Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
1 HOUSING ELEMENT 2021-2029 SUMMARY OF RESPONSES TO HCD COMMENTS This table contains corrections, clarifications, and changes to the published text of the 6th Cycle Housing Element and represents changes in response to HCD’s comments. The proposed corrections, clarifications, and changes to the Housing Element Update are listed with their locations and their corrections. There may be errors, clarifications and changes that carry over to multiple areas within the plan, all of which will be addressed and amended.
Change
No.
Page
Number
Summary of Change Recommended Redline
1. 91 Addresses HCD
Comment.
Provided additional
background on past
development on CityOwned Sites
The City has worked to overcome these barriers over the past 40 years by supporting 100% affordable housing on city-owned land resulting in the production of 770 units of affordable housing. The long-term affordability of these units has been guaranteed through recorded deed restrictions or in the case of property sale, the City has negotiated for right of first option to purchase for a low, fixed amount in the event of future sale. As such the City has a demonstrated history of continuously leveraged public land to produce affordable housing for the benefit of the community.
2. 108 Addresses HCD
comment.
SSI: Provide
background on local
data and knowledge
used to develop SSI.
To prepare the SSI, the City’s land use inventory was comprehensively reviewed to identify sites that are available for housing development within the Housing Element planning period, 2021-2029. The SSI process utilizes the Land Use Inventory to first identify which parcels are available for redevelopment based on zoning, general characteristics such as historic and land use designations, and market factors. City staff then further evaluated the sites individually using Google Streetview or site visits and assigned a potential redevelopment rating of “high, medium high, medium, or low” based on site-specific factors such as existing use, physical attributes, ownership, and other local knowledge by City Staff. Sites that were rated as “high” comprise the SSI. Following this process of identifying high potential SSI sites, the City applied development standards to the available sites to calculate housing capacity. The City then conducted a spot-check of individual parcels against current and past projects to confirm that the unit calculations resulted in realistic capacity. The City focused the inventory to underutilized commercial sites since these sites are most likely to be redeveloped based on evidence of past development trends. Based on the assessment of sites using the above factors and methodology, there are 138 parcels that have approved and pending projects for residential development and 180 non-vacant commercial/mixed use zoned parcels in the City identified to have high potential for residential redevelopment. In addition, 22 residentially zoned sites that are developed as parking lots have been identified as having high potential Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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Number
Summary of Change Recommended Redline
to be redeveloped for housing. Approximately 332 340 sites have been identified that have the highest potential to accommodate housing. These are shown on Map 4-1. Sites may be viewed interactively on the City’s Housing Element Update webpage at:
https://www.santamonica.gov/housing-element-update. The sites in the SSI are categorized according to Figure 4-2.
3. 110 Technical Revision:
Updated
Approved/Pending
Projects
The City has a significant number of housing projects in the pipeline that if constructed will count toward the City’s 6th Cycle RHNA. As of February 2021May 2022, there were approximately 1,6702,594 approved units (of which 401 637 are affordable) and 756 2,550 pending units on 108 13 parcels. The list of approved and pending projects is provided in Appendix F. A review of the past 5th Cycle Housing Element shows that 10% of approved and pending projects were withdrawn and/or have had permit approvals expire. It is not possible for City staff to predict how many and which specific approved and pending projects could be withdrawn or ultimately not developed. Doing so would be arbitrary and speculative.
Therefore, a 10% discount factor was applied to the current number of approved and pending units to allow for the possibility that some projects may never proceed to construction. This results in 1,5032,205 approved units and 680 2,168 pending units that are projected to count towards the 6th Cycle Housing Element.
4. 111 Technical Revision:
City Owned Sites
The City-owned sites in the SSI are: Public Parking lots 7, 8, and 12, Parking Structure 3, 4th & Arizona, Bergamot Arts Center, and Main Street parking lots. With consideration to existing constraints (such as lease terms, financial resources, etc.), City-owned sites have the potential for accommodating 1,884 880 units. Program 2.E commits the City to plan for a minimum of 1,884 880 affordable housing units across available City-owned sites, which may include but shall not be limited to rezoning actions.
5. 111 Technical Revision:
Community Assembly
Sites
Community Assembly Sites (including Religious Congregations)
6. 112 Technical Revisions:
SSI
With the programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production has the capacity to accommodate at least 11,07013,600 units providing a 24 53 percent buffer above the City’s RHNA of 8,895 units.
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This number is based on the application of new development standards for housing projects as established in Programs 1.F and 1.J. The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing.
Approximately 150 additional units could be added to the total capacity if housing projects on these sites provided on-site affordable housing, rather than off-site. The land inventory includes capacity for 2,444 521 extremely low, 2,3982,819 very low income, 2,542,703 low income, and 1,7841,901 moderate income units. Figure 4-3 breaks down the summary of the SSI capacity based on category and income levels.
Total
Capacity Capacity for Affordable Units
# Units
# Affordable
Units ELI VLI LI Moderate
Category 1
Approved
2,205 1,503 637 416 127 104 177 104 185104 148 104
Category 1
Pending
2,168 680 420 165 24 42 321 42 3442 41 42
Category 4
City Sites
1,880 1,884 1,880 1,884 627 628 627 628 627 628 - -
Category 11
Religious
Sites
257 257 130 129 32 32 32 32 32 32 34 32
Category 12
Parking Lots
96 105 9 53 - 13 - 13 9 13 - 13
All
Remaining
Categories
6,6196,289 6,6196,289 1,6551,572 1,6551,572 1,6551,572 1,6551,572 ADUs
376 352 249 232 56 53 8 7 162 151 23 21
Total 13,600
11,070
9,944 9,168 2,521 2,444
2,8192,398
2,7032,542 1,9011,784
RHNA
Targets
8,895 8,895 6,168 6,168 1,397 1,397 1,397
1,397
1,672 1,672 1,702
1,702
Buffer +4,705+2,175
+
3,776+3,000 +1,124+1,047
+
1,422+1,001
+ 1,031+870 +199+82
2453%
7. 114 Technical Revisions:
Past Permitted ADUs
Building Permit
Year
PermitS Issued Total
2018 2354 56
Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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2019 6051 83
2020 4127 115
2021 2102 27
TOTAL 226134 281
Average
2018-20201
(23+60_41+102) 54+51+27)/34
= 4456.5 units per year
Source: Building permit data as of June 1, 2021May 31, 2022 Each ADU building permit is only accounted for once across all years.
Updated Map 4-2 to reflect updated ADU data.
8. 116 Technical Revision:
Forecasted ADU
Development
As shown in the above table, based on ADU building permit data between 2018 and 20201, Santa Monica averagesd 4456 ADUs per year. However, given that 36 of the ADUs (approximately 16%) were located on parcels with existing multi-unit dwellings, which are less typical applicants for ADUs, the average annual production estimate has been reduced by 16% to approximately 47 ADUs per year. Therefore, Using this average production number, it can be expected that over the next eight-year Housing Element cycle, approximately 352376 ADUs will be built and can be used towards our RHNA. This estimate is conservative, as it accounts for a potential progressive decline in available land for ADU within single-unit zones. As noted, Tthis forecast also does not account for possible future interest in ADUs to be incorporated into existing multiple-unit residential and mixed-use developments, which the City has only just started seeing very recently as the new law permitting this only took effect January 1, 2020.
Income Level Percent of ADUsa Projected # of ADUs
Extremely Low Income 15% 5653
Very Low 2% 78
Low 43% 162151
Moderate 6% 2321
Above Moderate 34% 128120 a Based on SCAG Survey of ADU Affordability
9. 19 & 121 Program 1.A:
Elaborate on
Streamlined Approvals
… The by-right process for housing projects is intended to achieve the RHNA target and at minimum, the Quantified Objectives established in this Housing Element. ...
Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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The City shall also continue to facilitate consolidation of sites for housing projects by processing administrative lot tie agreements as part of the plan check process.
March 31, 2022October 15, 2022
10. 20, 123, &
E-55
Program 1.B : Evaluate
ARB approval findings
for impacts on housing
production.
…. The City shall review approval findings for design review and establish procedures or other mechanisms to promote approval certainty. The amendments shall also be clear that design review cannot be used to reduce density or deny a housing project. Additionally, the City shall develop objective design standards for applicable housing projects, which will also be used to ensure consistency anticipating compliance with SB35 for applicable housing projects.
Objective Design Standards by June 30, 2023; Process streamlining by October 15, 2022September 30, 2022
This includes expansions to the staff-level approvals, shifting the design review process to occur before or be concurrent with entitlement review, placing time and hearing limits on projects, review and establish mechanisms to promote approval certainty, and developing objective design standards.
11. 20 & 124 Program 1.C: Timing
Revision
August 1, 20222023
12. 20 & 125 Program 1.D: Timing
Revision.
August 1, 2022October 15, 2022
13. 20 & 126 Program 1.E: Technical
Revision.
By June 30, 2023
14. 21 & 127 Addresses HCD
comment.
Program 1.F: Specific
commitment to
change development
standards. Inserted
development
The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.75 to 4.0 with heights ranging from 55 feet to 84 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will promote housing and ensure feasibility and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than the minimum FAR and height shown in Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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Page
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Summary of Change Recommended Redline
standards table.
Timing revision.
the table below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement.
In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing including but not limited to development impact fees, unit mix, and designs standards… Zoning
District
Approx.
Acres to
be
Rezoned
Current
Tier 1
FAR
/Height
Minimum
Tier 1 FAR
/Height
with
Rezoning
Current
Tier 2
FAR/Height
Minimum
Tier 2
FAR/Height
with
Rezoning
Current
Tier 3
FAR/Height
Minimum
Tier 3
FAR/Height
with
Rezoning
LT (East) 12 1.50/ 39
ft
2.75/ 60
ft 2.25/ 50 ft 3.0/ 65 ft - -
LT (West) 11 1.50/ 39
ft
2.75/ 60
ft 2.75/ 60 ft 3.0/ 65 ft - -
NV 31 2.25/
39 ft
2.75/ 60
ft 3.50/ 60 ft 3.50/ 70 ft - 4.0/ 84 ft
BC
(Promenade) 12 2.25/ 39 ft
2.75/ 60
ft 2.75/ 60 ft 3.0/ 65 ft - -
BC (2nd/4th) 25 2.25/
39 ft
2.75/ 60
ft 3.50/ 60 ft 3.50/ 70 ft - -
TA 52 2.25/
39 ft
2.75/60
ft 3.50/ 60 ft 3.50/ 70 ft 4.0/ 84 ft 4.0/ 84 ft
OT 15 2.25/
39 ft
2.75/60
ft 2.75/ 60 ft 3.0/ 65 ft - -
WT 6 1.50/ 39
ft
2.75/60
ft 2.25/ 50 ft 3.0/ 65 ft - -
March 31, 2022October 15, 2022
15. 22 & 129 Addresses HCD
comment.
Program 1.G : Include
goals, priorities,
metrics, and
The City shall develop an Accessory Dwelling Unit Accelerator Program that will simplify the ADU process by providing property owners interested in constructing ADUs throughout all neighborhoods…
Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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milestones. Timing
revision. The program will further streamline the City’s ADU permitting review process with the aim of issuing building permits for an average of 47 ADUs/year.
December 31, 2022June 30, 2023
16. 22 & 129 Addresses HCD
comment.
Program 1.H: Stronger
language to commit to
zoning. Timing
revision.
As an alternative to constructing new housing, the City shall amend the Zoning Ordinance to encourage and incentivize the adaptive reuse of existing commercial tenant spaces citywide, for permanent residential use and also allow anadaptive reuse of existing ground floor commercial space for artists and live-work use. The City shall also adopt policy and zoning changes to Changes to incentivize the conversion of existing commercial tenant space to residential use include but are limited to, such as relaxing minimum parking requirements, unit mix, open space, and other typical zoning or building code requirements.
December 31, 20232024
17. 22 & 130 Timing Revision:
Program 1.I
December 31, 20232024
18. 22 & 131 Addresses HCD
comment.
Program 1.J: Specific
commitment to
change development
standards. Inserted
development
standards table.
Timing revision.
The City shall amend the Zoning Ordinance, LUCE, and the Bergamot Area Plan (BAP) to increase FAR and height standards throughout the city’s non-residential zoning districts (other than Downtown which is addressed in Program 1.F) to levels that can support feasible housing projects. The City’s assumptions of feasibility and the City’s SSI are based on the results of a feasibility analysis prepared by HR&A dated June 9, 2021 and February 2, 2022. Based on the results of the feasibility analysis, the feasible FARs for housing projects range from a minimum 2.002.75 to 3.25 with heights ranging from 55 feet to 65 feet. The City reserves the right to adjust these heights and FARs up or down. Any changes will ensure feasibility promote housing to ensure and that overall unit capacity assumed in the site inventory is met, including income category, and will be no lower than minimum FAR and height shown in the tables below. existing allowable height and FAR as of October 13, 2021. The off-site affordability requirement will be greater than the on-site requirement.
Zoning
District
# Acres to
be
Rezoned
Current
Tier 1
FAR/Height
Current Tier
2 FAR/Height
Minimum
FAR/Height
with
Rezoning
MUBL – N of
I-10 107 1.50/ 36 ft 1.75/ 36 ft 3.25/ 70 ft
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MUBL – Pico 15 1.50/ 36 ft 1.75/ 36 ft 2.00/ 45 ft
MUBL – Pico
(West of
Lincoln)
4 1.50/ 36 ft 1.75/ 36 ft 2.50/ 55 ft
MUBL – Main
St 10 1.50/ 36 ft 1.75/ 36 ft 2.50/ 55 ft
MUBL -
Lincoln 107 1.50/ 36 ft 1.75/ 36 ft 2.50/ 55 ft
MUB 59 1.50/ 39 ft 2.25/ 50 ft 3.25/ 70 ft
GC (SMB) 24 1.25/ - 1.50/ 35 ft 3.25/ 70 ft
GC (Lincoln) 19 1.50/ 36 ft 2.00/ 36 ft 2.50/ 55 ft
GC (Pico) 4 1.50/ 36 ft 2.00/ 36 ft 2.00/ 45 ft
NC 27 1.50/ 32 ft N/A 2.25/ 50 ft
NC (Main) 14 1.00/ 27 ft N/A 2.50/ 55 ft
NC (Ocean
Park) 15 1.00/ 32 ft N/A 2.50/ 55 ft
NC
(Montana) 15 1.00/ 32 ft N/A 2.50/ 55 ft
IC 77 N/A N/A 3.00/ 65 ft
OC 88 N/A N/A 2.75/ 60 ft
HMU 39 1.50/ 45 ft 2.50/ 70 ft 2.50/ 70 ft
Bergamot
Area
# Acres
to be
Rezoned
Current
Tier 1
FAR/Height
Current
Tier 2
FAR/Height
Current
Tier 3
FAR/Height
Minimum
FAR/Height
with
Rezoning
BTV 35 1.75/ 32 ft 2.00/ 60 ft 2.50/ 75 ft 4.0/ 84 ft
MUC – North
of
Pennsylvania
Avenue
parcel line
between
Stewart and
Stanford:
South of
Expo Bike
Path
31 1.50/ 32 ft 1.70/ 47 ft 2.20/ 57 ft 3.25/ 70 ft
Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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MUC -
remainder 31 1.50/ 32 ft 1.70/ 47 ft 2.20/ 57 ft 4.0/ 84 ft CCS 8 1.50/ 32 ft N/A N/A 2.50/ 55 ft
CAC 17 1.00/ 32 ft 1.00/ 60 ft 1.00/ 75 ft 2.50/ 55 ft
In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production… March 31October 15, 2022
19. 24 & 133 Addresses HCD
comment.
Program 1.K: Commit
to adequate densities,
acreage, and
requirements of Gov.
code 65583.2. Timing
revision.
To accommodate the City’s lower-income RHNA shortfall, the City shall make amendments to the Land Use and Circulation Element (LUCE), Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to create the opportunity for 1,880 lower income units and establish that the City-owned sites identified in the Suitable Sites Inventory meet all requirements pursuant to Government Code Section 65583.2(h) and (i) including but not limited to allowing are allowed 100 percent residential use and require requiring residential use to occupy at least 50 percent of the floor area. Additionally, while not required to meet the shortfall of lower-income units, the Zoning Ordinance shall be amended to specify additional mixed-used zoning districts that shall be allowed 100 percent residential uses. To ensure that the City comply with SB 166 (No Net Loss), the City will monitor new residential and mixed use project applications to ensure an adequate inventory is available to meet the City’s RHNA obligations.
August 1, 2022June 30, 2023
20. 25 & 134 Addresses HCD
comment.
Program 2.A: Include
goals, priorities,
metrics, and
milestones. Timing
revision.
The City shall amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in targeted at least three areas of the City…
August 1, 2022June 30, 2023
Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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21. 25 & 135 Addresses HCD
comment.
Program 2.B: Include
goals, priorities,
metrics, and
milestones. Timing
revision.
Promote the use of SB1079 (2020) which created a new foreclosure sale process for 2-4 unit buildings that allows qualified parties a means to purchase property in foreclosure, subject to certain requirements. Building off this state law, Tthe City shall consider adopting a Right of First Offer Ordinance that would provide nonprofit affordable housing providers the right of first offer for a specified time period to acquire private properties outside of foreclosure as they become available for purchase. As part of this effort, the City shall prioritize the scope of properties that would most effectively achieve the goal of making non-profit housing providers more competitive in the land buying market for the purpose of preserving or producing affordable housing. Given the lack of an identified funding source to assist nonprofit affordable housing providers in purchase of multi-unit residential buildingsthrough this program, explore funding sources, including grants and loans, that would contribute to the acquisition/rehabilitation quantified objective of 40 units. Require purchasers to preserve units as permanently affordable.
December 31, 20232024
22. 26 & 135 Addresses HCD
comment.
Program 2.C: Include
goals, priorities,
metrics, and
milestones. Timing
revision.
In order to increase the number of affordable housing units at all income levelssuch that 15% of all new multi-unit residential housing units are affordable to low and moderate income households and aim to achieve the Quantified Objective for lower income households as shown in Figure 5-1, Chapter 5, the AHPP on-site and off-site option for housing projects located outside of the Downtown shall be revised to include, but not be limited to… June 30, 2022by April 30, 2023
23. 26 & 137 Program 2.D: Timing
revision.
March 31October 15, 2022
24. 27 & 138 Program 2.E: Include
goals, priorities,
metrics, and
milestones.
The City shall plan for a minimum of 1,8841,880 affordable housing units across available City-owned sites, which are located throughout the city, as shown in Figure F-6, Appendix F, which may include, but shall not be limited to, rezoning actions in the LUCE, Specific Plans, and/or Zoning Ordinance amendments. Amendments to maximize affordable housing development potential on City-owned sites, and any subsequent development of those sites will be guided through a public process, including engagement of community stakeholders.
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At least three RFPs shall be issued for city-owned sites identified on the Suitable Sites Inventory to accommodate at least 1,880 affordable units. The first An RFP for at least onea city-owned site shall be issued by June 30, 2023. Subsequently, the City shall issue an RFP by June 30, 2025, and June 30, 2027 accounting for existing constraints on city-owned sites such as existing leases as shown in Figure F-6, Appendix F. Following the regular process for production of affordable housing on city-owned land, at the conclusion of the RFP process, .
Future RFPs shall be staggered based on availability of resources.the City will select a developer partner for each city-owned site with the intent to develop each site for 100% affordable housing. The developer would negotiate a ground lease with the City, process any necessary loans through the City’s local Housing Trust Fund, and concurrently process the Planning entitlements for the project through a ministerial process. The timeframe from selection of a developer to issuance of building permits typically takes approximately 24-30 months.
As has been done in the past, the City will use a variety of tools Tto facilitate 100% affordable housing development including but not limited to:
• Facilitate appropriate zoning and process to support 100% affordable housing • Substantially reduced or free ground rent, the City will • Providing funding through local housing trust fund
• Support applications for other funding sources for affordable housing (e.g. lowincome-housing tax credits, grants, State funding, Federal funding) • Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing Further, the City will continue to assess appropriate City-owned properties for the development of affordable housing…
An RFP to redevelop Parking Structure 3 located on the Third Street Promenade as affordable housing was issued in August 15, 2019 and a developer partner was selectedis currently pending review.
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Responsibility: Housing Division; City Planning Division; Economic Development Division
25. 28 & 140 Program 2.F: Include
goals, priorities,
metrics, and
milestones.
…. Local funding through the Housing Trust Fund will also help support the production of at least 1,880 affordable housing production units on City-owned/publicly owned land in accordance with Program 2E.
Santa Monica has been awarded a total of $10 million from the Local Housing Trust Fund (LHTF) program for the 2020 and 2021 funding rounds and is also eligible to receive an estimated $3.285 million from the first five years of the Permanent Local Housing Allocation (PLHA) entitlement program. The awarded State grants, as well as future State grants, are essential to Santa Monica’s ability to create affordable housing on City-owned land and further the goals of the City’s Housing Element.
Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing
26. 28 & 141 Program 2.G: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to utilize available financial resources and partnerships with service providers to create and retrofit existing housing for special needs households throughout the city with a target of 20 minor home repairs over the Housing Element cycle…
27. 29 & 143 Program 2.I: Commit
to revisions to
standards for
Emergency Shelters in
compliance with AB
139. Timing revision.
The City shall review and update the Zoning Ordinance and BAP, as applicable, to ensure consistency with State law as needed regarding special needs housing types and residential land use classifications as needed. Review and expected revisions will include, but are not limited to, updating parking requirements for Emergency Shelters pursuant to AB 139, the city’s definition of “household”, and land use requirements for Residential Care Facilities for seven or more persons to promote objectivity and approval certainty.
December 31, 2022 2023 and Annual Ongoing
28. 29 & 144 Program 3.A: Include
goals, priorities,
metrics, and
… and potentially expand upon the anti-displacement requirements of SB 330 to ensure that 100% of all protected units proposed to be demolished in order to construct a new housing development project are replaced.
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milestones. Timing
revision.
…the City shall amend the Zoning Ordinance to require that sites that currently have residential use, or within the past five years have had residential uses that have been vacated or demolished, that (1) are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income (approximately 1,150 deed-restricted affordable units within market-rate housing projects on private property), or (2) subject to any other form of rent or price control through a public entity's valid exercise of its police power (approximately 27,484 units)… SB 330 (effective 01/01/21 through 01/01/25) and SB 8 (extended SB330 through 01/01/30) enacted a program that establishes unit replacement requirements and tenant protections for new housing projects…
August 1, 2022June 30, 2023
29. 30 & 145 Program 3.B: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to implement programs throughout the city, including tenant and landlord education/outreach through workshops that are held twice as well as regular noticing of fair housing issues…
The City will also continue to work with community partners to keep the public aware of fair housing rights and obligations (along with the now much-needed rental assistance programs), and to use enforcement of our laws to help stop housing discrimination in Santa Monica whenever it appears. such as the Legal Aid Foundation of Los Angeles …the City has developed an Housing Aanti-discrimination Discrimination ordinance (Santa Monica Municipal Code chapter 4.28), which prohibits various types of housing discrimination—such as refusal to rent, differential treatment, discriminatory statements-- on the basis of disability, age, source of income, parenthood, pregnancy, or the potential or actual occupancy of a minor child. In 2015, as an affordable housing measure, the City added Source of Income as a protected class and then added an extra layer of protection with a pioneering definition for Source of Income. For the first time in Santa Monica and in California, the fair housing law expressly protected recipients of rental assistance such as Section 8. and
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Furthermore, City has launched a 2-year pilot Right to Counsel program…
30. 30 & 146 Program 3.C: Include
goals, priorities,
metrics, and
milestones.
… The City will continue to monitor over this Housing Element cycle the status of the approximately 770 affordable, deed-restricted at-risk projects units withinthroughout the City…
… the City shall continue to report annually on research and implement strategies on conserving non-covenant residential units such as the approximately 27,000484 rentcontrolled units and naturally occurring affordable units…
31. 30 & 147 Program 3.D:
Technical Revision
As resources are available, the City shall continue to provide loan assistance to nonprofit affordable housing providers and work with providers to identify new funding sources for acquisition and rehabilitation throughout the city.
32. 30 & 147 Program 3.E: Technical
Revision
The City shall support and fund the rehabilitation of 38 multi-family units and provide 20 minor home repairs throughout the city
33. 31 & 148 Program 3.F: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to respond to residential building code violation complaints throughout the city. Code Enforcement and Building and Safety Divisions will coordinate with the Housing and Human Services Division to provide information on available rehabilitation assistance to correct code deficiencies. The City shall continue to respond to residential substandard housing complaints that affect habitability (which are a Priority 1 complaint) within 1 day.
In the case of a residential building code violations that do not affect habitability, the City provides up to 30-days to correct the violation. If the work necessitates a building permit, the City provides up to 180 days to correct the violation (the life of the permit). In the case of substandard housing that affects habitability, the City requires the landlord to promptly commence the work to restore the unit(s) to a habitable condition and return tenants to their units through the Habitability Determination Form and Relocation Order and provide tenant protections (temporary relocation).
34. 31 & 149 Program 3.G: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to implement the Seismic Retrofit Program pursuant to the City’s Seismic Retrofit Ordinance. The City shall aim to issue building permits for seismic retrofit throughout the city of at least 900 buildings by the end of this Housing Element Cycle.
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35. 31 & 149 Program 3.H: Include
goals, priorities,
metrics, and
milestones.
Outreach will continue to include at least one annual seminar dedicated to providing information to rental property owners on rehabilitation and maintenance of properties.
Responsibility: Housing and Human Services Division, Rent Control Board
36. 150 Program 3.I: Included
past successes in
existing program.
Under the City’s pilot program and Los Angeles County’s parallel program, StayHousedLA, LAFLA has already helped 40 Santa Monica tenants facing eviction obtain full-scope legal representation. Another 42 have received limited scope services.
37. 31 & 150 Program 3.J: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to regulate condominium conversions pursuant to SMMC Section
9.24.040. The City will continue to track the City’s vacancy factor of rental units, and restrict conversions if vacancy factor is 5 percent or less of the total rental housing inventory.
Furthermore, the City will monitor removal of rental housing units from the rental housing market and provide annual data.
38. 32 & 152 Program 4.A: Include
goals, priorities,
metrics, and
milestones. Timing
revision.
… Land use regulations, FAR, and height (as indicated in Program 1.IJ) will be revised to allow housing in the three areas zones that currently do not allow housing… By August 1, 2022October 15, 2022
39. 32 & 153 Program 4.B: Technical
revision, timing
revision.
…Approximately fifteen seven parcels with religious congregations, which are classified in Santa Monica as community assembly uses,…
By August 1, 2022 June 30, 2023
40. 32 & 154 Program 4.C: Technical
revision, timing
revision.
The City shall establish programs to address historically exclusionary single-unit dwelling zones by encouraging and incentivizing the production of ADUs in single-unit residential districts in accordance with Program 4F.
by August 1, 2022June 30, 2023
41. 33 & 155 Program 4.D: Include
goals, priorities,
The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households.
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metrics, and
milestones.
The program will provide priority in City-funded affordable housing and inclusionary housing for up to 100 households or descendants of households.
42. 33 & 156 NEW Program 4.E: To
Affirmatively Further
Fair Housing
PROGRAM 4.E: PROVIDE NEW HOUSING CHOICES AND AFFORDABILITY IN HIGH OPPORTUNITY AREAS THROUGH INCENTIVES FOR SB9 UNITS IN R1-ZONE
NEIGHBORHOODS
The City shall adopt a local ordinance implementing SB9, which shall establish an administrative process without any discretionary action, and shall include strong incentives to densify larger parcels in R1-Zone neighborhoods by allowing property owners on parcels of at least 10,000 sf to add ADUs as allowed under State Law in addition to SB9 projects. This will open up the possibility for property owners to construct up to 6 units through a multistep process and create more housing choices and affordability in some of the most affluent areas of the city in accordance with Program 4F.
Program Background: Historic practices like redlining and restrictive covenants have perpetuated housing segregation and hindered fair access to housing. Although the City has been a leader in encouraging diverse neighborhoods through fair housing, rent control and tenant protections, predominantly homeowner neighborhoods have accommodated very little diversity in housing types reducing housing access for even middle-income households and a large percentage of Santa Monica workers. R1-zoned neighborhoods make up approximately 35% of the land area in the city but contain 13% of the housing units in the city. In comparison, commercial zoning comprises only 7% of the City’s land area but contains 15% of the housing units in the City.
SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, is a state bill that requires cities to allow one additional residential unit onto parcels zoned for single-unit dwellings. Allowing homeowners proposing SB9 projects to also construct ADUs, particularly on larger parcels, will increase new housing opportunities in high opportunity areas and also promote place-based strategies for community revitalization by increasing housing opportunities in all areas of Santa Monica.
• Timeframe: by June 30, 2023
• Responsibility: City Planning Division
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• Objective: Increase equitable access to all neighborhoods through small increases that may lower the barriers to housing access in high opportunity neighborhoods
43. 33 & 157 NEW Program 4.F: To
Affirmatively Further
Fair Housing
PROGRAM 4F: ESTABLISH TARGET TO INCREASE HOUSING PRODUCTION IN R1 ZONES
AND INCLUDE MID-CYCLE MONITORING
The City shall aim to issue at least 47 building permits per year for additional housing units and types in R1 zones. Review progress towards targets by December 31, 2025 and if targets are not being met, adjust land use strategies as necessary and appropriate within one year. • Timeframe: Assess progress by December 31, 2025
• Responsibility: City Planning Division
• Objective: Increase the number of net new housing units in R1 zones
44. 34 & 158 Program 5.B: Timing
revision
By December 31, 20232
45. 34 & 159 Program 6.A: Included
past successes in
existing program.
PROGRAM 6.A: ENHANCE HOUSING MOBILITY BY MAINTAINING RENTAL HOUSING
VOUCHER PROGRAMS THROUGHOUT THE CITY AND EXPAND TO ASSIST ALL PERSONS
WITH DISABILITIES
The City shall continue to operate strong rental housing voucher programs throughout the city and advocate for funding guidelines for Section 8 that are competitive for Santa Monica…
The Santa Monica Housing Authority (SMHA) administers two types of rental assistance vouchers, tenant-based and project-based, across five different federal housing programs:
Housing Choice Voucher (HCV); Continuum of Care (CoC); HOME Investment Partnerships Program (HOME); Veterans Affairs Supportive Housing (VASH), and Emergency Housing Voucher (EHV) programs. Tenant-based vouchers are allocated to specific individuals, which allow participants to choose where to lease rental housing, whereas project-based vouchers are allocated to specific properties rather than participants. In FY202120-2122, the Santa Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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Monica Housing Authority (SMHA) administered approximately 1,600 rental housing vouchers, including Section 8, Continuum of Care vouchers, HOME vouchers, and Veterans Affairs Supportive Housing (VASH) vouchers. The HOME program targets rent-burdened households at-risk of becoming homeless and persons who have been homeless for at least a year. Of the 772 vouchers that were used, voucher households reside throughout Santa Monica’s multifamily neighborhoods, with no concentration in one zip code. Five properties in Santa Monica representing senior and supportive affordable housing with significant allocations of project-based vouchers are located in zip codes 90401 (Downtown), 90403 (Wilshire-Montana/Northeast) and 90405 (Ocean Park/Sunset Park) representing a total of 340 affordable housing opportunities.
Distribution of Voucher Households 2017-2021 by Santa Monica Zip Code 90401 (Downtown)
Tenant-Based
Vouchers
Project-Based
Vouchers
Total Rental
Housing Vouchers
Count 154 155 309
Percentage 31% 57% 40%
90402 (North of Montana)
Count 2 0 2
Percentage 0% 0% 0%
90403 (Wilshire-Montana/Northeast)
Count 44 102 146
Percentage 9% 37% 19%
90404 (Mid-City/Pico)
Count 178 0 178
Percentage 36% 0% 23%
46. 34 & 160 Program 6.B: Include
goals, priorities,
metrics, and
milestones. Include
past successes in
existing program.
The City shall continue to pursue and identify new funding sources that support rental assistance programs, including emergency rental assistance for individuals and households at risk of displacement throughout the city with a goal to provide emergency rental assistance to at least 100 households throughout the city over the Housing Element cycle the extent feasible.
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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 Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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(CARES) and County General Funds. At the close of the program, 435 Santa Monica residents were awarded approximately $3.81 million in assistance through the County program.
47. 35 & 162 Program 6.C: Include
goals, priorities,
metrics, and
milestones. Include
past successes in
existing program.
Support measures that are not housing constraints to generate and allocate tax revenue for income assistance.
The City intends the POD Program to serve at least 150 participants within this Housing Element cycle.
In FY2020-21, the POD program served 196 low-income senior households providing an average monthly assistance of approximately $500 per month, allowing participants to age in place. Applications for POD are accepted both online and by mail, with assistance for those seeking a reasonable accommodation.
48. 35 & 162 Program 6.D: Include
goals, priorities,
metrics, and
milestones.
The City shall prioritize additional education and outreach to tenants and landlords throughout the city…
The City shall strengthen outreach and connect vulnerable residents with housing assistance and resources, including, but not limited to, credit counseling and support services addressing resident needs in securing adequate housing and hosting two educational events per year.
49. 35 & 164 Program 6.F: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to prioritize displaced residents on the City’s Below Market Housing waiting list in order to provide opportunities to identify comparable replacement housing within Santa Monica.
50. 35 & 164 Program 6.G: Include
goals, priorities,
metrics, and
milestones.
The City shall continue to require that all temporarily displaced tenants are relocated to comparable housing within Santa Monica, or close proximity, and that temporary relocation is for the amount of time necessary to restore habitability to the dwelling unit or if the landlord demonstrates that tenancy was legally terminated.
51. 36 & 166 Program 7.A: Include
goals, priorities,
metrics, and
milestones. Include
The City shall also conduct targeted outreach by hosting a Fair Housing Workshop to the general public twice a year that covers fair housing. The City shall also continue to provide and…
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past successes in
existing program.
Most of the cases are resolved informally, using demand letters, calls, and meetings to either to persuade the need for a change in what the landlord is doing or to conclude that there is insufficient evidence of a fair housing violation However, if there is sufficient evidence of ongoing fair housing violations and the landlord has refused to correct the problem, then the PRD often files a lawsuit in court to enforce the fair housing laws.
Since 2007, the PRD hosts a Fair Housing Workshop twice a year. The workshop covers several topics, including reasonable accommodations for tenants with disabilities, the City’s Right to Return program, pandemic-related issues in fair housing, and source-ofincome discrimination laws which protect Section 8 voucher-holders and users of rental assistance. All owners, property managers, attorneys, social-service providers, and tenants are invited to attend, free of charge. Over the years, hundreds of tenants and housing providers have attended.
The PRD’s workshops continued even through the pandemic, with a switch to virtual settings. The City has also made fair housing presentations to other local and regional groups. Just since April 2020, the City presented or even co-hosted housing rights events sponsored by Santa Monica Rent Control Board, the Legal Aid Foundation of Los Angeles, Western Center for Law & Poverty, Santa Monicans for Renters’ Rights, Fair Housing Council of San Diego, ACLU of Southern California, WISE & Healthy Aging, St. Joseph’s Center, and the Santa Monica Committee for Racial Justice.
52. 170 Quantified Objectives:
Technical Revision Household
Income
Category
RHNA % of Total Quantified
Objective % of Total
Very Low 2,794 31% 1,150116 2216%
Low 1,672 19% 572654 1110%
Moderate 1,702 19% 351479 7%
Above Moderate 2,727 31% 3,1804,459 6167%
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Total 8,895 5,2536,798
Source: City of Santa Monica Community Development Department The goal of 5,2536,798 units can be achieved based on current approved and pending projects,…
The quantified objective aims for 33% almost 50% of units produced to be affordable to low and moderate er income households.
53. 1721 POD Participant
Update: Technical
revision
The Preserving Our Diversity (POD) Program provides cash-based assistance to low-income, long-term Santa Monica residents in rent-controlled apartments to help achieve a “basic needs budget” for seniors. It is estimated to include at least 150 participants within the next housing cycle.
Income
Category
Rehabilitated Units Conservation Units
Definition
Multi-Family
Rehabilitation
Minor Home
Repairs
Acquisition &
Rehabilitation POD
Rental
Assistance
Vouchers
Right to
Counsel
Very Low 0-50% of County
MFI 19 10 40 150 1,600
0 Low 51 to 80% of
County MFI 19 10 0 0 0 210
Moderate 81 to 120% of
County MFI 0 0 0 0 0 0
Upper Over 120% of
County MFI 0 0 0 0 0 0
Totals 38 20 40 150 1,600 210
58 2,0001,900
54. E-26, 39 Appendix E: Technical
revision to definition
of permitted.
“P” = Permitted by right without discretionary action.
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Permitted means
without discretionary
action.
Therefore, supportive and transitional housing are both permitted uses without discretionary action within the City wherever and however single or multiple-unit dwellings are permitted…
Additionally, as shown in Figure E-10, Supportive Housing on its own is a permitted use without discretionary action in all multi-unit zones and commercial zones where multi-unit housing is a permitted use.
55. E-28 Appendix E: Technical
revision to update
ADU building permits
to current permits as
of May 2022. Aligned
with APR. Updated
map.
Since implementation of these new State laws, the City has seen an increase in ADU production and interest, averaging 56.5 ADUs per year between 2018 and 2021 each year.
Based on building permit data as of June 1, 2021, Figure E-12 and Map E-6 below summarize ADU development and location within the City since 2018 when State law began to focus on incentivizing ADUs.
Figure E-12 Santa Monica ADU Production
Building Permit Issuance
Year Permits Issued
2018 5423
2019 5160
2020 2741
2021 2102
TOTAL: 134226
56. E-33 Appendix E: Technical
revision to clarify that
emergency shelter
requirements will align
with AB 139.
Emergency shelter
capacity updated
Revisions will also include, but are not limited to, updated parking requirements for Emergency Shelters pursuant to AB 139.
According to the SSI, there are 11 10 parcels within the BTV and MUC zone districts of adequate size that can accommodate emergency shelters with no limitations on bed count and 178 118 parcels in the LT, NV, BC, TA, MUBL, MUB, and GC, NC, IC, and OC zone districts that limit emergency shelters to 55 bed per parcel. SFOf eExisting facilities accommodating an approximate range of 16-70 beds have oan average parcel size of 20,525 square feetXX, and of the 178128 SSI parcels, XX33 parcels would fall within this range SF, NV, BC, TA, Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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based on direction
from HCD.
MUBL, MUB, GC, BC, IC, and OC SF. Therefore, it can be concluded that the parcel sizes on the SSI can accommodate emergency shelters of at least 55 beds. In order to quantify the number of beds that can be established on sites with no bed count limit, a 160 square foot per bed size was applied based on both local analysis and County of Los Angeles standards .
As shown in Figure E-13, the City has capacity of 3,013 3,83811,823 emergency shelter beds. Therefore, Santa Monica has sufficient capacity to accommodate its emergency shelter need based on the 2020 point-in-time count of 907.
Figure E-13 Santa Monica Emergency Shelter Capacity
Zone
District
Number
of Parcels
Total Land Area (SF) Emergency Shelter
Bed Capacity
LT** 214 141,68943,996 770110
NV** 181 22,651183,480 99055
BC** 4 82,478 220
TA** 5 57,5820 275
MUBL** 5113 781,058467,399 2805715
MUB** 22929 499,449740,520273,121 15951210495
GC** 383 380,72981,457 2090165
NC** 14 92,5140 770
BTV* 1 38,54838,333 240240
MUC* 104 197,327287,036 1,7931233
IC** 1 19,662 55
OC** 4 26,117 220
Total: 3348189 2,590,3421,646,5691,124,283 11,8233,013838 * No limitation on bed count (160 SF per bed applied)
** 55 bed limit per parcel
57. E-45, 55 Appendix E: Technical
revision to clarify that
CUPs are not required
for typica MultipleUnit Dwelling projects.
Conditional Use Permits (CUPs) are not required for typical multiple-unit residential projects. CUPs are unusual for residential use classifications in the Zoning Code and a CUP for a residential use has not been requested in the past 10 years. Application fees, including CUPs, are based on cost recovery of services provided (i.e. staff time spent processing the permit), which typically requires significant analysis and development of conditions to mitigate potential impacts (e.g. noise, circulation, loading) on surrounding land uses.
As shown in Figure E-10, the only kinds of residential use classifications that very few residential land uses require approval of a Conditional Use Permit (CUP) are elderly and long-term care facilities and emergency shelters. Residential use classifications that require Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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approval of aor Minor User Permit (MUP) in some zones are group residential, residential care general, residential care senior, and hospice general. These uses are not typical multiple-unit residential uses in that they typically consist of shared living quarters and provide care for persons in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living.
58. F36 - 46 Appendix F: Expanded
AFFH analysis to
include number of
units by income group
in the SSI to show how
fair housing conditions
are addressed,
improved, or
exacerbated
Updated Step 8: Assessment of Sites to Affirmatively Furthering Fair Housing:
Included new maps comparing existing total housing units compared to units proposed under SSI, by census tract. The maps show where SSI units will go, broken down by affordability, in relation to existing housing and demographic patterns such as median income, racial predominance, and environmental health, among others.
59. F19-29 Appendix F: updated
to reflect the potential
for SSI properties to
develop with fewer
affordable units than
assumed in the
inventory. Also
accounts for the
potential of 100%
nonresidential uses.
Updated Step 5: Realistic Capacity Analysis of Suitable Sites:
The element now includes a probability factor for non-residential uses in the capacity analysis in the SSI. Specifically, capacity of sites now reflects an across the board 15% reduction in housing capacity based on past trends. Added a table showing typical densities of past housing projects.
60. F1-18 Appendix F: updated
to include analysis on
the extent that
existing uses impede
additional
development
Updated both Introduction and Step 4: Evaluating Suitability of Nonvacant Sites for Housing Potential
Included a new column in the SSI table identifying the factors (age of building, improvements to land ratio, tenancy, etc) used to select a site. Analysis includes a new flow chart to illustrate the methodology. New table shows how factors are weighted to identify SSI sites. In addition, Attachment 1 to the report now includes a table that supports the use of the factors based on a review of past and approved projects Attachment B – Summary of Draft Redlines Revisions in Response to HCD Comments Housing Element 2021- 2029
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61. F30-32 Appendix F: updated
to describe the trends
of past development
on small sites and lot
consolidation.
Updated Step 7: Summary of Capacity to Accommodate the RHNA:
Added an explanation of Santa Monica’s past history of small site consolidation and that lot tie agreements are approved administratively. Additionally updated the Shortfall Analysis and Rezoning Capacity Analysis to account for approved and pending projects. The Rezoning Capacity Analysis has also been updated to account for revised ADU projections and proposed floor area ratios and heights.
62. F69-71 Appendix F: Updated
to demonstrate
existing and planned
total infrastructure
sewer capacity to
accommodate RHNA.
Updated Section 2: Infrastructure Constraints
Preamble language to affirm that there is sufficient capacity to accommodate the RHNA.
63. F-74 SSI Table Revised to account for approved and pending projects and addition/removal of sites based on updated information. Total number of sites is now 344.