelines for Geotechnical Reports. All recommendations and design features in the Design-Level Geotechnical Report must be incorporated into the building design to minimize landslide and soil collapse hazards. Landslide risks are not considered to be constraints to housing development since there are existing regulations and plans in place to address such concerns.
f. Former Claypit/Landfill Areas
Beginning in the early 1900s, clay mining operations took place in the east central portion of the City (near the City Yards andthe Bergamot Plan area). After clay quarries were depleted, some clay pit areas were used as municipal landfills by the City from the mid-1940s until December 1970. After the landfills closed, structures were built over the landfills and remediation efforts have taken place including the installation of methane probes at the City Yards. Future housing projects occurring in these former claypit/landfill areas would require detailed Phase I environmental Site Assessments and subsurface investigations (Phase II) as necessary to address human health hazards. Any clean up recommendations and remediation measures in Phase I and Phase II site assessments are required to be implemented under the oversight of the appropriate clean up agency (Department of Toxic Substances Control, State Water Resources Control Board, Santa Monica Fire Department, etc.). The former claypit/landfill areas are not considered to be constraints to housing development since there are existing regulations and plans in place to address such concerns on a case-by-case basis. g. Santa Monica Airport
The Santa Monica Municipal Airport, located in the southeastern area of the City, covers approximately 215 acres of land generally bounded by Bundy Drive to the east, Santa Monica Business Park and Ocean Park Boulevard to the north, 23rd Street to the west, and Dewey Street
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Packet Pg. 756 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-64 in the City of Los Angeles to the south. The Santa Monica Municipal Airport is a general aviation airport that primarily caters to personal aircraft and flight schools and contains a number of non-aviation uses primarily located in the area south of the runways, including the Santa Monica College Bundy Campus. This airport is currently subject to a settlement agreement with the FAA and Consent Decree that require the City to maintain airport operations through December 31, 2028, and to also Santa Monica Measure LC, which governs use of the entire airport site should the City elect to close its airport at any time after December 31, 2028, as authorized by the Consent Decree.
The Los Angeles County Airport Land Use Commission (ALUC) is responsible for airport land use compatibility planning for Los Angeles County. Local actions, including rezoning and new housing projects located within an Airport Influence Areas (AIA) must be submitted to the ALUC for review. None of the sites identified in the SSI are located in Santa Monica’s AIA. The other potential environmental issue associated with the airport relates to operational noise. In general, residential uses should be sited outside of an airport’s 65 dBA CNEL (decibels, Community Noise Equivalent Level) noise contour. None of the sites identified in the SSI are located within the Santa Monica Airport’s 60, 65, and 70 CNEL noise contours. Therefore, the presence of the Santa Monica Airport is not considered to be a constraint to housing development.
h. Biological Resources
The City is mostly urbanized, with few areas of native wildlife habitat occurring within the City limits. The nearest wildlife habitat occurs along the coast at Santa Monica State Beach.
Substantial forested open space occurs in the Santa Monica Mountains, located approximately
3.5 miles to the north. The majority of the City of Santa Monica has been developed, paved, or landscaped, and is generally devoid of large expanses of habitat that support sensitive species.
No major regional wildlife migration corridors are known to exist within the City limits. No native riparian habitat, blueline streams, wetlands, or sensitive natural communities are located in the City limits. The beach areas of the City do provide foraging and roosting opportunities for several special status species (e.g., least terns. Snowy plovers). The City is not recognized as an existing or proposed Significant Ecological Area (SEA) that links wildlife populations. Biological resources are not considered to be constraints to housing development.
2. Infrastructure Constraints
As an urbanized community with well established residential neighborhoods and commercial districts, Santa Monica has a comprehensive backbone infrastructure which includes existing sewer and water lines, and storm drains. Based on existing and planned capacity, the City has sufficient infrastructure (water, sewer, and storm drain) capacity to accommodate the RHNA at all income levels.
a. Sewer System
The City’s sewer system consists of approximately 210 miles of sewer pipes ranging in size from 6 to 36 inches in diameter. Sewer lines are composed of vitrified clay pipes, plastic pipes, or reinforced concrete pipes. Sewer pipes have a flow capacity based on the diameter of the pipe
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Packet Pg. 757 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F-65 City of Santa Monica 2021-2029 Housing Element
and the slope of the pipeline. Increased wastewater flows from construction of up to 8,895 units in the next 8 years under the RHNA is projected to result in impacts to existing sewer pipes, incrementally triggering the need for expansion or replacement of individual sewer line segments. The City’s Public Works Department anticipates that an increase in the Capital Facilities Fee would be necessary to finance the capital improvements necessary to accommodate the increase in housing. While an increase in sewage capacity will be required to serve future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The City does not budget or pay for improvements that are necessary to support individual private development projects, which includes affordable housing projects. If it is shown that infrastructure capacity will be exceeded by a project, private developers are generally responsible for the cost of upsizing the mains needed to support the demand generated by the project. Housing projects would not be constrained by sewer capacity issues.
b. Water System
The City of Santa Monica Water Resources Division is a retail water agency providing water service throughout the City, including single- and multi-unit residential, commercial, and industrial customers, and landscape and fire protection supply. The City distributes water to approximately 18,000 customer accounts through a 140-mile network of water lines ranging from 4 to 36 inches in diameter. New housing would be required to comply with the City’s Water Neutrality Ordinance, which requires an offset of new water demand (50% offset of new water demand for 100% affordable housing projects). Nevertheless, water demand from construction of new housing is expected to increase, which could trigger the need for additional water distribution pumps if there is insufficient water pressure. While an increase in water system capacity will be required to serve future housing development, the City will be increasing the Capital Facilities Fee to implement improvements as necessary to serve future housing development. The City does not budget or pay for improvements that are necessary to support individual private development projects, which includes affordable housing projects. If it is shown that infrastructure capacity will be exceeded by a project, private developers are generally responsible for the cost of upsizing the mains needed to support the demand generated by the project. Housing projects would not be constrained by water system capacity issues.
c. Water Supply
The City water supply consists of local groundwater, imported water from Metropolitan Water District of Southern California (MWD), and urban treated runoff water from the Santa Monica Urban Runoff Recycling Facility (SMURRF). The City’s primary sources of water supply include groundwater drawn from the Santa Monica Groundwater Basin (SMGB) and imported water supplies provided by the Metropolitan Water District of Southern California (MWD). The City prepared a 2020 Urban Water Management Plan (UWMP) which is slated for adoption in June 2021. The UWMP indicates that sufficient water supply exists to serve the forecasted planned housing in the Housing Element Update. Therefore, water supply is not considered a constraint to housing development.
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Packet Pg. 758 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-66 d. Storm Drains
The overall drainage pattern of the City of Santa Monica is to the southwest. An underground storm drain system intercepts surface runoff through a series of catch basins, connector pipes and mainlines and carries the majority of the storm water to the Santa Monica Bay portion of the Pacific Ocean. The storm drain system is comprised principally of pipes and channels owned by two separate entities: the City of Santa Monica and the County of Los Angeles. Additionally, a few drainage facilities within the right-of-way of Interstate 10 are under Caltrans jurisdiction.
The storm drain pipes/channels in the city range from 16 inches to 11 feet in diameter. The conduits are mainly constructed of reinforced concrete pipe (RCP) or reinforced concrete (RC). A few of the structures are brick arch drains, or corrugated metal pipes (CMP).
Approximately 75miles of storm drain pipes are within the city. Of the approximately 1,900 catch basins collecting runoff into the storm drain system, about 1,050 are owned and maintained by the County; 70 by the City of Santa Monica, and 100 by Caltrans.
The City has constructed an Urban Runoff Recycling Facility (SMURRF) to treat the dry weather storm drain discharges from excess irrigation, spills, construction sites, pool draining, car washing and other activities that would otherwise drain into the Santa Monica Bay and recycle it for irrigation and dual plumbed building purposes.
All projects on sites over 15,000 sf would be subject to the City’s Runoff Conservation and Sustainable Management Ordinance requirements. This would include preparation and implementation of a Runoff Mitigation Plan to minimize polluted runoff in accordance with the City’s Ordinance. In addition, the projects would be required to store and use (for non-potable purposes), infiltrate, or evapotranspire project-generated runoff during a 0.75-inch storm event, or alternatively, pay the City an urban runoff-reduction fee. Therefore, storm drains do not pose a constraint to housing development.
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Packet Pg. 759 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) F
-67 City of Santa Monica 2021
-2029 Housing Element
Attachment 4 – Letter of Intent from SMMUSD
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Packet Pg. 760 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis B-68 Attachment 5 – Suitable Sites Inventory Table
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Packet Pg. 761 Attachment: Appendix F SSI Report Clean June 2022 (4856 : Housing Element Draft Revisions in F-61 City of Santa Monica 2021-2029 Housing Element
Category Consolidated
Site Address Parcel No. Zoning District
Land
Area Existing Use Building Age ILR Optional Information 1 A 3223 WILSHIRE BLVD 4266001046 MUB 6,522 parking lot for Aah's 0.00 approved project - part of 3223 wilshire 1 A 3223 WILSHIRE BLVD 4266001045 MUB 13,063 one-story Aah's retail store 1955 0.11 approved 54 unit project 1 AA 1431 LINCOLN BLVD 4282027019 LT 7,512 one-story comic book store 1983 0.13 approved 100 unit project (1427-1431 Lincoln) 1 AA 1427 LINCOLN BLVD 4282027020 LT 7,501 one-story comic book store 1956 0.02 approved 100 unit project (1427-1431 Lincoln) 1 AC 1527 LINCOLN BLVD 4282028019 LT 7,494 former tile store; vacant retail building 1945 0.31 common ownership; in Downtown; single tenant building 1 AC 1533 LINCOLN BLVD 4282028018 LT 7,510 former tile store; vacant retail building 1952 0.43 common ownership; in Downtown; single tenant building 1 AM 3RD STREET/PICO
BLVD 4289019022 MUBL 5,601 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 216 PICO BLVD 4289019023 MUBL 5,613 vacant one story bowling alley 1962 0.06 SB330 application; 199 units/ 19 affordable 1 AM 228 PICO BLVD 4289019021 MUBL 5,621 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 248 PICO BLVD 4289019017 MUBL 5,590 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 254 PICO BLVD 4289019016 MUBL 5,611 vacant one story bowling alley 0.00 SB330 application; 199 units/ 19 affordable 1 AM 234 PICO BLVD 4289019019 MUBL 28,008 vacant one story bowling alley 1959 0.10 SB330 application; 199 units/ 19 affordable 1 AO 1342 5TH ST 4291011019 NV 7,509 parking lot 0.00 approved 120 unit w SRO project (1338-1342 5th St) 1 AO 1342 5TH ST 4291011020 NV 7,485 parking lot 0.00 approved 120 unit w SRO project (1338-1342 5th St) 1 AR 1445 5TH ST 4291019016 TA 7,498 vacant one-story multitenant retail building 1946 0.02 approved project w SRO 1437-1445 project (63 units) 1 AR 1445 5TH ST 4291019017 TA 7,511 parking lot next to vacant retail 0.00 approved project w SRO 1437-1445 project (63 units) 1 AT LINCOLN BLVD/SANTA
MONICA BLVD 4291021009 LT 3,751 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1438 LINCOLN BLVD 4291021008 LT 3,752 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1444 LINCOLN BLVD 4291021010 LT 7,491 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1430 LINCOLN BLVD 4291021006 LT 7,507 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AT 1432 LINCOLN BLVD 4291021007 LT 7,492 parking lot 0.00 approved 100 unit project (1430-1444 Lincoln) 1 AU 1500 LINCOLN BLVD 4291022003 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1500 LINCOLN BLVD 4291022025 LT 22,450 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1518 LINCOLN BLVD 4291022004 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1526 LINCOLN BLVD 4291022005 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 1534 LINCOLN BLVD 4291022006 LT 7,500 one-story Von's with parking lot 0.00 approved 300 unit project (710 Broadway) 1 AU 710 BROADWAY 4291022026 TA 52,450 one-story Von's with parking lot 1995 0.18 approved 300 unit project (710 Broadway) 1 AX 1553 4TH ST 4291025028 TA 7,474 Vacant bank site across DT station 0.00 common ownership; vacant building in DT 1 AX 1555 4TH ST 4291025012 TA 7,497 Vacant bank site across DT station 1973 0.01 common ownership; vacant building in DT 1 AY 1127 2ND ST 4292021010 WT 7,517 parking lot 0.00 approved 100% affordable housing - 42 units 1 AY 1129 2ND ST 4292021009 WT 7,490 parking lot 0.00 approved 100% affordable housing - 42 units 1 BG 1152 21ST ST 4276007021 MUB 3,491 rear parking lot for NOMA sushi and Veggie grill (2025 wilshire) 0.02 SB330 application; 46 units w/ offsite affordable at 1211-1215 19th 1 BG 2025 WILSHIRE BLVD 4276007027 MUB 14,987 one story Veggie grill 1969 0.10 SB330 application; 46 units w/ offsite affordable at 1211-1215 19th 1 BL 1115 WILSHIRE BLVD
REAR 4281020029 MUB 13,949 rear parking lot 1927 0.18 (blank) 1 BL 1101 WILSHIRE BLVD 4281020012 MUB 8,559 one-story JP bar 1922 0.19 SB330 application; pending project (93 units) 1 BN 1819 SANTA MONICA
BLVD 4276029011 GC 14,986 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BN 1350 19TH ST 4276029010 GC 7,495 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BN 1342 19TH ST 4276029009 R2 8,991 Honda auto inventory lot 0.00 SB330 application; 41 units w/ 7 affordable 1 BO 2911 SANTA MONICA
BLVD 4267011022 MUBL 6,501 one story retail building 1926 0.20 approved 53 unit project (2901-2907 Santa Monica project) 1 BO 1347 YALE ST 4267011021 MUBL 3,266 one-story retail building 1926 0.25 approved 53 unit project (2901-2907 Santa Monica project)
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Packet Pg. 762 Attachment: Appendix F SSI Table Clean June 2022 (4856 : Housing Element Draft Revisions in Response to HCD (120 mins)) Appendix F | Report on Suitable Sites Inventory Analysis F-62 Category Consolidated
Site Address Parcel No. Zoning District
Land
Area Existing Use Building Age ILR Optional Information 1 BO 1349 YALE ST 4267011020 MUBL 9,368 one story multitenant retail building, two story apartment building w parking lot 1923 0.11 approved 53 unit project ( 2901-2907 Santa Monica project) 1 BP 1543 LINCOLN BLVD 4282028010 LT 7,497 one story vacant auto repair 1947 0.13 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BP 1547 LINCOLN BLVD 4282028009 LT 7,499 one story vacant auto repair 1999 0.43 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BP 1537 LINCOLN BLVD 4282028011 LT 7,496 one story vacant auto repair 1945 0.25 SB330 application; 114 units w/ offsite affordable at 1333 7th 1 BS 2002 21ST ST 4274026001 R2 7,533 one-story apartments 1949 0.10 approved Park Virginia Townhomes 19 units 1 BS 2008 21ST ST 4274026003 R2 7,130 one-story apartments 1953 0.11 approved Park Virginia Townhomes 19 units 1 BT 1840 14TH ST 4283030018 NC 7,524 100% affordable housing under construction 1962 0.26 approved affordable housing project 73 units 1 BT 1844 14TH ST 4283030017 NC 7,485 100% affordable housing under construction 1922 0.50 approved affordable housing project 73 units 1 BT 1848 14TH ST 4283030016 NC 7,525 100% affordable housing under construction 1968 0.00 approved affordable housing project 73 units 1 BU 1415 5TH ST 4291019021 TA 7,494 two story multitenant retail building 1980 0.00 approved 111 unit project (1415-1423 5th St) 1 BU 1423 5TH ST 4291019020 TA 7,525 two story multitenant retail building 1966 0.00 approved 111 unit project (1415-1423 5th St) 1 BV 1543 7TH ST 4291022014 TA 7,500 parking lot 1990 1.73 approved 100 unit project (1543-1547 7th St) 1 BV 1547 7TH ST 4291022013 TA 7,500 parking lot 0.00 approved 100 unit project (1543-1547 7th St) 1 BW 1547 6TH ST 4291023011 TA 7,505 one-story multi-tenant building, restaurant, office 1986 0.00 approved 140 unit project (part of 609 Colorado project) 1 BW 609 COLORADO AVE 4291023010 TA 14,982 one-story multi-tenant building, restaurant, office 1984 0.17 approved 140 unit project (part of 609 Colorado project) 1 BX 601 WILSHIRE BLVD 4292005029 WT 10,010 vacant one and two story buildings 1977 0.07 approved 40 units w/ 3 affordable (601-611 Wilshire) 1 BX 611 WILSHIRE BLVD 4292005026 WT 4,997 vacant one and two story buildings 1922 0.14 approved 40 units w/ 3 affordable (601-611 Wilshire) 1 BY 1650 LINCOLN BLVD 4290002008 LT 16,220 one-story retail, boxing fitness building 1954 0.00 approved 98 Units (1650-1660 Lincoln) 1 BY 1660 LINCOLN BLVD 4290002006 LT 7,570 one-story retail, boxing fitness building 1954 0.00 approved 98 Units (1650-1660 Lincoln) 1 BZ 1437 LINCOLN BLVD 4282027018 LT 7,485 one-story retail building 1949 0.00 approved 40 unit project (1437-1443 Lincoln) 1 BZ 1443 LINCOLN BLVD 4282027028 LT 7,510 one-story retail 1959 0.00 approved 40 unit project (1437-1443 Lincoln) 1 C 2501 WILSHIRE BLVD 4276001026 MUB 14,319
one-story commercial building with multiple
retailers; corner parcel; with rear residential
parking lot
1951 0.14 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 C 2515 WILSHIRE BLVD 4276001025 MUB 6,164 one-story multi-tenant commercial building 1941 0.49 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 C 2525 WILSHIRE BLVD 4276001027 MUB 10,347
one-story commercial building, Starbucks,
Urgent Care, Postal Store; common ownership;
corner parcel with rear residential parking
1970 0.44 SB330 application; 78 units w/ offsite affordable at 1215 19th 1 CA 1313 6TH ST 4291009021 NV 15,010 parking lot 0.00 approved 64 unit project (1313-1325 6th St) 1 CA 1323 5TH ST 4291010029 NV 7,512 parking lot 0.00 approved 43 unit project 1 CH 1902 WILSHIRE BLVD 4276013020 MUB 4,989 one story retail/restaurant building (Thai dishes, salon, medical office) 1939 0.33 SB330 application; 71 units w/ offsite affordable in rear 1 CH 1908 WILSHIRE BLVD 4276013030 MUB 24,993 one-story retail/restaurant building (Thai dishes, salon, medical office) 1925 0.20 SB330 application; 34 affordable units; lot has been split with 100% affordable in rear 1 CI 1921 WILSHIRE BLVD 4276008014 MUB 15,015 one-story retail building (GAP) 1975 0.41 SB330 application; 60 units w/ 9 affordable 1 CI 1933 WILSHIRE BLVD 4276008015 MUB 10,520 one-story retail building (GAP) 1958 0.33 SB330 application; 60 units w/ 9 affordable 1 E 2906 SANTA MONICA
BLVD 4267018026 MUBL 21,314 vacant two story office 1969 0.79 approved 46 unit project (2906-2918 Santa Monica Blvd) 1 E 2918 SANTA MONICA
BLVD 4267018003 MUBL 7,021 vacant parking lot 1965 0.12 approved 46 unit project (2906-2918 Santa Monica Blvd) 1 P 1347 18TH ST 4276029026 GC 7,512 Honda dealership with surface inventory 1969 0.00 SB330 application; 41 units w/ 7 affordable 1 P 1801 SANTA MONICA
BLVD 4276029048 GC 14,984 Honda dealership with surface inventory 1953 0.02 SB330 application; 41 units w/ 7 affordable 1 S 825 SANTA MONICA
BLVD 4282010012 GC 7,505 Toyota dealership 0.00 pending project 48 units (825 Santa Monica)