potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, while the element includes Program 2.I to amend zoning for a variety of housing types, the Program should include specific commitment to amend zoning for identified constraints related to the definition of households…” Identification of Reasonable Accommodations and updated requirements for new projects A. Reasonable accommodations are not currently part of the review process and approval of new construction. Inclusion of Housing and Urban Development full array of specifications of accommodations for disability is desperately needed.
B. Input from: Management of “successful” affordable housing such as the Belmar to learn what works and what are serious shortfalls in current plan approval.
C. Input from community organizations who work with needs of disabled and aging:
Disability Community Resource Center, People’s Concern, and WISE and Healthy Aging. Community Corporation Santa Monica Resident Council.
D. Change codes so developers include HUD accessibility standards prior to new construction.
E. Include disabled and low-income people in architectural plan-approval: people who already live in affordable housing know what works and what does not work.
Governmental Constraints and Institutional Discrimination:
A. Off-site affordable housing construction to meet the 20% requirement is systemic discrimination.
B. HUD allows low income to participate in home ownership programs with a section 8 voucher. Currently the City is discriminating against voucher holders on basis of income source for their home-ownership program.
C. Specific City Constraints: one current example is the development of Mountain View mobile home park--restricted to specific brand factory units. No options are given for units made of materials that would make the housing accessible for people with
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Packet Pg. 1500 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Housing Commission Member Discussion Items, Comments on HCD and FHA 2 of 3
respiratory and other disability triggered by vinyl and plastic building materials.
Sustainable building materials options are not given. Size of unit limitation discriminates against family size. Insufficient parking for families with two cars.
New Program Ideas:
A. Include 20%+ affordable townhomes for purchase in townhouse projects.
B. Provide Co-Housing opportunities, zoning permits, financial support, and education C. Create Zoning permits for Tiny home single person housing on small lots subdivided for home-ownership: this is successfully being done in LA County and LA City.
3. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding A1, the element requires a complete analysis of AFFH. Depending upon the results of that analysis, the City may need to revise or add programs to affirmatively further fair housing. In addition, HCD’s prior review found the City should revise Program 4.D (Rezoning R1 Neighborhoods) with meaningful and sufficient actions to overcome patterns of segregation and foster inclusive communities. In response, the element now appears to only promote accessory dwelling units; an insufficient action given the perpetuated segregation noted in the element. Please see HCD’s prior review Ideas regarding Existing Santa Monica policies that perpetuate segregation in Housing Element:
1. Currently Developers are allowed to build buildings and put the affordable income-based apartments off-site. This loophole is the very definition of FHA segregation. The off-site buildings are in inferior locations, inferior/inadequate amenities (parking, storage, space), inferior construction (vinyl, particleboard, laminate). They are largely built near freeways and rarely are cross-ventilated and thus not accessible for medical reasons for many disabled people. Developments (apartments AND townhomes) that do not include affordable units on-site fail to meet Fair Housing requirements.
2. When developers submit their plans, mandate that they show an overview of the WHOLE city and how the building fits in, and include a color-coded key that shows housing density throughout the city so that people can easily see how the proposed development meets or does not meet the density and diversification goals of the City.
3. Do 100% affordable projects discriminate and enforce segregated communities?
4. Raise the percentage of units designated affordable. Consider raising it to 33% and not grandfathering in any developments in progress.
5. Raise percentage of affordable units in existing buildings with persistent vacancies.
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Packet Pg. 1501 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Housing Commission Member Discussion Items, Comments on HCD and FHA 3 of 3
6. Tax penalties for buildings with persistent high vacancy rate due to rents not affordable to people --Stop allowing vacancies to be a tax write-off for developers-set an annual vacancy limit.
7. Change the basic qualifications to include a list of HUD defined accommodations needed for disability---current SMHA waitlists do NOT include accommodation specifications per HUD and are income based, not rent-ability based. People with section 8 vouchers who can pay market rate with their vouchers are discriminated against on basis of income—a violation of the Fair Housing Act. Specific needs are not acknowledged by developers, SMHA, nor the Housing Commission.
8. Include a density factor and amend zoning. Consider air quality in housing as part of the density zoning change: recent construction created rows of buildings with small apartments along major roads and freeways. Other major cities use the freeway adjacent land as accessible open parkland.
9. Include parks and open spaces in neighborhoods with people living in high density housing. Currently the City is using open spaces to build more high-density prison-like building--further segregating and lessening the quality of life for working people in affordable housing.
10. Include more disabled and low-income people on established Santa Monica City committees that approve these projects at all stages.
11. Report on what actually works and does not work in current mixed-use housing and affordable housing. People already living in this kind of housing can report what they have to say. DO NOT have a Santa Monica City Survey go out. These surveys are heavily biased and do not ask the salient questions needed to address Fair Housing issues.
12. Include analysis from The People Concern on transitional housing needs.
13. Include analysis from Wise and Healthy Aging and Disability Community Resource Center on housing needs for disabled aging people. Include description of multiple disability issues that need to be addressed in housing in order to comply with ADA and FHA accessibility.
14. Look at other cities globally that are successfully planning and building inclusive cities.
Thank you for your consideration,
Elizabeth Lutz Ph.D.
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Packet Pg. 1502 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Monday, June 20, 2022 3:59 PM
To: Jing Yeo
Subject: FW: 06/21/22 Santa Monica City council meeting; Comment on item 8B, Housing Element
Attachments: SocialHousingAuthority.TieiraRyder.4-25-22.pdf
EXTERNAL
FYI
From: HowTheWest Was Saved <[email protected]>
Sent: Monday, June 20, 2022 3:43 PM
To: [email protected]
Subject: 06/21/22 Santa Monica City council meeting; Comment on item 8B, Housing Element Hello,
We are asking HCD to support a county-led social housing team that is overseen by actual progressive housing advocates. Not much has changed in Santa Monica City's housing element and as a collective, we will NEVER get out of the housing crisis if we do not begin implementing a solid social housing policy across the entire U.S. Build more privately owned market-rate housing but residents cannot rely on a market that has proven unreliable!
The source has already granted us all permission to live on Earth.
Residents of varying "racial" & class backgrounds do not require the permission of another human to live anywhere on Earth. We must build housing in well-built communities that are walkable, bikefriendly, and affordable! The incorrectly zoned Santa Monica airport & penmar golf course MUST close in this housing cycle so that we can begin building housing surrounded by a large park! HCD, local residents are asking for your support in capturing PUBLIC land to be used for PUBLIC good. Localities that have been
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Packet Pg. 1503 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 intentionally segregated by race & class cannot be expected to do the right thing.
https://htwws.org/social-housing-ca/ [htwws.org]
‐‐
Best,
Tieira
https://htwws.org/santamonicaairport/ [htwws.org]
https://youtu.be/WSFf00y-0uA [youtu.be]
Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
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Packet Pg. 1504 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) REPEAL ARTICLE 34 in the CA state constitution; USE public land for PUBLIC GOOD, end systematic housing violence & displacement. Article 34 of the CA constitution reads; “No low rent housing project shall hereafter be developed, constructed, or acquired in any manner by any state public body until, a majority of the qualified electors of the city, town or county, as the case may be..”
Localities that have been abusing their positions and segregating cities by race & class should not decide what happens to public land. Workers that commute into cities also have the right to decide what happens to public land, retirees, college students, and many others also have that right!
“Heidi Marston resigns from LASHA, citing difficulties in fulfilling LAHSA's mission without "fundamental shifts". In her resignation letter, Marston elaborates:
"Power and funding alone control homelessness. But in our current system, organizations like the one I lead, the Los Angeles Homeless Services Authority (LAHSA), are not given control over regulatory or policy decisions, service providers remain underfunded, and dedicated front-line employees of non-profit organizations and government entities are hamstrung by rules, red tape, and bureaucracy. Marston also points to low wages, high rents, restrictive zoning laws, and other "shadow monsters'' we must tackle in order to end homelessness." https://medium.com/@hmarston2/the-homelessness-crisis-a-monster-of-our-own-maki ng-be5975399ce1
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Packet Pg. 1505 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Structural Governance of the Social Housing Authority
The State Housing Authority - HCD will oversee
The Social Housing Authority; Community-led development of PS, affordable, & market-rate housing: Social Housing Agencies in each county in CA (ONE SOCIAL HOUSING AGENCY with selected progressive civil peers (community advocates) assigned to offices in each part of the county (likely NSEW & Mid-City, TBD); a group of progressive housing civil peers that implements & develops new community-owned affordable, market-rate, and PS rental housing on publicly owned land throughout LA County. Communities are well put together, mostly in walkable, pedestrian/bike-friendly built communities. The agency as a collective whole will capture vacancy numbers (parking lots, buildings (privately & publicly owned), to determine ownership/best use for vacant spaces.
The Social Housing Authority will override city councils in localities to partner directly with County BOS, and HCD to collect funding meant for homeless/housing 2 11.A.h
Packet Pg. 1506 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) spending, money goes into ONE TRUST account that must provide RECEIPTS of where/how much money is spent on specific projects.
Agency works with HUD to implement new guidelines for affordable homeownership for the blue-collar working class. Agency maintains ONE website/database that has a list of AVAILABLE community-owned affordable, market-rate, and PS rental housing. List of AVAILABLE affordable & market-rate homeownership opportunities.
Affordable housing waitlist for rental housing should be no longer than 6 months, 6 months is actually too long but should not exceed that. The social housing agency is focused on public safety, public safety means safety from heavy traffic violence and climate arson. This means the social housing team works to build communities that are walkable, bike, and pedestrian-friendly. Communities that have access to green space.
Communities that aren’t being heavily polluted by LAPD helicopter pilots (noise & fuel pollution linked to dementia, linked to cancer). Cars belong on the outside of multi-family communities, not within. Cars are occupying too much land space! Humans need land to live on, we shouldn’t NEED to drive everywhere. Create when possible 15-20 minute cities/small communities.
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Packet Pg. 1507 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Social Agency is primarily focused on the development of community-owned housing. However, the agency will be divided into 3 primary teams; PSH, affordable & market-rate rentals, affordable & market-rate homeownership; Permanent Supportive Housing- PSH for residents in need of wraparound services. Services could be needed short or long-term depending on the person.
This team is focused on securing housing for residents with low-to-no income, chronically homeless, FOSTER youth (up to age 24), disabilities etc. This team doesn’t provide the services it connects other agencies & non-profits to PS housing.
This team maintains a database of PSH units that are available and works to revamp/remodel the broken shelter housing system to turn them into PSH.
Again, ONE social service housing website for residents with varying needs.
Foster Youth: safe and clean group homes that provide guidance & structure to youth/young adults up to the age of 24.
REVAMP the broken Foster System; guidance comes from social workers that are based out of the revamped DPSS, non-profits, grassroots teams, etc.).
PSH shouldn’t feel carceral (jail-prison like).
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Packet Pg. 1508 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Supportive services are wraparound services in QUALITY family planning, STI/STD prevention/protection, mental, behavioral, & rehabilitation healthcare, etc, etc.
Introduce UBI, money that should come from another trust account will not come from the housing trust fund. UBI for foster youth, and adult residents not working or below the poverty line. UBI up to $1000 a month for completed work/ treatment assignments.
For displaced youth; completed schooling/work/etc. Standard UBI (no work /treatment assignments required) $300-$500.
Repeating; services are provided by A REVAMPED DPSS, by grassroots and non-profit teams, etc. Agency will provide a civil peer court system; will also be for any potential cases of alleged abuse happening from workers but all workers must have ongoing training, schooling, and teachings in proper behavior when interacting with residents in PSH communities, especially foster youth! Service teams should meet every few months to go over what is and what is not working, the social housing agency does not provide the service, they are simply making available the housing needed for the residents in need of PSH, possibly in need of long term care, healing, community.
The PSH Social Housing Team works with the DPSS to secure safe parking/dwelling zones within the county until PSH becomes available. All non-profit groups/service teams need to be an extension of this department (LASHA, DPSS, Grassroot teams, etc., etc.) Service teams should be able to contact PSH social agency team to find PSH, Safe parking/dwelling, and/or to receive money for temporary hotel/room stays (FEMA MONEY should be used as the ONE trust account is mostly for development/maintenance/admin of community-owned housing. ONE TRUST per county social agency/authority).
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Packet Pg. 1509 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-Owned affordable & market-rate Housing; residents are self-sufficient, can pass a criminal background check likely just need assistance securing an affordable or market-rate unit. Will work with residents with a prior eviction. Community-owned affordable & market-rate rental housing that is always affordable. Rent shouldn’t take more than 20-30% of a resident's total income after taxes. Establish an affordable rental market-rate price for the blue-collar working class. The affordable price should not be averaged with working-class/high income earners included in the calculation. Most workers, most jobs in LA County pay about $40,000. What is the average wage for the blue-collar worker??? Community-owned, market-rate units will likely be much cheaper than privately owned market-rate.
All local city affordable housing authorities would be moved into the social agency/demolished. There are too many moving parts of the housing programs/processes. We need ONE coordinated system with FUNCTIONING non-profits, social service teams an extension of the one agency. Social workers, field workers, and rehousing specialists should be able to utilize the agency/website to secure at a minimum safe parking/safe dwelling. Should be able to give food vouchers/stamps, etc. to those that need them.
Again, the housing team is likely divided by local cities in the county, likely by NSEW & mid-city, TBD. Each of those divided teams will be divided into the 3 groups of; PSH, affordable & market-rate rentals, affordable & market-rate homeownership) Public Safety- A civil peer board of housing (court) will be established to hear cases about any potential threats to public safety happening in Socially owned housing. The court will also hear about allegations of any abuse happening within the system and 6 11.A.h
Packet Pg. 1510 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) correct the action. PSA on appropriate behavior will be provided to all residents/staff that are part of the social housing community.
The goal of the Social Housing agency is to prevent displacement but they will support “JUST-CAUSE” eviction for tenants posing a risk/threat to other tenants. No gang activity or violence WILL be tolerated, the community has a right to safety, if that safety is ever threatened, residents in the community have the right to evict! Some PSH will be for residents in transition from jail/prison back into community living. Prevent ROOT CAUSE of problems that we are seeing in our community. Also, consider communities for disabled residents/ residents with special needs that may need long-term wraparound services. Consider partnership with community colleges for affordable housing for students/young adults up to age 24-25. Consider committed behavioral, mental, and rehabilitation health programs for residents with outstanding issues in above mentioned. Any committed programs should still be a place of healing, not further violence and trauma. Dismantle and rebuild existing programs in that area.
Fix the problems at the ROOT, save the next generation and again, ongoing training, and schooling, for workers in this field. HIGHER pay for workers in these fields! 7 11.A.h
Packet Pg. 1511 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) The private housing market can always exist if it likes but residents shouldn't be forced to rely on it. There are residents whose families have been dealing with generational housing violence as it relates to race & class, they cannot rely on a privately owned market that has no accountability! Rent has gone up by over 65% within the last 10 years in LA County with no rebuttal for the blue-collar working class, retirees, residents of generational housing violence and displacement, college students, foster youth, and many many others. 8 11.A.h
Packet Pg. 1512 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) 9 11.A.h
Packet Pg. 1513 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) This social agency will have nothing to do with private housing developments but it can purchase private housing and it can assist with securing housing for residents in privately owned housing. The Social Agency will maintain a website of AVAILABLE community-owned affordable, market-rate, and PS rental housing units. Privately owned units can also be listed. <<< WATCH CYBER FRAUD/SCAMS which is rampant on apartment rental websites.
The social agency is being created to develop and implement new housing developments on vacant publicly owned land and remodels for publicly owned vacant buildings. The agency cannot deny community-owned housing developments in any neighborhood in LA County, they are a county-wide team that implements new developments of community-owned PS, affordable, and market-rate housing in ALL CITIES in the county, this includes SANTA MONICA, BEVERLY HILLS,
WEST HOLLYWOOD, MARINA DEL REY, PASADENA, DOWNEY, LONG
BEACH, etc., etc., etc., ALL CITIES IN LA COUNTY! The intentional segregation as it relates to race & class MUST end, THE NIMBY violence MUST END!
For community-owned affordable & market-rate housing, long-term residents of LA County should get priority with housing placements, focusing on getting workers closer to their jobs. It is imperative for the health of humans, the health of the Earth, and other species that we reduce drive times, and reduce pollution. Preventing displacement is IMPERATIVE. The team can prevent displacement by subsidizing rent for tenants in privately owned units and/or helping move them to community-owned affordable housing.
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Packet Pg. 1514 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Affordable homeownership- full proposal coming soon, introduce co-ops, CLT’s, and resell requirements. The primary focus is blue-collar workers (affordable with resell requirements) and market-rate housing. Use money from market-rate sales to place into the ONE trust account. Insert grassroots team to help with restorative justice aspects of homeownership for residents impacted by systematic racial violence.
How do you think this story is going to end?????????
Short-term rentals- introduce tourism short-term stays, money goes into the ONE trust account.
Trust Account- One trust account that will be audited by city/state controllers. Money comes from HUD, Feds, State, Donations, & HHH. The annual state surplus budget must donate a portion into trust every year. The tourism industry should be donating a portion of total earnings into the trust. The cannabis industry should be donating a portion of money into the trust, should be redirecting money to communities impacted by the “pretend war on drugs” created by the U.S Gov’t. A small portion is for admin/resident manager fees (try to avoid outsourcing resident management to other companies, which could run up costs). The largest portion of the trust is for housing development/property maintenance.) How much are CA taxpayers giving in federal dollars to other states using the money for social services (TBD). 11 11.A.h
Packet Pg. 1515 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-owned housing cannot be sold to corporations. If TOPA is introduced, keep under CLT (land lease) to allow tenants to purchase their units but prevent corporations from being able to purchase***??? (verify). Also, any money given to nonprofits to build affordable housing should mean that that housing cannot be sold to a corporation. How and why are some non-profits that received Gov’t/Taxpayer money able to sell affordable buildings after a set number of years to private corporations? Housing would go back to the social agency OR TOPA if the non-profit wanted to be released from oversight/responsibility. The Social Agency can buy privately owned property and resell it to private owners/corporations but NOT publicly owned land/housing, not rent nor ownership. Again, community-owned developments are going to be built with the community in mind, with green space, stores, hospitals, etc., sometimes worked/developed within the communities.
Social Housing Plans ready for implementation;
https://htwws.org/santamonicaairport/
(Author notes, not part of the proposal)
-Examine the years that ADOS (American descendants of Survivors paid federal taxes but were not able to utilize public service. Examine displacement and communities that were intentionally burned t the ground by supremacists. Request reimbursement/hold percent of federal/state taxes to heal communities.
-Tenancy in common is a form of co-ownership of property in which each party owns an undivided interest that passes to his or her heirs at death. The interest is undivided 12 11.A.h
Packet Pg. 1516 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) because each tenant has rights in the whole property. Although ownership is in common, tenants may have equal or unequal shares.
-Joint tenancy is the joint ownership of property by two or more co-owners in which each co-owner owns an undivided portion of the property. On the death of one of the joint tenants, their interest is automatically passed to surviving tenants. -Real property- immovable property, a building, land, plants etc, (though buildings can actually be moved depending on).
-Just cause eviction in CLT - Community members causing violence when corrective action cannot be taken, not working. Racial violence & other forms of discrimination.
Peer court will recommend rehabilitation programs when permitted to do so, severe cases could result in immediate evictions.
-Land on Earth belongs to all of humanity.
-Land has not been fairly distributed to residents impacted by systematic housing violence as it relates to race & class.
-The aim of the Surplus Land Act (the "Act"); is to increase the availability of real property in California for affordable housing development by requiring the prioritization of affordable housing when selling or leasing public lands no longer necessary for agency use.
-"Feb. 5, 1866: Thaddeus Stevens Proposes Land Distribution Amendment" https://www.zinnedproject.org/news/tdih/thaddeus-stevens-freedmens-bill/ 13 11.A.h
Packet Pg. 1517 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -Foster City- examine the broken foster system, keeping families together whenever possible, family planning services, safe housing & family for youth that are not able to stay with their biological families.
To do;
-Write the state bar and include them on your housing emails. REQUIRE that the state bar authorize civil peers to oversee legal issues related to housing (LLP’s). -BLM the org must redirect funding into one trust that is overseen by a group of Black civil peers. Push money back into Black communities as direct UBI payment, as housing payments, treatment payments, crime & gang prevention, etc., etc. -Email OMBW/Watch for grants (GS)
-Civilian Eminent Domain of Public Land; communities protected from Climate arson; Free market exists for those that want to be part of it. -Establish Public Bank
-A PORTION of public land MUST remain PUBLICLY owned for use by the community.
-Agency divided into NSEW & Mid-City?!?! Civil Peer teams in NSEW & Mid-City ?? -If the BOS goes ROUGE, the social agency will partner with the state housing authority directly and override county BOS should they become non-compliant. 14 11.A.h
Packet Pg. 1518 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -representcal.org, why a constitutional convention is necessary, and how the CA constitution allows localities to abuse their position, allows illegal segregation as it relates to race & class.
-Examine pre-built tiny home/ADU placements in well put together communities that are affordable & supportive. Sheds are not tiny homes. Some residents already own tiny homes or they want to, can support themselves but need land. Communities likely could be supported in the valley.
15 11.A.h
Packet Pg. 1519 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Tuesday, June 28, 2022 1:32 PM
To: Jing Yeo
Subject: FW: Current Draft Housing Element Santa Monica Attachments: Systemic discrimination in the SMHA practices and the proposed housing element.docx
EXTERNAL
FYI
From: Elizabeth Lutz <[email protected]>
Sent: Tuesday, June 28, 2022 1:26 PM
To: McDougall, Paul@HCD <[email protected]>
Subject: Current Draft Housing Element Santa Monica
Dear Mr. McDougall,
The Planning Commission of the City of Santa Monica has finished their current Housing Element Draft although it is not accepting comments. I am forwarding limited comments regarding the FHA and ADA systemic biases and practices in the City as pertain to this draft.
I am sending this after reading the Housing elements of other Cities in Coastal California and I see we can do much much better at addressing discrimination. Additionally, the housing element is misleading in some respects and I seek to clarify as a disabled resident of the City.
My expertise is only FHA and ADA, and I have limited my comments to a few examples where change is purported however where actually the Housing element and City practices perpetuate systemic issues.
Thank you for your work and your consideration for the issues in my City.
Elizabeth Lutz
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Packet Pg. 1520 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) June 28, 2022 Santa Monica Updated Draft Housing Element Comments ADA and FHA systemic discrimination and misrepresentations in the proposed housing element:
Systemic contradictions and discrimination:
This housing element describes as “high priority” properties for disabled with mobility, sight and hearing disabilities. This is discrimination against the disabled and a bias towards particular disabilities. In the index of the FHA chapter the housing element proports to update its definition of disability to one recognized by the federal government ADA and FHA, however in practice this housing element privileges particular disabilities. Someone with MCS or severe respiratory illness triggered by car exhaust, dumpsters, environmental factors caused by businesses or cheap building materials used in off-site affordable housing are left without accessible housing. New projects approved by the city do not provide oversite that the deed-restricted units are of the same quality as market-rate units. “Unseen” disabilities continue to be invisible to policy makers at the City level, although HUD specifically describes accommodation for people with environmental illness and disability.
The answer to most FHA issues in the Housing Element is to hire an ADA specialist. Even if the ADA specialist is hired – they still have to go along with the systemic discriminatory practices and rules embedded in this housing element. The hands of the ADA specialist will be tied—whose interests will they serve? What power can an independent administrator have in this troubled City government? Every department needs to take responsibility to update their practices ADA compliant. Every department needs an ADA administrator.
There are many descriptions of supportive services and groups available for the disabled in Santa Monica in this document. Although there were supports including counseling and support groups available historically, the funding was removed several years ago. A disabled person under age 65 has virtually no disability services in the City of Santa Monica, other than a subsidized Lyft ride program (75$ credit which at current Lyft costs equals approximately three round trip rides in a month). There are disability organizations, however they are not included in policy formation in the City on any level.
The proposed housing element describes the need for flexibility in family composition and, for example, cites the need for two-bedroom apartments for a disabled person and their aide. HUD supports this composition; however, the Santa Monic Housing Authority prohibits a second bedroom for an aide under any circumstances. A disabled person may have a dedicated sick room bedroom if medically required and the aid lives in the living/dining/kitchen area. The housing element describes a two-bedroom unit available for diversity of household composition of two non-related adults and the SMHA disallows this—The proposed housing element conflicts with SMHA practices and creates discrimination on the basis of source of income and discrimination of disabled.
Every housing authority on the California coast including high-cost real estate and density areas of:
Marin, Santa Cruz, Long Beach, and Orange Counties has a housing element that aligns with the spirit of the FHA regulations—Not Santa Monica. These other comparable cities and counties allow a bedroom for a live-in-aide AND also have a Home-ownership program or a home-ownership program as an accommodation to a disability in place. When speaking the Santa Cruz office, they said providing a bedroom for a live-in aide is the LAW under HUD rules. Santa Monica Housing Authority chooses to interpret this differently. The other housing authorities comply with HUD home-ownership options. This option may not be used often, however this is a choice encouraged by HUD, and, like denying a bedroom for an aide, the SMHA does not allow this possibility. This narrow interpretation has a subtle
11.A.h
Packet Pg. 1521 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) June 28, 2022 Santa Monica Updated Draft Housing Element Comments segregation and discriminatory bias against the disabled who use the section 8 voucher. Imagine an aide living in your living room? This restriction on space, and ownership impacts what is produced by builders. They build the minimum size rooms and units to be HUD compliant. If the City required a higher ratio of multi-bedroom units based on the needs of the disabled and elderly non-family occupants then a systemic discrimination would be resolved.
Our housing element does not open the potential for condominiums, co-housing, home-ownership supported by HUD and other ways citizens can own their property. The neglect of sustainable housing options in favor of corporate construction of apartment towers with off-site affordable housing ghetto buildings is by definition segregationist. It is not addressed in this Housing Element. What it the remaining City owned property was utilized for condominiums? The housing element could set a goal of much higher percentage deed restricted –as these apartments are the new rent-controlled apartments. The housing element could set a goal that a large percentage of housing be condominiums and deed restricted—without this goal in sight—the corporate-model housing supported by the element is a model that is a systemic discrimination against ALL residents of Santa Monica on the basis of funding access.
The much-touted ADU program in the R1 zones of Santa Monica--these are not under rent control or deed-restriction. Who will have the opportunity to rent these units? Section 8 recipients? Are these units first offered to disabled or elderly residents as Reasonable Accommodation units? No. The inducements for property owners to build these income-producing units for unrestricted use and tax benefits is systemic discrimination against renters and systemic payoffs and benefits given to wealthy.
This current draft of the housing element for Santa Monica does not address the systemic discrimination that the State’s February letter described. This report is a wish list of goals without any change of the institutionalized discrimination that is clouding the vision and potential for this community.
Thank you,
Elizabeth Lutz Ph.D.
Disability and Elder Advocate
Santa Monica, CA
11.A.h
Packet Pg. 1522 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Monday, July 11, 2022 8:49 AM
To: Jing Yeo
Subject: FW: Santa Monica possible affordable housing action Attachments: Letter to Council.pdf
EXTERNAL
FYI
From: Buettner, John@HCD <[email protected]>
Sent: Monday, July 11, 2022 7:41 AM
To: McDougall, Paul@HCD <[email protected]>; Housing Elements@HCD <[email protected]> Subject: FW: Santa Monica possible affordable housing action See attached. Thanks
From: Kevin McKeown <[email protected]>
Sent: Sunday, July 10, 2022 5:24 PM
To: Buettner, John@HCD <[email protected]>
Subject: Santa Monica possible affordable housing action I believe it’s important HCD be aware of this. My letter to members of the Santa Monica City Council, a public document, is attached.
Thanks,
Kevin McKeown
Most immediate past Mayor (retired)
City of Santa Monica
————————————
K e v I n M c K e o w n
https://urldefense.com/v3/__http://www.mckeown.net__;!!KIquKgc!f6s3rbom3pIpw409w92QozkhidptF3KffpALJeHMO _LEdrWesY4cVZaGGPV‐ecK5661pJWy‐QIPuI33RH1cdew$
Phone (310) 393‐3639
“Choose to be conscious”
————————————
11.A.h
Packet Pg. 1523 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) July 12, 2022 Item 11-A — OPPOSE
Councilmembers, item 11-A on your agenda tonight risks severe consequences for betraying on-record assurances made in the Housing Element submitted to the California Department of Housing and Community Development by your own vote just three weeks ago.
Those assurances, which I shall detail, commit our City to support measures that would generate and allocate tax revenues for deed-restricted affordable housing, and for housing stability assistance for distressed renters, such as our pioneering P.O.D. (Preserve Our Diversity) program.
Over the past months, over 10,000 Santa Monica residents signed petitions to successfully qualify a November ballot measure that would specifically fulfill the Council’s Housing Element policy assurances. The language of that voter-supported initiative directly commits generated transfer-tax revenue to, as described in the City Attorney’s Ballot Title and Summary, “…provide ongoing or emergency income assistance, acquire and rehabilitate existing rental properties as deed-restricted affordable housing, create new deed-restricted housing, and fund programs and services designed to preserve and improve affordable housing for lower income households.”
At a budget session in late May, Councilmember Brock proposed a competing measure, which is before you tonight, requesting your affirmative vote to place it on the November ballot. It targets similar transfer-tax revenue to be used for different purposes, and was deliberately crafted with a “poison pill” that would thwart the resident-powered initiative to fulfill Housing Element policy promises.
There can be no doubt of that hostile intent, as a few days later Councilmember Brock posted on Twitter,
Further, on June 1st, Councilmember Brock released via Facebook a “public letter” explaining why he wants to quash the affordable-housing measure. In that Facebook post he says that previous affordable-housing tax allocations have been very generous, and, “I'm in full support of these measures but do not believe the City's taxpayers should be asked to provide millions of dollars for new affordable housing in lieu of addressing issues of much more pressing concern to our residents.” The underlying intent of the proposed ballot measure you will consider tonight is, then, well documented. Its primary proponent himself has made clear that his proposal was deliberately designed to thwart the resident-generated affordable-housing ballot measure, and thereby contradict the Housing Element policy assurances submitted to HCD by the Council.
11.A.h
Packet Pg. 1524 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) As a reminder, those assurances include the following Housing Element policies:
Program 2.E (Commit To The Production Of Affordable Housing On City-Owned/Publicly-Owned Land): "Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed restricted affordable housing.” Program 2.F (New Affordable Housing Finance Programs To Enable Continued Provision Of Technical And Financial Assistance For Housing Production). "Support measures that are not housing constraints to generate and allocate tax revenue for the acquisition and development of deed-restricted affordable housing.”
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.”
Program 6.C (Maintain And Expand The Preserving Our Diversity (POD) Program). "Support measures that are not housing constraints to generate and allocate tax revenue for income assistance."
Besides the conflict the Brock measure creates with the above programs you chose and voted to include in Santa Monica’s Housing Element, an action to oppose affordable housing funding and production is inherently inconsistent with our Regional Housing Need Assessment (RHNA) mandate and with the very reason cities are required to submit compliant Housing Elements.
The consequences of an unwise “yes” vote to put the proposed affordability-killer measure on the ballot are gruesomely clear. The “poison pill” provision means the resident-generated affordable-housing measure cannot go into effect if this competing measure (with an enticingly lower tax levy) gets just one vote more, even if both exceed the 50% needed to pass.
Lacking the funding needed to support distressed renters, Santa Monica will see displacement of lower-income residents and a continuing crisis in housing affordability.
Tens of millions of dollars for subsidizing deed-restricted affordable housing will be lost, along with the opportunity to leverage that money with grants and tax credits. Our City will therefore almost certainly fail to meet state affordable-housing requirements.
The Council’s willful pre-emption of the resident-powered ballot initiative to use transfer taxes for housing affordability would likely be seen by state observers as a demonstration of bad faith with respect to the Housing Element you voted to submit three weeks ago. That could goad California housing officials into greater intervention against our local zoning, perhaps even choosing to make an example of us.
Is that what we want?
It all hangs on your vote tonight.
Please vote NO on item 11-A.
Kevin McKeown, former Mayor
Cc: California Department of Housing and Community Development
11.A.h
Packet Pg. 1525 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Thursday, July 14, 2022 1:43 PM
To: Jing Yeo
Subject: FW: Public Comments on Santa Monica Housing Element Attachments: 2022-07-13 - Santa Monica Housing Element Comment Letter - AHLA & YIMBY Law.pdf
EXTERNAL
FYI
From: David Barboza <[email protected]>
Sent: Wednesday, July 13, 2022 4:56 PM
To: Velasquez, Gustavo@HCD <[email protected]> Cc: Housing Elements@HCD <[email protected]>; Leonora Camner <[email protected]>; Keith Diggs <[email protected]>; Kirkeby, Megan@HCD <[email protected]>; Coy, Melinda@HCD <[email protected]>; Buckley, Tyrone@HCD <[email protected]>; McDougall, Paul@HCD <[email protected]>; [email protected]; [email protected] Subject: Public Comments on Santa Monica Housing Element Dear Director Velasquez,
On behalf of Abundant Housing LA and YIMBY Law, attached please find a public comment letter on the subsequent draft of the City of Santa Monica's Housing Element, which your department received for review on 7/8/2022. ‐‐
David J. Barboza, AICP (he/him)
Director of Policy and Research
Abundant Housing LA
515 S. Flower Street, 19th Floor
Los Angeles, CA 90071
We request that candidates do not send us confidential campaign strategy information, including polling data or other information that is not publicly available.
11.A.h
Packet Pg. 1526 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) July 13, 2022
Gustavo Velasquez, Director
California Department of Housing & Community Development 2020 West El Camino Avenue, Suite 500
Sacramento, CA 95833
Dear Director Velasquez:
Thank you for the opportunity to comment on the process of updating the Housing Element of Santa Monica’s general plan. We are writing on behalf of Abundant Housing LA (AHLA) and YIMBY Law regarding Santa Monica’s 6th Cycle Housing Element Update (HEU). Abundant Housing LA is a pro-housing, nonprofit advocacy organization working to help solve Southern California’s housing crisis, and YIMBY Law’s mission is to make housing in California more accessible and affordable through enforcement of state housing law.
We support reforms to legalize more homes, make homes easier to build, increase funding for affordable housing, and protect tenants, which are all needed to make housing more affordable, improve access to jobs and transit, promote greater environmental sustainability, and advance racial and economic equity.
On 3/16/2021, 6/1/2021, 9/8/2021 and 10/8/2021 AHLA shared letters with Santa Monica and HCD, regarding drafts of the HEU, providing comments on how Santa Monica should fulfill both the letter and the spirit of housing element law.
On 2/8/2022, HCD sent a letter to Santa Monica regarding its adopted 6th Cycle housing element, identifying corrections that need to be made to obtain certification of the plan. A subsequent draft Housing Element was received by HCD for review on 7/8/2022. The purpose of this letter is to provide our comments on the subsequent draft HEU.
We have reviewed the City’s subsequent draft HEU received by HCD on 7/8/2022, and continue to have serious concerns about Santa Monica’s ability to meet its state-mandated RHNA targets.
The 2/8/2022 HCD review letter identified deficiencies in the previous adopted HEU. This letter concludes by highlighting common themes in our and HCD’s comments.
Discussion of issues that AHLA raised previously:
Comment 1: “Planning’s process for selecting sites and assessing their capacity does not accurately estimate parcels’ likelihood of development or net new units if redeveloped.
Therefore, Planning has not identified enough sites where 9,000 homes will realistically be developed by 2029.”
11.A.h
Packet Pg. 1527 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The HEU conflates two distinct issues. The first issue is the likelihood that a given property will be developed during the planning period and the second issue is what density of development will occur on a property that is redeveloped given the various constraints such as FAR, height limits, parking requirements and other development standards. The HEU uses a pre-screening approach to identify sites that are deemed more likely to develop during the planning period 1 .
This approach considers a variety of factors, including the presence of existing housing units, historic designations, improvements to land value ratio, and others. While this approach has some merit as a way of thinking about the relative likelihood of development during the planning period, it does not produce the crucial estimate, which is the probability that the screened sites will be redeveloped during the planning period. The plan essentially assumes that this probability is 100%, but State law requires a downward adjustment for “realistic development capacity”
2 . Just because something may be more likely to happen, it does not necessarily follow that it is guaranteed to happen. The result of this error is that the plan overestimates the likelihood of development of sites in the “Suitable Sites Inventory” (SSI) and underestimates the amount of land use reform which is needed to make it likely that the RHNA will actually be built.
Indeed, the discussion of quantified objectives makes it clear that Santa Monica does not view the RHNA target as achievable. The quantified objectives for new construction are set at just 76% of the RHNA, with even larger gaps for homes affordable to lower-income households 3 . It is
unacceptable for the City of Santa Monica, in which the median price of a single-family home is $4 million and the median rent for a two-bedroom apartment is $3,200 4 , to set quantified
objectives below the RHNA. These prices are exceptional and frankly, shocking, even in the context of California’s housing affordability crisis, which is unacceptable enough on its own. We cannot become numb to the exclusion and human suffering implied by those figures. It is difficult to understand how a city with a median detached house price of $4 million can morally or legally justify having any single-family zoning within its boundaries. Where multifamily housing is allowed in Santa Monica, the median condo costs “just” about $1 million 5 , which while certainly
not affordable, is much more affordable than a $4 million house. Santa Monica needs to aim higher. Political difficulties are no excuse to take needed reforms off the table. The city’s RHNA is in fact achievable, provided that meaningful efforts to remove governmental constraints are put forward.
Comment 2: “Planning assumes that 2,183 housing units that were approved or pending approval during the 5th Cycle will be built during the 6th Cycle, without sufficiently accounting for the highly likely possibility that some projects will never be built.” The current draft of the HEU now applies a discount factor of 15%, which the document claims is based on prior experience with in-pipeline projects not completing construction. There is a 5 Santa Monica Subsequent Draft Housing Element, Appendix B, page 44. 4 Santa Monica Subsequent Draft Housing Element, Appendix B, pages 44-45. 3 Santa Monica Subsequent Draft Housing Element (redlined version), page 170. 2 Gov. Code § 65583.2(c)(2); see Elmendorf et al. (2020). “‘I Would, If Only I Could’ How Cities Can Use California’s Housing Element to Overcome Neighborhood Resistance to New Housing.” UCLA Reports.
1 Santa Monica Subsequent Draft Housing Element, Appendix F (redlined version), page 4. 2 11.A.h
Packet Pg. 1528 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) typo in Figure F-6, where it states 10% but the discounts are calculated at 15%. However, the number of units claimed as in-pipeline is now significantly higher, at 4,373, with the discount applied
6 . This accounts for nearly half of the city’s RHNA of 8,895 homes, and thus warrants additional scrutiny and spot checking by HCD.
Comment 3: “The City does not provide an adequate No Net Loss buffer for the very low income, low income, and moderate income RHNA targets, which disregards HCD’s recommendation that 15-30% capacity be provided at each level of income.” The HCD-recommended no net loss buffer is to be provided at each affordability level. The HEU now claims a buffer of at least 30% overall and for each income category, except for moderate, where the claimed buffer is only 11.6%. Given the issues identified above, under Comment 1, with regard to the lack of an estimate about the probability of development for sites passing through the pre-screening process, the sub-standard moderate income buffer is a concern.
Robust buffers reduce the risk of the plan underperforming in the event that the HEU’s assumptions about the likelihood of development are overly optimistic. They facilitate compliance with state law and reduce the likelihood that inefficient ad-hoc general plan amendments and rezoning actions will be necessary if parcels do not develop at anticipated densities.
Comment 4: “Planning continues to triple-count past ADU production in order to support an overly optimistic forecast of future ADU production.”
The ADU forecast is still problematic. General plan annual progress report data show that Santa Monica has permitted an average of 40 ADUs per year between 2018 and 2021 and they were all classified in the above moderate income affordability level 7 . Despite this, the city projects 47
ADUs per year. This goes against HCD’s ADU safe harbor method for estimating ADU production
8 . While the uptick in permitting activity is encouraging, factors including a potential recession, which the U.S. economy may already have entered 9 , could cause ADU permitting
activity to decrease. It is prudent to estimate ADU production conservatively so that Santa Monica does not run into no net loss issues that would require cumbersome ad hoc updates to the plan and the zoning code in the middle of the 6th Cycle. If ADU permitting trends in Santa Monica continue to increase, as we hope, that will be valid data to consider for the 7th Cycle.
Comment 5: “Planning misinterprets a SCAG analysis of regional ADU affordability to suggest that a significant share of future ADUs in Santa Monica will be affordable to lower-income households, which is unlikely based on local rent data.” As mentioned above in Comment 4, all ADUs permitted in Santa Monica were classified in the above moderate income affordability level in Santa Monica’s general plan annual progress 9 Heller, Robert (2022). “This Recession May Be Mild. The Second One Will Be Worse.” Barron’s. 8 Kirkeby, Megan (2020). “Housing Element Site Inventory Guidebook,” page 31. 7 California Department of Housing and Community Development. APR Data Dashboard. 6 Santa Monica Subsequent Draft Housing Element, Appendix F (redlined version), page 21 3 11.A.h
Packet Pg. 1529 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) reports between 2018 and 2021. Therefore, it is now puzzling why only 34% of ADUs are projected to be in this category going forward, and the rest are being counted towards the moderate and lower-income RHNA
10 . While the 6th Cycle’s higher RHNA target may now be motivating Santa Monica to look harder for affordable units, we remain concerned about the use of SCAG’s regional ADU affordability estimates to project ADU affordability. As mentioned above in Comment 1, Santa Monica’s median home prices and rents are extremely high, and a city-specific analysis of ADU affordability would be more appropriate given Santa Monica’s atypical position in SCAG’s housing market.
Comment 6: “Planning’s proposal to expand inclusionary zoning is unlikely to achieve a significant portion of the lower-income RHNA targets, due to the economic infeasibility of redevelopment where high set-aside percentages apply, as demonstrated by Planning’s own analysis.”
Santa Monica voters passed Proposition R in 1990, which requires that 30% of all new housing built citywide to be affordable to low or moderate-income households annually 11 . California’s
inclusionary zoning (IZ) enabling law allows HCD to require economic justification of IZ requirements above 15% for lower-income households, when certain conditions are met 12 . Such
scrutiny would certainly be wise in this case. When IZ requirements are set too high, they can act as yet another governmental constraint on housing development. If projects can’t be built because the IZ is too high to be economically feasible, the result is fewer new homes at any affordability level. A high percentage of 0 units is 0 units. Thus, the result can be appearing to do something to produce affordable housing, while actually making the problem worse.
Program 2.C calls for updating the Affordable Housing Production Program (AHPP), which is Santa Monica’s IZ ordinance
13 . Unfortunately, the revisions to be adopted are specified somewhat vaguely and it is therefore difficult to assess what, if anything, the proposed changes would accomplish. However, generally speaking, it is prudent when adopting IZ policies to craft them in light of rigorous independent economic analysis about what is feasible, and align them with the lower end of what grants incentives in state density bonus law. Local density bonus ordinances should always be more generous towards housing production than state law, or else they are moot.
Comment 7: “Planning does not propose meaningful reforms to address the major constraints on redevelopment that exist in Santa Monica.”
Single-unit zoning must be abolished in Santa Monica and replaced with something appropriate to address the city’s dire housing affordability situation. Indeed, any housing affordability plan for Santa Monica that fails to do so would be absurd on its face. As mentioned above, the median detached house in Santa Monica is valued at $4 million. The plan notes the racist origins of 13 Santa Monica Subsequent Draft Housing Element (redlined version), page 135. 12 Assembly Bill 1505. Chapter 376, Statutes of 2017.
11 Santa Monica Subsequent Draft Housing Element (redlined version), page 170. 10 Santa Monica Subsequent Draft Housing Element (redlined version), page 116. 4 11.A.h
Packet Pg. 1530 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) single-unit zoning: "Single-unit zoning was also seen as a way to economically separate the wealthier Whites from Blacks/African Americans and other racial and ethnic groups, including Italians, Japanese, Mexicans, Portuguese and, later Jews 14 ." These harms are not some
abstract historical curiosity. To this day, Santa Monica has Racially Concentrated Areas of Affluence in the northeast of the city that overlap with areas of single-family zoning 15 . The city is
less racially diverse than the County as a whole and is majority non-Hispanic white, in a county where non-Hispanic whites make up only about 25% of the population 16 . This is not affirmatively
furthering fair housing (AFFH), it is entrenching de facto segregation.
Program 4.E does propose to go a bit beyond the unit allowance provided by SB 9 for lot splits and duplexes on single-unit zoned properties
17 . However, allowing six units on land where state
law currently allows four is not a measure commensurate with the scale of the crisis. Santa Monica’s extremely high housing costs and “built out” nature suggest that much denser forms of housing would be needed to make market rate housing abundant and affordable there. The obstacles to allowing that type of housing are not technical, they are political.
Eliminating off-street parking requirements citywide would help make housing more affordable and feasible to build while fostering a more balanced, sustainable transportation system. Some of the plan’s programs appear to rely on this type of action while at the same time not firmly committing to it. For example, Program 1.C deals with redevelopment of parking lots associated with commercial uses which are located in residential zones 18 . Such redevelopment is unlikely
to be feasible without abolishing commercial parking requirements 19 , at least for the properties
in question. The program should also address existing leases, a type of nongovernmental constraint that often imposes contractual rights to the use of a particular parking lot.
Program 1.D commits to reducing parking requirements to “Parking Overlay 1” rates, which are not specified in the description of the program. Santa Monica should save itself the trouble of describing Parking Overlay 1 here and commit to eliminating parking requirements citywide.
This would be an action commensurate with the severity of the city’s housing affordability crisis, not to mention the climate crisis.
Program 1.A calls for by-right approvals of certain housing projects, but limits this helpful measure to overly narrow categories, like 100% affordable projects 20 . There are only about
3,900 deed-restricted affordable units in the city but about 52,600 units overall (7.4%) 21 .
Streamlining should apply to all housing development projects, because they all contribute in different ways to a healthier, less exclusive housing market. If discretionary review were 21 Santa Monica Subsequent Draft Housing Element (redlined version), page 146. 20 Santa Monica Subsequent Draft Housing Element (redlined version), page 121. 19 See Santa Monica Municipal Code § 9.28.060.
18 Santa Monica Subsequent Draft Housing Element (redlined version), page 124. 17 Santa Monica Subsequent Draft Housing Element (redlined version), page 156. 16 Santa Monica Subsequent Draft Housing Element (redlined version), page 44. 15 Santa Monica Subsequent Draft Housing Element (redlined version), page 49. 14 Santa Monica Subsequent Draft Housing Element (redlined version), page 40. 5 11.A.h
Packet Pg. 1531 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) compatible with housing affordability in Santa Monica, the city’s home prices and rents would be in a very different place.
Comment 8: “For all of the above reasons, Planning’s intended approach to updating the housing element does not affirmatively further fair housing and reverse existing patterns of residential segregation in Santa Monica.”
Building on the discussion above under Comment 7, Santa Monica does propose some programs to AFFH, but they do not fundamentally disrupt the status quo, and thus are more symbolic than substantive. For example, Program 4.D attempts to redress the displacement of Black, Indigenous and other communities of color during the 1950s and 1960s, when the 10 Freeway and Civic Auditorium were built
22 . However, prioritizing these people and their
descendants for selection in underfunded affordable housing programs does not constitute a “right to return,” it’s more of a “slim chance to return, if you’re lucky.” Program 6.C, dubbed “preserving our diversity” provides cash assistance for lower-income seniors to help them hang on in Santa Monica, but the funding available cannot overcome the housing scarcity that makes Santa Monica ever more exclusive with each passing day
23 . While the program is doubtless
helpful and appreciated by the lucky few who benefit from it, this is the equivalent of building a low berm on the beach to stop a tsunami. AFFH requires solutions that work at the same scale as the problem. Abolishing single-family zoning and replacing it with zoning that allows for a range of multifamily housing types, including bungalow courts, townhomes and apartment buildings, would be a more significant action to AFFH.
MapCraft Analysis:
AHLA commissioned an independent analysis of the HEU by MapCraft Labs, dated 12/9/2021 24 .
The analysis found that the capacity claimed in the sites inventory could fall short by approximately 1,800 to 3,500 units. The finding lends support to our conclusion that the sites inventory is not adequately considering realistic development capacity 25 . The analysis
considered historic development scale and financial feasibility analysis under different parking requirements scenarios. The analysis makes the following recommendations:
1. “Right-sizing claimed capacity on sites in the current site inventory, both by reducing expectations on many sites and being more ambitious in upzoning other sites. The city could revisit additional opportunities to rezone more parcels in the inventory, particularly in areas like Downtown, Mid-City, and Northeast.”
2. “Adding more sites to the site inventory and evaluating rezoning of those sites. Excluding ADUs, the inventory includes only 1% of the city’s 23,400 parcels, so there are many places that could be explored further to address this potential shortfall.” 25 See above text accompanying fn. 2.
24 MapCraft (2021). “Housing Element Analysis Results.” 23 Santa Monica Subsequent Draft Housing Element (redlined version), page 162. 22 Santa Monica Subsequent Draft Housing Element (redlined version), page 155. 6 11.A.h
Packet Pg. 1532 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
3. “Reducing or eliminating parking requirements and promoting automobile alternatives to reduce households’ demand for parking. If developers could meet household demand with fewer on-site parking stalls, it could make multifamily development in many parts of the City more economically feasible.”
4. “Introducing new economic incentives to increase the financial feasibility of redevelopment, especially for projects that include below-market-rate units.”
5. “Consider establishing development minimums to ensure high utilization of sites with feasible housing capacity.”
Comparison of HCD Comment Letter and AHLA/YIMBY Law Comment Letter:
The table below lists the comment numbers that are relevant to the categories of deficiencies identified, along with a summary of key AHLA and YIMBY Law policy recommendations for each category.
Deficiency
AHLA/YIMBY
Law Comment
Letter
HCD
Comment
Letter
Key AHLA/YIMBY Law Policy
Recommendations
Sites Inventory 1, 2, 3, 4, 5 A2, B1
Quantify the likelihood that each
parcel in the SSI will be
redeveloped during the planning
period.
Set quantified objectives at or
above RHNA overall and for each
affordability level.
Spot check the development
pipeline for realism.
Propose an adequate no net loss
buffer for the moderate income
category.
Make ADU forecast more realistic.
Conduct a city-specific ADU
affordability analysis.
Funding and
Promoting
Affordable
Housing and
Housing for
Special-Needs
Groups
6 B2
Provide evidence that IZ
requirements are not acting as a
constraint on development and
defeating their own stated purpose.
7 11.A.h
Packet Pg. 1533 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Deficiency
AHLA/YIMBY
Law Comment
Letter
HCD
Comment
Letter
Key AHLA/YIMBY Law Policy
Recommendations
Governmental
Constraint
Removal
7 A3, B2
Abolish single-unit zoning and allow
a full range of multifamily housing
types on these parcels.
Abolish minimum parking
requirements.
Expand ministerial approval
procedures to all housing projects.
AFFH Analysis
and Programs to
Promote
Integrated
Neighborhoods
8 A1, B3
Remove governmental constraints
more aggressively, so other AFFH
programs become more than
symbolic.
We request the opportunity to meet with you and your colleagues to address the concerns raised in this letter. Thank you for your time and consideration.
Sincerely,
Leonora Camner Sonja Trauss
Leonora Camner
Executive Director
Abundant Housing LA
Sonja Trauss
Executive Director
YIMBY Law
CC: Megan Kirkeby, Deputy Director, Housing Policy Development, HCD Melinda Coy, Land Use and Planning Manager, HCD
Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD Paul McDougall, Housing Policy Development Manager, HCD Santa Monica City Council
Santa Monica Planning Department
8 11.A.h
Packet Pg. 1534 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Monday, July 25, 2022 8:44 AM
To: Jing Yeo
Subject: FW: How much longer will Santa Monica & other localities be permitted to abuse their positions?
Attachments: SocialHousingAuthority.TieiraRyder.4-25-22.pdf; PenmarGolfCourse+SMAirportproposal.TieiraRyder.pdf
EXTERNAL
FYI
From: HowTheWest Was Saved <[email protected]>
Sent: Monday, July 25, 2022 8:23 AM
To: Housing Elements@HCD <[email protected]>
Cc: [email protected]; [email protected]; [email protected]; [email protected]; Ruth Roofless <[email protected]>; Leonora <[email protected]>; [email protected]; LA City Planning <[email protected]>; [email protected]; McDougall, Paul@HCD <[email protected]>
Subject: How much longer will Santa Monica & other localities be permitted to abuse their positions? "Santa Monica, ever the innovator, is breaking new ground in the field of blocking new homes by appropriating the language of social justice. This proposed initiative would require developers to pay up to 2.7 times the prevailing wage, which is of course completely infeasible."
https://twitter.com/ShaneDPhillips/status/1550947176410333184?s=20&t=24YgX0Adpt tkcmx_z0reQw [twitter.com]
How much longer will Santa Monica & other localities be permitted to abuse their positions as residents continue to flee the state and those that stay continue to fall into homelessness? I'm asking HCD again to please authorize a county-led social housing authority that is people-led across all CA cities. We cannot wait for the establishment that has not done the right thing to finally just wake up one morning and decide they are going to do the right thing.
When has that ever happened and if it does, it's very rare! The people have waited long enough, we need localities to get their hands out of the housing market, they are causing serious disruptions in the lives of millions! What is a housing authority if
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Packet Pg. 1535 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 they are not aligned with the best interests of the mass majority of residents who have a RIGHT TO LAND USE & HOUSING?
Thank You for your attention to the matter, I'm patiently waiting for your response.
Best,
How The West Was Saved
https://htwws.org/social-housing-ca/ [htwws.org]
Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
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Packet Pg. 1536 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 1/11
HOW THE WEST WAS SAVED
"In the future when it's asked how the west was saved, the story will be that the people of the west saved themselves from ongoing systematic violence"
THE PROGRESSIVE SPACE
When The Santa Monica Airport Closes…
By Bear Writer On 05/30/2021
Update: A Letter from HCD (Department of Housing & Community development) to Santa Monica City’s planning team regarding the upcoming housing element. How The West Was Saved (Tieira R.), Our current direction is not left
or right, but forward towards
progress.
How The West Was Saved is an
open space for discussions on
progressive solutions to the
Western world. Our team is
currently focused on solutions
to affordable housing in the
Greater Los Angeles area. We
are committed to progress, we
are committed to change for
the betterment of everyone in
society.
Follow Us
Petition:
Close the
incorrectly
zoned Santa
Monica
airport and
build housing
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Packet Pg. 1537 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 2/11
along with some other wonderful housing advocates were mentioned as consideration for the comments that HCD gave to Santa Monica regarding a compliant housing element. Thank You HCD for rejecting Santa Monica’s non-compliant housing element, we must hold cities accountable for housing production so that residents can finally have the housing that they are owed!
https://www.smgov.net/
When the incorrectly zoned Santa Monica airport closes, a closure that should be happening in this upcoming housing element cycle (2021-2022), a walkable community that includes
majority affordable housing should be developed. The
location is perfect for a community-owned, walkable/bike-friendly residential neighborhood that includes a variety of housing types for working-class residents on the westside, students, seniors, those living with disabilities, and many others in need of affordable housing.
(Author does not
own the rights to
all of the photos
attached, via
social media. All
rights reserved to
original owners)
Taras Grescoe
@grescoe
“I’ve been living my life wrong.”
—literally everyone in North America.
6:23 AM · Aug 30, 2021
1.4K Reply Share
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Packet Pg. 1538 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 3/11
To be clear, this community would include both communityowned rental and homeownership options. This pro-housing advocacy effort should be led by a housing advocate that understands the needs of the local community, someone that likely falls within the working class and has the best interest of the local community in mind. When it comes to renting, rent should never exceed 20-30% of a resident’s total income after
taxes. Please keep in mind, the average worker in LA makes about $39,000 a year, this rental housing would be catered to those workers but the community itself would be mixedincome meaning it would also include market-rate units (still cheaper usually than private market-rate housing).
Along with market-rate rentals & homeownership opportunities, business placements would be considered throughout the
community.
Housing proposal for the Santa Monica airport
(Please note that Penmar golf course is also being requested for this project.
The exact community plans would need to be confirmed & this is just a proposed housing plan for the vacant land space. The proposal was created by Tieira R.)
Affordable Homeownership;
1. Affordable, reasonably priced homeownership for working-class residents, priority for long-term residents living or working in the Santa Monica, Venice, & Mar Vista zip codes.
2. Consider a set number of market-rate “for-sale” homes.
3. A variety of home types should be considered for development but especially multi-family housing such as plexes, condos, townhomes, and apartments. Consider co-op ownership.
4. Priority consideration should also go to first-time
homeowners in LA County, my recommendation is residents that have lived/worked at least 10 years in LA County.
5. Priority consideration for historically displaced residents from supposed marginalized communities. Consider a 30-40% “right to return”, “right to housing” for ADOS families (African
descendants of Survivors), & for other residents impacted by systematic housing violence. (Google the history of displaced Black families in Santa Monica, Venice, and/or Manhattan Beach if you need more info.)
6. The millennial generation should also receive a percentage of priority consideration, they currently own a measly 18% of the homes in Los Angeles. “Equity is defined as “the state, quality or ideal of being just, impartial and fair.” The concept of equity is synonymous with fairness and
justice.”
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Packet Pg. 1539 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 4/11
7. At no time would a small or large equity firm be granted permission to purchase a home within the community nor would an option be granted to purchase the community as a whole.
8. My recommendation on income qualifications for residents that are first-time buyers is; working-class residents making between $30,000-$130,000.
9. If potential owners require financing, ownership could be subject to credit union or bank approval. Consider public, city-owned bank.
10. The actual cost of homes should match that of the actual average wage of what most working-class residents make. There would likely be re-sell requirements as affordability would be protected by a trust.
Affordable Rental Housing;
1. Community-owned rental housing in mixed-income
developments.
2. The recommended height for apartment buildings is 6-7 stories.
3. Set an “affordable rental rate” based on what the average person from the working class makes. At this moment, most workers in LA make about $39,000 a year. Affordability is usually priced for residents in the $17,000-$70,000 range.
4. Community-owned market-rate rentals to be included, most likely still cheaper than the private market-rate rental housing.
5. No income restrictions once residents are housed.
https://www.nhlp.org/resources/lihtc-admissions-rentsgrievance-procedures/
6. Reserve a portion of the housing for limited to no-income residents. Consider the following; subsidize with HUD and/or new digital voucher program; subsidize low to no income residents with market-rate apartment & business rentals; consider HCID/HACLA westside chapter. Social services for housing, food, and health care should be ONE efficient program.
7. Affordable bachelors, studios, 1, 2, and 3 bedrooms.
8. As with affordable homeownership, the rental units & placements would be for various types of community members but especially keeping in mind our core working class which includes
the essential workforce, students, seniors, veterans, those living with disabilities, etc. etc.
9. Student apartments would be bachelor-sized apartments with smaller fridges and MUST have a kitchen area sink and a small area to put a hot plate (or something similar) so they can cook if needed. (Similar to this https://urbanize.city/la/post/micro-unitapartment-building)
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Packet Pg. 1540 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 5/11
More info on the proposed community as a whole;
1. priority consideration for business placements within the community.
2. Open park space, recreation center within the walkable community. Cars can exist on the outside of the community, not within.
3. Consider the possible need to build new schools.
4. Consider a quality westside public transit system especially for college students between SMC and/or UCLA. (cut down on car traffic congestion because students wouldn’t need to drive)
5. College student housing should have its own small park area that has a WIFI and outdoor/indoor workspace for them.
6. Consider large home space for displaced minors within the community aka a “group home” to provide stability.
7. Request consideration for golf course closure(s) as well as other vacant land plots and buildings that have
potential use for affordable housing that is communityowned and suits apartments, condos, townhomes, small and/or tiny homes for locals. Request more interim housing and healthcare sites on the westside for residents with long-term behavioral health needs.
The overall progressive housing goal is to adopt a similar social housing policy for each city in California (all of the U.S) with prohousing community advocates from said cities leading the efforts.
The private market can obviously always exist but it can’t compete against itself, forcing residents to beg for housing that is priced much higher than most can afford. That doesn’t sound like freedom to me!
California’s Housing Crisis
The current CA housing crisis is literally wiping out and pushing the blue-collar working class, students, senior citizens, and many other residents into poverty! In the last 10 years, rent has gone up well over 65% in the city of Los Angeles, in that same amount of time the number of unhoused residents increased by at least 50%! There are currently 60,000+
unhoused residents in LA County and the median income can no longer afford a rent-controlled studio in cities like Santa Monica!
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Packet Pg. 1541 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 6/11
It’s time to return ownership to the residents of Los
Angeles, our right to clean, safe, and affordable housing is being denied!
Side Notes:
Walkable communities are
essential
https://planning.lacity.org/plans-policies/housing-element (LA City Housing Element)
What is a community land trust?
“Starting at about $600 per month for a studio, rents in the Los Angeles Eco-Village are less than half the price of some comparable apartments nearby, and prices aren’t raised unless community members agree to it. That’s possible because the land beneath the co-op is owned by the Beverly/Vermont Community Land Trust, which has pledged to make the land permanently affordable regardless of rising housing prices.”
Renters need to earn $95,000 to afford rent-controlled
studio in Santa Monica, new report says
A household earning the Los Angeles area’s median income cannot afford a rentcontrolled studio in Santa Monica, according to a new report from the city’s Rent Control Board. By U.S. Department of Housing and Urban Development affordability standards, a family would need an income of at least $95,429 to afford a studio, which is about … Continue reading
Santa Monica Daily Press 1
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Packet Pg. 1542 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 7/11
https://laist.com/2021/02/02/community-land-trusts-los-angelesaffordable.php An email from the Santa Monica planning team regarding
use of the airport in this upcoming housing element
“Hi , Thanks for sharing your proposal and thoughts for the airport. Please note that since the airport is slated to close at the end of 2028 and conversion to any other use would take time, the airport is not realistically being considered in the planning for the 6 cycle Housing Element Update
(October 2021 – July 2029). It will most certainly be a consideration in the following housing element cycle
(beyond 2029). However, to get to that point, there will need to be a public process around the future of the airport given the significant community interest and varying views on its future use so I hope you will continue on to be engaged in that separate effort.”
Quotes from an LA Times article regarding the Santa
Monica airport
“The opening of a the 227-acre site on the Westside — in close proximity to jobs, good schools and transit — is a once-in-ageneration opportunity. Housing has to be a part of the equation. “Since the 1980s, Santa Monica has approved the construction of millions of square feet of office space, transforming it into a hub for both the tech and entertainment industries, with a daytime population that swells by more than 150,000 people. But this explosive job growth has not been accompanied by a proportional increase in housing units.” “Santa Monica’s estimated population of 92,478 residents in 2019 was only a blip above what it was in 1970, when 88,289 people called the city home. This growing imbalance between jobs and housing has created a massive influx of daily commuters into Santa Monica (even well-compensated tech employees) who either can’t find or can’t afford housing near these job centers. Meanwhile, population in neighboring jurisdictions has swelled, displacing lower-income residents. The result is more and more commuters crowding the freeways from increasingly distant parts of Southern California.”
The plan to turn Santa Monica Airport into a park is irresponsible.
The Westside needs housing
th
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Packet Pg. 1543 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) REPEAL ARTICLE 34 in the CA state constitution; USE public land for PUBLIC GOOD, end systematic housing violence & displacement. Article 34 of the CA constitution reads; “No low rent housing project shall hereafter be developed, constructed, or acquired in any manner by any state public body until, a majority of the qualified electors of the city, town or county, as the case may be..”
Localities that have been abusing their positions and segregating cities by race & class should not decide what happens to public land. Workers that commute into cities also have the right to decide what happens to public land, retirees, college students, and many others also have that right!
“Heidi Marston resigns from LASHA, citing difficulties in fulfilling LAHSA's mission without "fundamental shifts". In her resignation letter, Marston elaborates:
"Power and funding alone control homelessness. But in our current system, organizations like the one I lead, the Los Angeles Homeless Services Authority (LAHSA), are not given control over regulatory or policy decisions, service providers remain underfunded, and dedicated front-line employees of non-profit organizations and government entities are hamstrung by rules, red tape, and bureaucracy. Marston also points to low wages, high rents, restrictive zoning laws, and other "shadow monsters'' we must tackle in order to end homelessness." https://medium.com/@hmarston2/the-homelessness-crisis-a-monster-of-our-own-maki ng-be5975399ce1
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Packet Pg. 1544 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Structural Governance of the Social Housing Authority
The State Housing Authority - HCD will oversee
The Social Housing Authority; Community-led development of PS, affordable, & market-rate housing: Social Housing Agencies in each county in CA (ONE SOCIAL HOUSING AGENCY with selected progressive civil peers (community advocates) assigned to offices in each part of the county (likely NSEW & Mid-City, TBD); a group of progressive housing civil peers that implements & develops new community-owned affordable, market-rate, and PS rental housing on publicly owned land throughout LA County. Communities are well put together, mostly in walkable, pedestrian/bike-friendly built communities. The agency as a collective whole will capture vacancy numbers (parking lots, buildings (privately & publicly owned), to determine ownership/best use for vacant spaces.
The Social Housing Authority will override city councils in localities to partner directly with County BOS, and HCD to collect funding meant for homeless/housing 2 11.A.h
Packet Pg. 1545 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) spending, money goes into ONE TRUST account that must provide RECEIPTS of where/how much money is spent on specific projects.
Agency works with HUD to implement new guidelines for affordable homeownership for the blue-collar working class. Agency maintains ONE website/database that has a list of AVAILABLE community-owned affordable, market-rate, and PS rental housing. List of AVAILABLE affordable & market-rate homeownership opportunities.
Affordable housing waitlist for rental housing should be no longer than 6 months, 6 months is actually too long but should not exceed that. The social housing agency is focused on public safety, public safety means safety from heavy traffic violence and climate arson. This means the social housing team works to build communities that are walkable, bike, and pedestrian-friendly. Communities that have access to green space.
Communities that aren’t being heavily polluted by LAPD helicopter pilots (noise & fuel pollution linked to dementia, linked to cancer). Cars belong on the outside of multi-family communities, not within. Cars are occupying too much land space! Humans need land to live on, we shouldn’t NEED to drive everywhere. Create when possible 15-20 minute cities/small communities.
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Packet Pg. 1546 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Social Agency is primarily focused on the development of community-owned housing. However, the agency will be divided into 3 primary teams; PSH, affordable & market-rate rentals, affordable & market-rate homeownership; Permanent Supportive Housing- PSH for residents in need of wraparound services. Services could be needed short or long-term depending on the person.
This team is focused on securing housing for residents with low-to-no income, chronically homeless, FOSTER youth (up to age 24), disabilities etc. This team doesn’t provide the services it connects other agencies & non-profits to PS housing.
This team maintains a database of PSH units that are available and works to revamp/remodel the broken shelter housing system to turn them into PSH.
Again, ONE social service housing website for residents with varying needs.
Foster Youth: safe and clean group homes that provide guidance & structure to youth/young adults up to the age of 24.
REVAMP the broken Foster System; guidance comes from social workers that are based out of the revamped DPSS, non-profits, grassroots teams, etc.).
PSH shouldn’t feel carceral (jail-prison like).
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Packet Pg. 1547 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Supportive services are wraparound services in QUALITY family planning, STI/STD prevention/protection, mental, behavioral, & rehabilitation healthcare, etc, etc.
Introduce UBI, money that should come from another trust account will not come from the housing trust fund. UBI for foster youth, and adult residents not working or below the poverty line. UBI up to $1000 a month for completed work/ treatment assignments.
For displaced youth; completed schooling/work/etc. Standard UBI (no work /treatment assignments required) $300-$500.
Repeating; services are provided by A REVAMPED DPSS, by grassroots and non-profit teams, etc. Agency will provide a civil peer court system; will also be for any potential cases of alleged abuse happening from workers but all workers must have ongoing training, schooling, and teachings in proper behavior when interacting with residents in PSH communities, especially foster youth! Service teams should meet every few months to go over what is and what is not working, the social housing agency does not provide the service, they are simply making available the housing needed for the residents in need of PSH, possibly in need of long term care, healing, community.
The PSH Social Housing Team works with the DPSS to secure safe parking/dwelling zones within the county until PSH becomes available. All non-profit groups/service teams need to be an extension of this department (LASHA, DPSS, Grassroot teams, etc., etc.) Service teams should be able to contact PSH social agency team to find PSH, Safe parking/dwelling, and/or to receive money for temporary hotel/room stays (FEMA MONEY should be used as the ONE trust account is mostly for development/maintenance/admin of community-owned housing. ONE TRUST per county social agency/authority).
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Packet Pg. 1548 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-Owned affordable & market-rate Housing; residents are self-sufficient, can pass a criminal background check likely just need assistance securing an affordable or market-rate unit. Will work with residents with a prior eviction. Community-owned affordable & market-rate rental housing that is always affordable. Rent shouldn’t take more than 20-30% of a resident's total income after taxes. Establish an affordable rental market-rate price for the blue-collar working class. The affordable price should not be averaged with working-class/high income earners included in the calculation. Most workers, most jobs in LA County pay about $40,000. What is the average wage for the blue-collar worker??? Community-owned, market-rate units will likely be much cheaper than privately owned market-rate.
All local city affordable housing authorities would be moved into the social agency/demolished. There are too many moving parts of the housing programs/processes. We need ONE coordinated system with FUNCTIONING non-profits, social service teams an extension of the one agency. Social workers, field workers, and rehousing specialists should be able to utilize the agency/website to secure at a minimum safe parking/safe dwelling. Should be able to give food vouchers/stamps, etc. to those that need them.
Again, the housing team is likely divided by local cities in the county, likely by NSEW & mid-city, TBD. Each of those divided teams will be divided into the 3 groups of; PSH, affordable & market-rate rentals, affordable & market-rate homeownership) Public Safety- A civil peer board of housing (court) will be established to hear cases about any potential threats to public safety happening in Socially owned housing. The court will also hear about allegations of any abuse happening within the system and 6 11.A.h
Packet Pg. 1549 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) correct the action. PSA on appropriate behavior will be provided to all residents/staff that are part of the social housing community.
The goal of the Social Housing agency is to prevent displacement but they will support “JUST-CAUSE” eviction for tenants posing a risk/threat to other tenants. No gang activity or violence WILL be tolerated, the community has a right to safety, if that safety is ever threatened, residents in the community have the right to evict! Some PSH will be for residents in transition from jail/prison back into community living. Prevent ROOT CAUSE of problems that we are seeing in our community. Also, consider communities for disabled residents/ residents with special needs that may need long-term wraparound services. Consider partnership with community colleges for affordable housing for students/young adults up to age 24-25. Consider committed behavioral, mental, and rehabilitation health programs for residents with outstanding issues in above mentioned. Any committed programs should still be a place of healing, not further violence and trauma. Dismantle and rebuild existing programs in that area.
Fix the problems at the ROOT, save the next generation and again, ongoing training, and schooling, for workers in this field. HIGHER pay for workers in these fields! 7 11.A.h
Packet Pg. 1550 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) The private housing market can always exist if it likes but residents shouldn't be forced to rely on it. There are residents whose families have been dealing with generational housing violence as it relates to race & class, they cannot rely on a privately owned market that has no accountability! Rent has gone up by over 65% within the last 10 years in LA County with no rebuttal for the blue-collar working class, retirees, residents of generational housing violence and displacement, college students, foster youth, and many many others. 8 11.A.h
Packet Pg. 1551 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) 9 11.A.h
Packet Pg. 1552 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) This social agency will have nothing to do with private housing developments but it can purchase private housing and it can assist with securing housing for residents in privately owned housing. The Social Agency will maintain a website of AVAILABLE community-owned affordable, market-rate, and PS rental housing units. Privately owned units can also be listed. <<< WATCH CYBER FRAUD/SCAMS which is rampant on apartment rental websites.
The social agency is being created to develop and implement new housing developments on vacant publicly owned land and remodels for publicly owned vacant buildings. The agency cannot deny community-owned housing developments in any neighborhood in LA County, they are a county-wide team that implements new developments of community-owned PS, affordable, and market-rate housing in ALL CITIES in the county, this includes SANTA MONICA, BEVERLY HILLS,
WEST HOLLYWOOD, MARINA DEL REY, PASADENA, DOWNEY, LONG
BEACH, etc., etc., etc., ALL CITIES IN LA COUNTY! The intentional segregation as it relates to race & class MUST end, THE NIMBY violence MUST END!
For community-owned affordable & market-rate housing, long-term residents of LA County should get priority with housing placements, focusing on getting workers closer to their jobs. It is imperative for the health of humans, the health of the Earth, and other species that we reduce drive times, and reduce pollution. Preventing displacement is IMPERATIVE. The team can prevent displacement by subsidizing rent for tenants in privately owned units and/or helping move them to community-owned affordable housing.
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Packet Pg. 1553 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Affordable homeownership- full proposal coming soon, introduce co-ops, CLT’s, and resell requirements. The primary focus is blue-collar workers (affordable with resell requirements) and market-rate housing. Use money from market-rate sales to place into the ONE trust account. Insert grassroots team to help with restorative justice aspects of homeownership for residents impacted by systematic racial violence.
How do you think this story is going to end?????????
Short-term rentals- introduce tourism short-term stays, money goes into the ONE trust account.
Trust Account- One trust account that will be audited by city/state controllers. Money comes from HUD, Feds, State, Donations, & HHH. The annual state surplus budget must donate a portion into trust every year. The tourism industry should be donating a portion of total earnings into the trust. The cannabis industry should be donating a portion of money into the trust, should be redirecting money to communities impacted by the “pretend war on drugs” created by the U.S Gov’t. A small portion is for admin/resident manager fees (try to avoid outsourcing resident management to other companies, which could run up costs). The largest portion of the trust is for housing development/property maintenance.) How much are CA taxpayers giving in federal dollars to other states using the money for social services (TBD). 11 11.A.h
Packet Pg. 1554 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-owned housing cannot be sold to corporations. If TOPA is introduced, keep under CLT (land lease) to allow tenants to purchase their units but prevent corporations from being able to purchase***??? (verify). Also, any money given to nonprofits to build affordable housing should mean that that housing cannot be sold to a corporation. How and why are some non-profits that received Gov’t/Taxpayer money able to sell affordable buildings after a set number of years to private corporations? Housing would go back to the social agency OR TOPA if the non-profit wanted to be released from oversight/responsibility. The Social Agency can buy privately owned property and resell it to private owners/corporations but NOT publicly owned land/housing, not rent nor ownership. Again, community-owned developments are going to be built with the community in mind, with green space, stores, hospitals, etc., sometimes worked/developed within the communities.
Social Housing Plans ready for implementation;
https://htwws.org/santamonicaairport/
(Author notes, not part of the proposal)
-Examine the years that ADOS (American descendants of Survivors paid federal taxes but were not able to utilize public service. Examine displacement and communities that were intentionally burned t the ground by supremacists. Request reimbursement/hold percent of federal/state taxes to heal communities.
-Tenancy in common is a form of co-ownership of property in which each party owns an undivided interest that passes to his or her heirs at death. The interest is undivided 12 11.A.h
Packet Pg. 1555 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) because each tenant has rights in the whole property. Although ownership is in common, tenants may have equal or unequal shares.
-Joint tenancy is the joint ownership of property by two or more co-owners in which each co-owner owns an undivided portion of the property. On the death of one of the joint tenants, their interest is automatically passed to surviving tenants. -Real property- immovable property, a building, land, plants etc, (though buildings can actually be moved depending on).
-Just cause eviction in CLT - Community members causing violence when corrective action cannot be taken, not working. Racial violence & other forms of discrimination.
Peer court will recommend rehabilitation programs when permitted to do so, severe cases could result in immediate evictions.
-Land on Earth belongs to all of humanity.
-Land has not been fairly distributed to residents impacted by systematic housing violence as it relates to race & class.
-The aim of the Surplus Land Act (the "Act"); is to increase the availability of real property in California for affordable housing development by requiring the prioritization of affordable housing when selling or leasing public lands no longer necessary for agency use.
-"Feb. 5, 1866: Thaddeus Stevens Proposes Land Distribution Amendment" https://www.zinnedproject.org/news/tdih/thaddeus-stevens-freedmens-bill/ 13 11.A.h
Packet Pg. 1556 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -Foster City- examine the broken foster system, keeping families together whenever possible, family planning services, safe housing & family for youth that are not able to stay with their biological families.
To do;
-Write the state bar and include them on your housing emails. REQUIRE that the state bar authorize civil peers to oversee legal issues related to housing (LLP’s). -BLM the org must redirect funding into one trust that is overseen by a group of Black civil peers. Push money back into Black communities as direct UBI payment, as housing payments, treatment payments, crime & gang prevention, etc., etc. -Email OMBW/Watch for grants (GS)
-Civilian Eminent Domain of Public Land; communities protected from Climate arson; Free market exists for those that want to be part of it. -Establish Public Bank
-A PORTION of public land MUST remain PUBLICLY owned for use by the community.
-Agency divided into NSEW & Mid-City?!?! Civil Peer teams in NSEW & Mid-City ?? -If the BOS goes ROUGE, the social agency will partner with the state housing authority directly and override county BOS should they become non-compliant. 14 11.A.h
Packet Pg. 1557 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -representcal.org, why a constitutional convention is necessary, and how the CA constitution allows localities to abuse their position, allows illegal segregation as it relates to race & class.
-Examine pre-built tiny home/ADU placements in well put together communities that are affordable & supportive. Sheds are not tiny homes. Some residents already own tiny homes or they want to, can support themselves but need land. Communities likely could be supported in the valley.
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Packet Pg. 1558 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Friday, July 29, 2022 9:44 AM
To: Jing Yeo
Subject: FW: Santa Monica 7 29 2022: Current Draft Housing Element Santa Monica
EXTERNAL
FYI
From: Elizabeth Lutz <[email protected]>
Sent: Friday, July 29, 2022 8:19 AM
To: McDougall, Paul@HCD <[email protected]>
Cc: [email protected]
Subject: Santa Monica 7 29 2022: Current Draft Housing Element Santa Monica Dear Mr. McDougall,
At the Santa Monica Housing Commission meeting this week it was revealed that 5 of the 11 staff positions at the Santa Monica Housing Authority are empty. The manager position for the SMHA has been vacant since November 2021. The Housing Commission Chair noted that they were not able to see the vacancies posted in any job‐search areas. https://www.santamonica.gov/housing‐commission [santamonica.gov] https://bluejeans.com/s/C@@_wHQD3Ns [bluejeans.com]
The issue of continued segregation into 100% affordable housing tenements rather than integrated buildings was raised.
The fact that voucher holders can only afford deed‐restricted units in these deed‐restricted buildings lining the major 10 freeway and Lincoln Blvd was raised. The lack of consequences for illegal evictions of section 8 tenants was raised.
The Santa Monica Housing Authority does not have a rent‐competitive voucher nor allow for Area rent adjustments.
The lack of an ADA administrator for housing (when the Housing Element proposes this position as an answer to many of its segregation problems) was noted. The lack of accessible process for discrimination ADA or FHA complaints was raised. The flagrant neglect of the SMHA to apply for grant funds currently available through the Biden administration to make websites ADA accessible was ignored.
The two SMHA representatives attending denied economic and racial discrimination in Santa Monica and insisted affordable housing is available throughout the City. There are no statistics or records kept by the housing authority of how many voucher holders are in deed‐restricted buildings and low‐income housing versus market‐rate or R1 areas.
It was noted that economically similar cities on the Coast have integrated neighborhoods, self‐efficacy and homeownership programs in place.
Thank you,
Elizabeth Lutz
On Tue, Jun 28, 2022 at 1:32 PM McDougall, Paul@HCD <[email protected]> wrote:
Thank you for your comments Elizabeth
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Packet Pg. 1559 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 From: Elizabeth Lutz <[email protected]>
Sent: Tuesday, June 28, 2022 1:26 PM
To: McDougall, Paul@HCD <[email protected]>
Subject: Current Draft Housing Element Santa Monica
Dear Mr. McDougall,
The Planning Commission of the City of Santa Monica has finished their current Housing Element Draft although it is not accepting comments. I am forwarding limited comments regarding the FHA and ADA systemic biases and practices in the City as pertain to this draft.
I am sending this after reading the Housing elements of other Cities in Coastal California and I see we can do much much better at addressing discrimination. Additionally, the housing element is misleading in some respects and I seek to clarify as a disabled resident of the City.
My expertise is only FHA and ADA, and I have limited my comments to a few examples where change is purported however where actually the Housing element and City practices perpetuate systemic issues.
Thank you for your work and your consideration for the issues in my City.
Elizabeth Lutz
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Packet Pg. 1560 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Thursday, September 15, 2022 5:09 AM
To: Jing Yeo
Subject: FW: Santa Monica Housing Element - Program 1.A
EXTERNAL
FYI
From: Santa Monica Commenter <[email protected]>
Sent: Wednesday, September 14, 2022 2:58 PM
To: McDougall, Paul@HCD <[email protected]>; Kirkeby, Megan@HCD <[email protected]> Subject: Santa Monica Housing Element ‐ Program 1.A
Dear HCD Team:
I would like to point out a potential flaw in Santa Monica's Housing Element. I am a Santa Monica resident who has been interested in our Housing Element but I have not felt comfortable sharing this issue with HCD for fear of reprisal by our Mayor and City Council. However, I recently learned that you will consider anonymous comments so I am submitting anonymously instead.
I believe Santa Monica has already abandoned Housing Element Program 1.A.
Program 1.A. committed the city to "make permanent amendments to the Zoning Ordinance that are currently interim." The Interim Zoning Ordinance referenced by Program 1.A. allowed most code complaint housing projects to be approved with a by-right ministerial process. The interim zoning ordinance was adopted on August 25, 2020.
Meeting minutes available here (Item 7.C):
https://santamonicacityca.iqm2.com/Citizens/FileOpen.aspx?Type=15&ID=1265&Inline=True [santamonicacityca.iqm2.com]
However, when the City Council took this up during their January 25, 2022 meeting they made edits which weakened this provision. Instead of making the interim ordinance permanent, as called for by the Housing Element, the city changed the zoning ordinance to require projects on sites larger than one acre to go through a more discretionary, political process with the Planning Commission. They did so because of pushback against a large project utilizing density bonus law at the corner of Lincoln Boulevard and Ocean Park Boulevard. Meeting minutes available here (Item 7.F):
https://santamonicacityca.iqm2.com/Citizens/FileOpen.aspx?Type=15&ID=1322&Inline=True [santamonicacityca.iqm2.com]
A local press article discussed this change as follows:
"Concerned that such a large project could be approved administratively, the City Council recently voted to require that projects exceeding 1 acre be subject to Development Review." https://www.surfsantamonica.com/ssm_site/the_lookout/news/News-2022/February2022/02_24_2022_NEWS_ANALYSIS_Gelsons_Proposed_Project_a_Done_Deal.html [surfsantamonica.com] City Council did not make this decision blind. As the January 25th meeting minutes indicate, they discussed the possibility of this change causing issues with the state.
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Packet Pg. 1561 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 There are several sites in Santa Monica's Housing Element which are larger than one acre. Because of the actions taken at the January 25th city council meeting, housing projects on these sites will now face a longer, more political approval process than indicated in the Housing Element.
I thought this issue would be noted in at least one of the several revisions of the Housing Element since January 25, 2022. However, despite Santa Monica having many opportunities to do so, they never once updated the Housing Element to say Program 1.A has been effectively abandoned. This creates a misleading picture of what Santa Monica plans to do, and calls into question the city's commitment to all other programs.
I hope you find this information useful. Please feel free to contact me at this e-mail address with any questions.
Regards,
Anonymous
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Packet Pg. 1562 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Friday, September 16, 2022 11:10 AM
To: Jing Yeo
Subject: FW: Santa Monica Housing Element: continued major concern regarding Program 1A Attachments: thank you to HCD for holding Santa Monica accountable on state housing law, and additional 6th Cycle comments
EXTERNAL
FYI
From: Jason Mastbaum <[email protected]>
Sent: Thursday, September 15, 2022 4:09 PM
To: Housing Elements@HCD <[email protected]>; McDougall, Paul@HCD <[email protected]>; Kirkeby, Megan@HCD <[email protected]>; Zisser, David@HCD <[email protected]> Subject: Santa Monica Housing Element: continued major concern regarding Program 1A Hello, in light of the September 6 letter from HCD to Santa Monica regarding its housing element, I'm writing to express a major concern that I still have about Program 1A of the Santa Monica housing element. This is a concern which I first submitted to HCD on February 24 of this year and which I believe HCD may have overlooked in its consideration of Santa Monica's housing element. I’m including a condensed version of what I wrote in February here; for reference, I have also attached the original email to this email as a .eml file.
At the January 25 Santa Monica city council meeting (agenda:
https://santamonicacityca.iqm2.com/Citizens/Detail_Meeting.aspx?ID=1289 [santamonicacityca.iqm2.com]), agenda item 7F sought to modify the city emergency zoning ordinance underpinning Program 1A of the housing element and under which the housing development at 2601-2645 Lincoln Blvd (known locally as “the Gelson’s project”) was approved by:
Changing the ordinance so that the ordinance’s administrative approval would only apply to properties up to 1 acre, and making properties over 1 acre once again get city council approval. Retroactively applying this change to the Gelson’s development (this was clearly stated at the time by While the council was unsuccessful in retroactively applying this change to the Gelson’s project, they were successful (by a 6-1 vote) in passing the change and having it apply to any future project. The version of the emergency zoning ordinance as written *prior to this change* was the core of Program 1A in the draft housing element submitted to HCD in November 2021. When the June draft housing element was submitted following HCD’s February rejection of the November draft, no mention was made of this modification to program 1A.
I believe the city withheld disclosure of this change from HCD *deliberately*, because as I wrote in my February 24 email, the following statements were made at the January 25 meeting:
Mayor Pro Tem Kristin McCowan said that this program was meant to get us through housing element compliance.
Mayor Sue Himmelrich agreed and was very clear that she wanted to keep this program in place only as long as absolutely necessary to get HCD approval for our housing element.
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Packet Pg. 1563 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 Councilmember Gleam Davis (the lone no vote on this amendment of Program 1A) noted that this attempt at retroactively changing what developments qualify for this program was an attempt by Santa Monica to backtrack on its housing element promises before HCD had even made a decision on the housing element (at the time, the February rejection letter by HCD had not yet been received by the city) and was likely a violation of the Housing Accountability Act, for reasons including that the HAA makes no distinctions about lot sizes.
It’s my understanding that HCD is supposed to consider whether or not a city can be trusted as a good-faith actor when deciding whether to approve housing elements and the Santa Monica city council could not have been more clear that they are not, so I wanted to raise this issue again in case my February 24 comment on this matter was in fact missed at the time.
Thank you for your time and consideration,
Jason Mastbaum
P.S. There are two Facebook links to additional comments made by a city councilmember on the platform in the attached original email; the Facebook group has since been taken private but screenshots are included.
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Packet Pg. 1564 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: Jason Mastbaum <[email protected]>
Sent: Thursday, February 24, 2022 9:45 AM
To: Housing Elements@HCD
Cc: councilmtgitems; councilmtgitems; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Sue Himmelrich; Kristin McCowan; Oscar de la Torre Subject: thank you to HCD for holding Santa Monica accountable on state housing law, and additional 6th Cycle comments
Attachments: phil brock santa monica now comment 1.PNG; phil brock santa monica now comment
2.PNG
Hello, I wanted to write to thank HCD both for holding Santa Monica accountable on state housing law and for the acknowledgement of my submissions to HCD on Santa Monica's 6th Cycle housing element in the letter sent to the city by HCD on February 8. It was gratifying to get a direct acknowledgment that the time I spent writing HCD in 2021 was well spent and to know that my comments were able to assist HCD with its critical work enforcing state housing law.
Unfortunately, while I had planned on simply writing a thank you letter after finding out about HCD's decision, in even just the couple of weeks since the letter was sent it has appeared increasingly unlikely that the Santa Monica city council will be able to find the votes to make the necessary changes to bring our city into compliance with state housing law and meet our 6th Cycle RHNA obligation and will in fact be looking for every possible opportunity to subvert the housing element process. As such, I'm writing again to ask HCD to please keep up the good work and continue to hold our city accountable on state housing law. In addition to the fact that the city government not only ignored a large number of suggestions from the public on how to fix deficiencies in the housing element but also removed proposals such as upzoning some of our R1 areas from the draft housing element during the period leading up to the submission of the final version of the housing element trasnmitted to HCD, several recent actions have shown that some city councilmembers are looking to dig in on their refusal to comply with state law, engage in tricks whereby they will tell HCD that the city has programs in place to get housing build which they fully intend to rescind at the first possible opportunity, and even to retaliate against members of the public who wrote HCD in our common cause of holding the city government accountable for its obligations under state law.
This has turned into a bit of a long letter, so I'd like to provide a quick bottom line up front. In the past month, the Santa Monica city council and a number of its individual members have:
Used city council meeting time to intimidate members of the public against submitting comment to HCD on the housing element.
Retaliated against a sitting Housing Commissioner four months before the end of her term for her activity as executive director of Abundance Housing LA, especially her and AHLA's correspondence with HCD on the Santa Monica housing element.
Openly stated on a social media group moderated by one of the councilmembers that
1. Six councilmembers voted in favor of a city council agenda item because they were seeking to retroactively modify the terms of an emergency zoning ordinance which allows for administrative approval of a 521 unit housing development on Lincoln Blvd. This program was also included as program 1A in the housing element transmitted to HCD, and multiple councilmembers made clear during a city council meeting that this program was only intended to be in place for exactly as long as necessary to get certification of our housing element by HCD.
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Packet Pg. 1565 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 2. "Regarding the overall housing element we will not rezone our city further".
Going in chronological order, during the January 25, 2022 city council meeting, Mayor Sue Himmelrich used city council meeting time to complain about members of the public writing into HCD, "every Abundant Housing YIMBY person and their brother will be writing to HCD...if you want I'll share the results of this PRA with you, if we lift an eyebrow they write to HCD and complain." I have spoken to other people who were thanked by name in the February 8 HCD letter for submitting comment and I was not the only one who felt that Mayor Himmelrich's comments about filing a PRA to find out who we are was intended to intimidate us for submitting public comment because she is unhappy about being held accountable by the public on state housing law. As stated in the February 8 HCD letter rejecting our housing element, "public participation in the development, adoption and implementation of the housing element is essential to effective housing planning", so it's disturbing to see our mayor seeking to suppress this crucial public participation. Mayor Himmelrich followed by stating that she was ready to sue the state if our housing element was rejected because she believed it was beyond a doubt compliant--these do not sound like the words of someone who intends to make any serious good-faith changes to the now-rejected housing element.
On February 16, Councilmember Phil Brock wrote on the Santa Monica Now Facebook group (of which he is a moderator and on which he routinely interacts with the public in his capacity as a councilmember) regarding his opposition to the 521 unit (including 53 deed restricted affordable units for very low-income households) mixed use development slated for 2601-2645 Lincoln Blvd. Specifically, he wrote "I tried to make sure the project has to come before Planning and, by appeal, to the City Council by shrinking the size of administrative approval. It appears that my effort on that front, even though it passed City Council by a 6-1 vote has failed".
Councilmember Brock is referring to agenda item 7F from the January 25 city council meeting, which sought to modify the city emergency zoning ordinance under which developments such as this one can seek administrative approval instead of having to get approved the Planning Commission and potentially city council as well. The failure Councilmember Brock is referring to is that the goal of the councilmembers who voted for this agenda item (Councilmember Gleam Davis was the lone no vote) was to retroactively make it so that the 2601-2645 Lincoln Blvd development could not qualify under the emergency zoning ordinance for administrative approval by modifying it to only apply to projects of at most 1 acre (the site is larger than 1 acre), yet be able to simultaneously tell HCD that they didn't rescind a housing development approval streamlining program that will help the city meet its RHNA obligations. This is a remarkable public admission from Councilmember Brock in any circumstance, and doubly so a mere 8 days after receipt of the housing element noncompliance letter from HCD. This also runs directly counter to and indeed seeks to actively subvert the Housing Accountability Act, the comments in item B.2 in the February 8 HCD letter that "address[ing] and, where appropriate and legally possible, remov[ing] governmental and nongovernmental constraints to the maintenance, improvement, and development of housing" is one of the changes necessary to bring the city's housing element into compliance, and as noted by Councilmember Davis in the January 25 meeting that administrative approvals is something the city promised to the state as program 1A in the drafting element transmitted to the state of the 6th Cycle. So in addition to Councilmember Brock's February 16 comments, in the January 25 meeting it was noted by Councilmember McCowan that this program was meant to get us through housing element compliance (which we now know it was insufficient to do so); Mayor Himmelrich was clear that she wanted to keep this program in place only as long as absolutely necessary to get HCD approval for our housing element; and as as noted by Councilmember Davis, this attempt at retroactively changing what developments qualify for this program was an attempt by Santa Monica to backtrack on its housing element promises before HCD had even made a decision on the housing element! This comment by Councilmember Brock is available at
https://www.facebook.com/groups/SantaMonicaNow/posts/5242681159128025/?comment_id=5248298441899 630&reply_comment_id=5259602177435923 [facebook.com] and I have additionally attached a screenshot of this comment to this email.
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Packet Pg. 1566 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 3 On February 18, Councilmembers Phil Brock, Christine Parra, and Oscar de la Torre placed item 13G on the agenda for the February 22 city council meeting to remove Leonora Camner from the Housing Commission 4 months before the end of her term in explicit retaliation for her work as the executive director of Abundant Housing Los Angeles, especially but not only because of her and AHLA's work corresponding with HCD to make sure that Santa Monica's housing element was compliant. This was another clear attempt to suppress public participation in the housing element process. The councilmembers justified item 13G by lying that she was a paid lobbyist and thus has a conflict of interest serving on a city commission. During the February 22 council meeting they made it clear they were not interested in the fact that Commissioner Camner last year asked the city attorney for a review of whether she has any conflicts of interest that would prevent her from serving on a commission, and received a letter from the city attorney certifying that she in fact does not and can serve on the Housing Commission without any legal or ethical concerns.
So in addition to having a majority of councilmembers voting to reatroactively unapprove the rules allowing the development proposal at 2601-2645 Lincoln Blvd, this makes another majority of the city council who have one way or another sought to intimidate people against submitting comment to HCD on the housing element and punish those who have. If any of these councilmembers intended to respond to the February 8 letter rejecting the city's housing element as noncompliant by actually putting in the hard work to fix the deficiencies noted by HCD, why would they instead be wasting time seeking supression of and revenge against those who worked to make sure that HCD recognized that Santa Monica's housing element was not compliant? Finally, on February 20, Councilmember Brock wrote again on the Santa Monica Now Facebook group, this time saying "regarding the overall housing element we will not rezone our city further". Since the city cannot achieve its RHNA obligation without any further rezoning, this is as clear a statement as possible by Councilmember Brock that he has absolutely zero intention of even pretending to make any effort to bring Santa Monica into compliance with state housing law, and that he also believes that he has the backing of a majority of the city council to respond to HCD's findings from the February 8 letter with intransigence. In this post Councilmember Brock also reconfirms that he has previously sought to block the development at 2601- 2645 Lincoln specifically in direct contravention of program 1A of our 6th Cycle housing element. This post by Councilmember Brock can be found at
https://www.facebook.com/groups/SantaMonicaNow/posts/5249963815066426/?comment_id=5263391147057 026&reply_comment_id=5271326146263526 [facebook.com] and as with the other Santa Monica Now comment by Councilmember Brock I have also attached a screenshot of the comment to this email.
Between the attempts at suppressing public participation in the housing element process via both intimidation and targeted retaliation, the dirty tricks with gutting an administrative approval program for housing development without outright repealing it completely so as to be able to tell HCD that the city still has the program while openly admitting the program is only intended to exist exactly as long as necessary to get through 6th Cycle compliance review, and the clear as day statement of zero intention of doing any of the rezoning which the city government knows is necessary to meet its RHNA obligation, it's clear that this city council does not view itself as obligated to comply with state housing law. They have also, again, clearly stated that they will seek any possible avenue for being deemed to be in compliance while being able to gut and eliminate the programs that gained the certification of compliance the moment the ink is dry on the certification.
I hope that HCD will have all of this in mind while continuing to apply close scrutiny of all further submissions by Santa Moncia regarding its progress on meeting its 6th Cycle obligations.
Thank you again for all of your time and hard work,
Jason Mastbaum
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Packet Pg. 1567 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1568 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1569 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Jing Yeo
From: McDougall, Paul@HCD <[email protected]>
Sent: Tuesday, September 20, 2022 2:58 PM
To: Jing Yeo
Subject: FW: Santa Monica Housing Element
Attachments: HCDsanta2.pdf
EXTERNAL
FYI
From: Mathew Millen <[email protected]>
Sent: Tuesday, September 20, 2022 2:33 PM
To: McDougall, Paul@HCD <[email protected]>
Subject: Santa Monica Housing Element
Dear Mr. McDougall.
I submitted opposition to the revised Santa Monica Housing Element and your letter of Sept 6 does not mention my name that my client's opposition was considered. please revoke the approval and take into consideration the City's continued efforts to perpetuate the segregation of minorities in the Pico Neighborhood and FAIURE to AFFH sincerely,
Mathew
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Packet Pg. 1570 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1593 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1595 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1596 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Les Gibbs
To: Housing Update
Subject: Copy of Recording?
Date: Friday, May 27, 2022 9:10:28 AM
EXTERNAL
Hi SM,
~~~Can we get a copy of the ADU presentation from 5/26/22.
Thanks!
Sent from my iPad
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Packet Pg. 1597 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Do Not Reply to This Email
To: Housing Update
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Packet Pg. 1598 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Galit Gottlieb
To: Housing Update
Subject: Housing update on Lincoln and Arizona
Date: Sunday, August 21, 2022 2:09:10 PM
EXTERNAL
To Whom This May Concern,
My name is Galit. I have been on the housing list for 2/3 years. And a long time resident 9th and Arizona. And currently on 10th and Arizona.
There are at least 3 new builds in my current neighborhood. However for some reason I'm being offered the housing out of my neighborhood, in the unsafe area of Pico. I can see one of the new builds from my living room window.
Is there any chance I can be put on the housing list in my long time neighborhood? Please help,
Galit
Sent from Yahoo Mail on Android
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Packet Pg. 1599 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Erik Felix
To: Housing Update; Jing Yeo
Cc: Paavo Monkkonen
Subject: Interested in learning more about your 6th Cycle Housing Element process Date: Monday, April 4, 2022 8:07:51 AM
EXTERNAL
Hello Jing,
My name is Erik Felix and I am a graduate student researcher with the UCLA Lewis Center for Regional Policy Studies. I am working with Professor Paavo Monkkonen on a research project regarding the 6th Cycle Housing Element update process. We are interviewing planners involved with this process in a few cities. Would you be available this month to discuss your experience developing the City of Santa Monica's Housing Element? Please let me know if there's a 30-60 minute window of time that works for you during the following days and times:
Mondays: 9 am - 2 pm
Thursdays: 3:30 pm - 6 pm
Fridays: 9 am - 6 pm
Best,
Erik
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Packet Pg. 1600 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Liberty Justice
To: Housing Update
Subject: Is there any news on my Section 8??
Date: Tuesday, August 30, 2022 3:08:38 PM
EXTERNAL
I've been on the list for about 2 years now. Can you tell me how far I am on the list?? Thank you so much! I appreciate y'all!
Liberty V Justice
CEO, I'm Worth It Inc.
www.youtube.com/channel/UCIamjpPzOhKs8gEtUZkZckw
[email protected] | "Die to self so others can live" Create your own email signature
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Packet Pg. 1601 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 June 9 B Comments
Mathew Millen <[email protected]>
Tue 5/31/2022 12:50 PM
To: Planning <[email protected]>;Planning Commission Comments <[email protected]> 1 attachments (1 MB)
9Bergamot.pdf;
EXTERNAL
Attachments are comments regarding item 9B for 1 June meeting
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Packet Pg. 1602 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1629 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Agenda Item 9B (Housing Element)
Kenneth Kutcher <[email protected]>
Tue 5/31/2022 4:49 PM
To: Mario Fonda-Bonardi <[email protected]>;Nina Fresco <[email protected]>;Leslie Lambert <[email protected]>;Shawn Landres <[email protected]>;Jim Ries <[email protected]>;Ellis Raskin <[email protected]>;Samuel Tolkin <[email protected]> Cc: Wendy Radwan <[email protected]>;David Martin <[email protected]>;Jing Yeo <[email protected]>;Heidi von Tongeln <[email protected]>;Susan Cola <[email protected]>;Rachel Kwok <[email protected]>;Planning Commission Comments <[email protected]>
1 attachments (243 KB)
Housing Element Ltr to PC.pdf;
EXTERNAL
Dear Commissioners,
The attached comments about the Housing Element are being submitted on behalf of the Santa Monica Housing Council.
Ken
Kenneth L. Kutcher | Attorney at Law
1250 Sixth Street, Suite 200 | Santa Monica, CA 90401
O: (310) 451-3669 | [email protected]
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Packet Pg. 1630 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) (310) 451-3669
May 31, 2022
VIA E-MAIL
Santa Monica Planning Commission
1685 Main St., Room 212
Santa Monica, CA 90401
Re: Agenda Item 9B (Housing Element discussion)
Our File No. 639.67
Dear Commissioners:
This letter is submitted on behalf of the Santa Monica Housing Council (“SMHC”).
As you may know, the Santa Monica Housing Council has filed a lawsuit in Los Angeles County Superior Court against the City for the City’s failure to adopt a legally compliant Housing Element. (LASC Case No. 22STCV11610.)
The lawsuit also challenges the City’s failure to implement Housing Element Programs 1.A (by-right approvals for housing projects), 1.F (revised the DCP standards to support housing projects), 1.J (rezoning by revising development standards to ensure that housing projects are feasible and incentivized over commercial development), and
2.D (update the City’s Density Bonus Ordinance to ensure consistency with State law).
All four of these important Housing Element Programs were to be implemented no later than March 31, 2022. That did not happen. Nothing in the City’s Housing Element states that implementation is contingent upon HCD certification.
The lawsuit also challenges the City’s failure to comply with the State Density Bonus Law, including as to: (i) the City’s failure to amend its Ordinance to reflect the percentage increases for density bonuses, (ii) the City’s refusal to grant statutory bonuses for Tier 2 housing projects, and (iii) the City’s failure to adopt timelines for processing density bonus applications. These are clear obligations to facilitate housing production under State law. The City has no choice in the matter.
The City is not doing what it needs to do to facilitate more housing production and to comply with State law as to encouraging housing production during the Statewide housing crisis.
[email protected]
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Packet Pg. 1631 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
The City Needs to Raise Heights and FARs for Housing
in its Commercial Districts Without Delay
We have read the June 1, 2022 Staff Report. In our opinion, the Staff Report gives confusing mixed messaging as to the City’s undeniable need to increase allowable heights and FARs for housing projects in the Downtown and the commercial boulevards. (See Staff Report, p. 4 (“HCD is seeking firm commitments on number of units and allowable densities in the revised Housing Element programs such that the language providing flexibility for the City to adjust a range of FARs may not be acceptable.”) and p. 2 (“This report presents updated recommendations on FAR and height that form the basis of the increased overall housing capacity necessary to respond to HCD’s comments”).)
City Staff appears to be trying to forestall and corral this critically important discussion, which (for good reason) was well underway at the Planning Commission before City Staff’s decision to push it off. (See Staff Report, p. 2 (“With the receipt of HCD’s comments, rezoning efforts that were brought forward to the Planning Commission were put on hold pending revisions to the Housing Element.”).) The City needs to facilitate more housing production, and yet the City is putting on the breaks for upzoning as months continue to pass by.
The City Needs to Identify and Mitigate its Numerous
Regulatory Constraints to Housing Production
City Staff continues to push back on its legal duty to identify and mitigate governmental constraints. (Gov’t Code § 65583(a)(5) & (c)(3).) The current Staff Report continues to avoid such a discussion. (See Staff Report, p. 2 (“Given the need to first prepare revisions necessary to respond to HCD’s comments to achieve a compliant Housing Element (i.e. the policy document), staff has not analyzed specific zoning recommendations as those will be deferred for future discussion on Housing Element implementation [emphasis added].”).) This approach is at variance with State Housing Element Law’s requirement that the governmental constraints analysis must happen as part of the Housing Element, not afterwards.
The HR&A Feasibility Modeling Remains Fundamentally Flawed In the rare instances of actually committing to reduce a governmental constraint (e.g., reducing the parking requirements for housing and allowing residential units on the ground floor), City Staff has directed HR&A to update its “feasibility modeling” to take those mitigating factors into account for feasibility purposes rather than considering those regulatory changes to be tools to encourage more housing production. (See Staff
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Packet Pg. 1632 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
Report, p. 4 (“On February 2, 2022, City staff presented new FARs and heights for rezoning based on updated financial feasibility analyses prepared by HR&A, Advisors Inc. The updated analyses were prepared in response to Planning Commission’s request to update the original analyses[1] based on revised assumptions of reduced minimum parking requirements and allowing residential units on the ground floor.”).) The more fundamental concern with the HR&A analysis that did come up during the February 2, 2022 hearing was the failure to account for economic downturns, apparently based on instructions provided to HR&A by City Staff (who are not economists). The economic world has turned upside down, and yet the financial modeling upon which City Staff is relying does not even attempt to take any of that turmoil into account. Below is a transcription of this troubling revelation.
Landres: Because Commissioner Raskin went there, I want to ask the question. The HR&A testing, these are certainly interesting findings. I think it would certainly be helpful to understand the range of the pro formas that were used to achieve them.
Specifically, what I would like to know, because these are large numbers, is how sensitive they were to inflation and the currently volatile interest rate environment, and whether or not those numbers are truly sustainable. Like, they might have been sustainable at the time they did the testing. Are they going to be sustainable six months from now?
And I think it would be, I’d just like to ask Staff that to the extent that you are obviously going to bring these numbers forward, because you want to share the data with Council, because it’s really important that the decision makers
understand just how sensitive or how insensitive they are in an extremely volatile economic environment. Because they might look good now, but they might not look so good in a year. And we have an eight year housing plan.
2:06:54
Yeo: I’m going to have someone from the HR&A team, I wonder if you can address that. I will say, generally speaking, as 1 I don’t remember such a request coming from the Planning Commission, but perhaps I am mistaken.
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Packet Pg. 1633 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
you’re well aware, when we do these analyses they’re never sort of extremes on one end or the other. They tend to have an approach that accounts for that sort of variation, but perhaps Paul or on someone on the HR&A team can speak
to that.
Silvern: Good evening Commissioners, this is Paul Silvern, partner with HR&A Advisors. As we noted in our summary of
modeling assumptions that we presented to the technical working group about a year ago almost, all of our modeling assumptions are based on pre-pandemic economic
circumstances. [Emphasis added.]
So, we tried to make sure that we were not accounting for what was happening during the pandemic period, and
therefore, the assumptions are more closely associated with first quarter 2020 market conditions. And that includes all the modeling parameters; inflation per se is not one of the modeling assumptions. [Emphasis added.]
2:08:14
Landres: Okay, can I follow up with that, Chair?
Ries: Yes, please do.
Landres: Okay, so Mr. Silvern, Paul.
Silvern: Yeah.
Landres: Help me think about this. The world has changed substantially. In the context of what we’re looking at, we have broken supply chains. We have substantial inflation.
We probably have some serious work labor inflation. We
have interest rates going up and not looking like they’re coming down.
And I’ll be frank, the risk of getting this wrong is that we won’t produce and then we will get SB35’d, and then Santa Monica will lose all of its discretionary--we’ll lose a lot of discretionary control.
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Packet Pg. 1634 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
So, if you have any information you can share with us based on the work that you’ve done more recently, maybe not for Santa Monica, maybe for other people, that gives us a sense of where things are headed. Because now that you share
that, I’m extremely nervous relying on pre-pandem--I mean I’m just really nervous relying on pre-pandemic economics.
Silvern: As I think Jing tried to say, we cannot account for year to year variation that will undoubtedly occur over an 8½ year planning period. We don’t have any better crystal ball than you do. But we do follow a lot of the economic trend
information emanating from everyone from the
Congressional Budget Office to the Federal Reserve to the UCLA Anderson quarterly economic forecast.
The general consensus, I believe, is that while we are
experiencing a period of elevated inflation caused by a variety of different circumstances, that those circumstances will work themselves out over the coming year or so. So we would not expect all the supply chain problems that are causing inflation, and we would not expect all of the labor shortages that are driving up wage rates to continue
indefinitely. Like the pandemic, we view it as a temporary economic problem that will sort itself out over time. And that developers looking to build will accommodate
circumstances, as they always do.
2:11:02
This approach to the feasibility modeling is in stark contrast with the City’s financial status update to its biennial budget:
The FY 2022-23 Proposed Budget, the second year of the
City’s FY 2021-23 Biennial Budget for operating
expenditures, is an important milestone in the City’s gradual recovery from the disruption and economic losses that
accompanied the COVID-19 pandemic. Despite frequent
budget amendments to restore services incrementally as
revenues slowly recover, a large portion of the reductions in programs and services, facility maintenance, and capital improvement projects made in the beginning of the
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Packet Pg. 1635 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
pandemic continue. Data indicates that the City continues to recover. At the same time, the City, like the entire country, is projected to experience significant cost increases coming from the highest levels of inflation in forty years, supply chain issues, other market disruptions occurring as a result of the war in Ukraine, and adjustments to staff compensation
increases.2
* * *
As noted above, while economic recovery is happening, the disruption that began two years ago is still affecting the global economy and has resulted in continued severe
revenue loss for the City. While revenues continue to
recover faster than previously projected, coronavirus
variants continue to emerge and threaten to slow down
economic activity.
3 * * *
[T]he Russian invasion of Ukraine as well as inflation and the appearance of new COVID-19 variants have added new
layers of uncertainty to the overall economic recovery.
GDP unexpectedly declined 1.4% in the first quarter of 2022, and a recent Bloomberg survey of economists now projects
3.2% growth for all of 2022 followed by slower growth of around 2% for the following two years. Despite the low
unemployment rate, labor force participation has not
recovered to pre-pandemic levels and many employers are finding it difficult to attract and/or retain workers. Inflation has risen to the highest level in four decades, and supply chain issues are causing disruption, all of which could further hamper growth.
4 2 City Council Staff Report (Agenda Item 4.B, May 24, 2022), pp. 1-2; emphasis added.
3 Id. at p. 6; emphasis added.
4 Id. at p. 9; emphasis added.
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Packet Pg. 1636 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
See also Timber Briefing: U.S. Lumber Prices Could Be Affected by Sanctions on Russia, K&L Gates LLP (May 23, 2022) (“The U.S. lumber market has seen unprecedented price rises in recent years. Prices could climb even higher as the world responds to the conflict between Russia and Ukraine. Russia is a major exporter of wood in the global market . . .”).
We anticipate that City Staff has never informed HCD of this fundamental economic flaw in their feasibility modeling of new heights and FARs, just as the City has concealed HR&A’s assumptions from us when responding to our very specific and straightforward Public Records Act request for the assumptions the City directed HR&A to use in its analysis. What did we receive back from the City? Hundreds of pages of redacted text with no explanation. (This reduction was generated by the City long before any litigation had been filed.) Following is a link to some of the secretive “disclosure” pages we received from the City, which purports to pride itself on transparency. City Redactions as to HRA Assumptions
We would ask the Planning Commission to ask City Staff for a clear and comprehensive list of the economic assumptions HR&A has been directed to employ with its housing feasibility analysis, keeping in mind that the point should be to incentivize housing production not simply make it technically feasible. The City’s secretive approach to withholding disclosure of the assumptions on which the recommended heights and FARs are based is quite concerning.
At least as important as updating the Housing Element EIR (at a cost of $367,386) is the need to update the HR&A feasibility modeling to truly account for today’s economic conditions and forecasting. Otherwise, the City is deluding itself and HCD with its fundamentally flawed analysis. A legitimate economic analysis of how to incentivize housing production (rather than simply assessing feasibility) would be much more productive than will undertaking additional CEQA analysis.
The City’s Suitable Sites Inventory Is Unreliable
As to its Suitable Sites Inventory, the Staff Report acknowledges: “HCD’s letter states that further revisions are necessary to demonstrate that the sites on the City’s Suitable Sites Inventory (SSI) are realistic and have demonstrated potential for housing development.” (Staff Report, p. 3.) However, City Staff continues to resist the repeated suggestion from SMHC that HR&A should be authorized to privately interview longstanding local commercial property owners to ascertain what it would take to incentivize them to change from continuing the existing commercial uses on their properties.
Instead, City Staff still wants to go at this question in a roundabout fashion:
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Packet Pg. 1637 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
1) Providing evidence from past and current projects that the land improvements value ratio, age and size of building, size of site, and tenancy are valid factors to utilize for identifying redevelopment potential
2) Including a discount factor to account for the probability of non-residential uses occurring on a SSI site based on historical trends 3) Providing a flow chart that clearly shows the methodology used to identify sites and how the capacity of sites was calculated
4) Providing tables and maps that show income levels of SSI units by AFFH metrics5
As HCD has already indicated, the SSI’s reliance on turnover of commercial properties is not realistic, and this comes directly back to the need for more impactful increases in allowable heights and FARs for housing in commercial districts.
The City’s CEQA Analysis Needs to Study Higher Potential Maximum Heights and FARs to Ensure the Policy-Makers
Have Sufficient Decision-Making Flexibility
At pages 7-8 the Staff Report includes four different FAR scenarios for commercial/industrial zoning districts. It is not clear what heights and FARs will be evaluated in the supplemental CEQA analysis.
In order to preserve decision-making flexibility for policy-makers, it is important that the CEQA analysis include a range of potential heights and FARs and that the scenarios studied do not constrain the discretionary powers of the decision-makers from making the necessary increases in heights and FARs to actually incentivize housing.
The Planning Commission should ensure that the heights and FARs being studied for purposes of CEQA are sufficiently aggressive.
The Staff Report’s Draft Rezoning Comparison Is Misleading The Staff Report includes a proposed chart for the Housing Element comparing the existing FARs with placeholders for the new FARs. We think this chart would be misleading without also including the Tier 2 FARs (and Tier 3 in the case of TA in the Downtown). Tier 2 (and Tier 3) FARs should be added to this chart. 5 Staff Report, p. 3.
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Packet Pg. 1638 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
Housing on City-Owned Sites Needs Much Stronger Commitment As the Staff Report notes, “HCD’s comments state that given the reliance on City-owned sites to accommodate nearly a third of the RHNA’s affordable unit allocation, far greater commitment from the City to facilitate development on city-owned sites would be needed.” (Staff Report, p. 10.)
We reserve judgment on the 338 affordable units assumed for 4th/5th/Arizona, the 707 affordable units assumed for Bergamot Arts Center and the 605 affordable units assumed for the Main Street parking lots6--except to point to the City’s recent failures to develop Bergamot (after 8 years with developer Worthe Real Estate Group) and 4 th/5th/Arizona (after 7 years with Clarett West Development) and the well-meaning but farfetched idea of high density housing on the Main Street parking lots in the Coastal Zone behind a number of historic resources. As the Staff Report acknowledges:
“[N]ote that if minimum number of units for each city-owned site is not met, then those affordable units must be made up elsewhere in the City, which would potentially mean required [further] upzoning on private property to make up affordable unit capacity.” (Staff Report, p. 11.)
We fail to comprehend why the City would think that 100% affordable housing (without any market rate housing to offset the affordable housing subsidy) would lead to the “Identif[cation of] any possible partners that would develop 100% affordable housing.” (Staff Report, p. 11.) This sounds implausible to our client.
Conclusion
Based on the foregoing, our client urges the Planning Commission to:
• Insist on returning to its recommendations as to aggressive increases in heights and FARs for housing in commercial districts to incentivize housing over commercial development or continuation of existing commercial uses, thereby avoiding housing pressures in existing residential neighborhoods. • Identify and mitigate governmental constraints as part of the Housing Element, rather than improperly deferring this discussion to implementation. • Direct City Staff to publicly disclose the modeling assumptions HR&A was directed to use in its feasibility analysis.
6 Staff Report at p. 10.
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Packet Pg. 1639 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
May 31, 2022
• Urge HR&A to take into account today’s economic woes in its feasibility modeling.
• Urge HR&A to privately interview long-time local commercial property owners to assess what it would take to incentivize them to put their properties into residential use.
• Ensure that the height and FAR scenarios studied for compliance with CEQA will provide the City decision-makers with sufficient policy-flexibility to adopt the new heights and FARs needed to incentivize housing in the commercial and industrial zones. (See Mar. 2, 2022 Memorandum from Commissioners Fresco, Lambert and Landres (about which there seemed to be general consensus on the Planning Commission).)
• Consider a realistic mix of market-rate and affordable housing on City-owned sites to attract reputable private entities to partner with the City on redeveloping those sites.
Very truly yours,
Kenneth L. Kutcher
KLK:sna
cc: David Martin
Jing Yeo
Heidi von Tongeln
Susan Cola
Megan Kirkeby
Shannan West
John Buettner
F:\WPDATA\639\639.67 (Santa Monica Housing Element 2021)\Cor\PC 2022.05.31.docx
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Packet Pg. 1640 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1641 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) (310) 451-3669
June 15, 2022
VIA E-MAIL
Santa Monica Planning Commission
1685 Main Street, Room 212
Santa Monica, CA 90401
Re: Agenda Item 9A (Housing Element)
Our client: Santa Monica Housing Council
Our File No. 639.67
Dear Commissioners:
This letter is submitted on behalf of the Santa Monica Housing Council (“SMHC”).
Below are SMHC’s comments on the redlined Programs. Attached are SMHC’s comments on the continuing deficiencies of the Constraints analysis (i.e., Appendix E).
Programs 1.F and 1.J
SMHC generally supports the currently proposed residential and mixed-use FARs and heights being recommended for the “non-residential” zoning districts. With the Planning Commission’s urging, we think the City has made progress with those thresholds in order to encourage future housing development. And we strongly support the need for incorporating those FARs and heights directly within Programs 1.F and 1.J of the Housing Element. We also support the October 15, 2022 timeframe for implementing those FARs and heights.
For purposes of clarification, Programs 1.F and 1.J should expressly include reference to “height,” not just the “FAR,” in their respective sentences leading into the charts of new heights and FARs. Specifically, for Program 1.F, the sentence above the chart on page 6 of the Chapter 5 redline should be revised to read as follows: “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.” (Addition shown in underlined text.) Similarly, for Program 1.J, the sentence above the chart on page 9 of the Chapter 5 redline should be revised to read as follows: “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.” (Addition shown in underlined text.) We assume the omission about height was inadvertent.
[email protected]
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Packet Pg. 1642 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
June 15, 2022
The main problem with Programs 1.F and 1.J is that they unlawfully defer a carefully examination and mitigation of many of the Zoning Code’s constraints to housing production besides height, FAR and parking. Tellingly, the last paragraphs of Programs 1.F and 1.J, respectively, make this deferral clear:
“In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees and design
standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight
plane adjacent to existing residential neighborhoods.”
(Program 1.F; emphasis added.)
“In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix
requirements, and design standards such as restrictions on ground floor residential use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods.” (Program 1.J; emphasis added.)
As discussed in the accompanying attachment, the Housing Element is legally required to identify all governmental constraints and identify corresponding mitigation measures, but Appendix E essentially remains unchanged and continues to be woefully deficient.
Moreover, SMHC does not understand why “unit mix requirements” are called out as a constraint outside the Downtown but not within the Downtown. The unit mix requirement is a constraint both within and outside the Downtown. There is no basis for distinguishing between the two.
Program 1.D
SMHC supports the adoption of the Parking Overlay 1 minimum parking requirements for all housing projects as provided in Program 1.D. But SMHC does not understand the reason for delaying that simple change all the way until June 30, 2023.
Such a delay would make no sense.
The Parking Overlay 1 rates are already codified in the Zoning Code. It should be simple and easy to implement Program 1.D by October 15, 2022, when the new heights and FARs will be implemented. Indeed, HR&A’s feasibility analysis of heights and FARs assumes the parking reductions for purposes of its February 2022 analysis. What is the
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Packet Pg. 1643 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
June 15, 2022
reason for the delayed implementation of this parking relief? No reason is given in the Staff Report. Please change the implementation date for Program 1.D to October 15, 2022.
Program 2.D
SMHC also supports and stresses the importance of Program 2.D: i.e., update the City’s Density Bonus Ordinance to ensure consistency with State Law. This requirement for the City to comply with State Law is long overdue. It should be implemented immediately. SMHC is disappointed that the City has not done so already.
Furthermore, with respect to Program 2.D, SMHC strongly supports the intention for the Municipal Code to “set forth a voluntary by-right menu of incentives & concessions that do not require following the process under Government Code Section 65915(d) for approval.” (Ch. 5 redline, p. 16.) SMHC continues to urge that the by-right menu should be “robust” as consistently recommended by the Planning Commission.
Finally, if the Affordable Housing Production Program (“AHPP”) is going to impose a 15% inclusionary obligation consisting of 5% very low/5% low/5% moderate, then the City’s density bonus ordinance should count all 15% towards eligibility for density bonuses. Program 2.D should be amended by the Planning Commission to address this potential underhanded strategy that otherwise would severely undercut the State Density Bonus Law.
Program 2.C
SMHC is concerned about Program 2.C (i.e., update the City’s AHPP to increase the number of affordable housing units at all income levels). Specifically, SMHC objects to the City’s previously published intention to require that the new 15% inclusionary requirement must be evenly distributed between 5% very low, 5% low and 5% moderate income categories. This distribution is clearly intended to undercut the City’s obligation to grant density bonuses:
Himmelrich: But regardless of 10% or 15% [inclusionary], the State Density Bonus Law will give 50% bonus, so all of these four stories, whether it’s a 10% or 15% are going to be six stories, right? And the FAR will also be more, right? Because they get less setbacks, etc. etc., right?
Yeo: Yeah, they would be entitled to, as we indicated, incentives and concessions. They would be allowed to request relief from that if necessary to support the on-site affordable housing.
Brock: Is there any way to counter that?
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Packet Pg. 1644 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Santa Monica Planning Commission
June 15, 2022
* * *
Yeo: So, 15%, we ran this analysis assuming evenly split between 5% very low income, 5% low, and 5% moderate. So now I’m going to show you the Government Code and please just bear with me here.
These are the tables in the State Density Bonus Law. So if I did 5% very low income, I get a 20% density bonus. And if I did 5% low income, I can’t get any less than 20. Does that make sense? So, it’s sort of like if we split them among those different levels, it gets you overall like more affordable units, although they’re at different levels and that would be a way to potentially temper the State Density Bonus’ application to this.
Brock: Alright, so I would like to do that then.
See June 15, 2021 City Council Hearing beginning at 4:40:33.
If the City is going to impose a mandatory distribution of the 15% between various levels of affordability, the distribution should reflect the City’s RHNA distribution:
The RHNA allocation is 2,794 very low units, 1,672 low and 1,702 moderate, or 45.3% very low, 27.1% low and 27.6% moderate. This equates to a 7.5% very low/3.75% low/3.75% moderate distribution, not 5%/5%/5%. Alternatively, a housing applicant should be able to count all required inclusionary units towards density bonuses under the City’s revised local density bonus ordinance, regardless of their City mandated affordability split. Or another approach would be to allow applicants to elect to provide all 15% as very low or low income units, at the applicant’s choice.
Because the Staff Report was only made available for public review late last Friday afternoon, we reserve the right to supplement these comments at a later time.
Very truly yours,
Kenneth L. Kutcher
Enclosure on Constraints
cc: David Martin (w/ encl.)
Jing Yeo (w/ encl.)
Heidi von Tongeln (w/ encl.)
Susan Cola (w/ encl.)
Megan Kirkeby (w/ encl.)
Shannan West (w/ encl.)
John Buettner (w/ encl.)
SMHC Boardmembers (w/ encl.)
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Packet Pg. 1645 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 APPENDIX TO SMHC HOUSING ELEMENT COMMENTS
GOVERNMENTAL CONSTRAINTS
Appendix E of the Housing Element still fails to undertake a serious analysis of Santa Monica’s local governmental constraints affecting the production of housing. Appendix E does not critically examine the numerous local regulatory barriers and burdens to housing production, including various land use controls, fees and exactions, processing and permit procedures, codes and enforcement, and on-/off-site improvements. As a result, the Housing Element Programs do not sufficiently remove or mitigate local constraints to achieving Santa Monica’s RHNA obligation of 8,895 units of new housing during the 6th Cycle.
The purpose of the local governmental constraints analysis is to inform the development of effective programs. HCD’s February 8 rejection determination reiterates this requirement and purpose:
“As noted in Findings A3, the element requires a complete analysis of potential governmental and nongovernmental
constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.” (HCD
Appendix (Feb. 8, 2022), p. 5.)
The Housing Element sidesteps this vital requirement. Santa Monica will never achieve its RHNA obligation if it is not willing to own up to its existing and proposed constraints.
This is a fundamental problem that the City has refused to address.
The City’s Housing Element unlawfully defers its constraints analysis into Programs 1.F and 1.J for future evaluation, rather than using the programs to concretely explain exactly how the City will remove or mitigate the local governmental constraints that already should have been identified and fully evaluated, both individually and cumulatively. Indeed, Appendix E expressly acknowledges this deferral of the legally required analysis:
“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.” (Appendix E, p. E-10.)
As previously identified by HCD, this song and dance routine does not satisfy Government Code Section 65583(a)(5) of State Housing Element Law.
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Packet Pg. 1646 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 Land Use Controls
Overview
In rejecting Santa Monica’s October 2021 Housing Element, HCD correctly noted:
“Land Use Controls: The element generally describes
programs that were added to address constraints. However, those programs do not include specific commitment to
remove or modify standards and generally commit to only review and change land use controls if necessary. Instead, the element update should review or analyze those land use controls and programs should specifically commit to address constraints. Please see HCD’s prior review for additional information.” (HCD Appendix (Feb. 8, 2022, p. 3.)
Santa Monica’s Housing Element still falls far short of this direction. As the latest redline of Housing Element Appendix E demonstrates, the City of Santa Monica made feeble and inadequate attempts to gloss over its shortcomings as to the need to comprehensively evaluate its land use controls affecting new housing production.
The extent of the City’s analysis of land use controls affecting housing production is essentially limited to the following:
“[C]urrent 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.” (p. E-10.)
Deferred Governmental Constraints Analysis
The City has deferred a comprehensive analysis of the impact of its land use regulations. (See Programs 1.F and 1.J.) Tellingly, as to the Downtown, Program 1.F reads in part:
“In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production including but not limited to development impact fees and design
standards such as restrictions on ground floor residential
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Packet Pg. 1647 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 3 use, minimum/maximum ground floor height, and daylight plane adjacent to existing residential neighborhoods.”
(Adopted Housing Element, p. 121.)
This commitment in Program 1.F to undertake (in the future) review and evaluation of potential constraints should have already been done in the Housing Element analysis of local governmental constraints; deferring such analysis until after the Housing Element’s adoption is unlawful.
Similarly, as to the commercial zoning districts outside of the Downtown, Program 1.J reads in part:
“In addition to FAR and height, the City shall review and modify as appropriate all standards and regulations that may be considered a constraint to housing production, including, but not limited to, development impact fees, unit mix
requirements, and design standards such as restrictions on ground floor residential use, minimum/ maximum ground
floor height, and daylight plane adjacent to existing
residential neighborhoods.” (Adopted Housing Element, pp. 124-125.)
Again, this review and evaluation of potential constraints should have already been done in the Housing Element’s analysis of local governmental constraints, but was not.
Moreover, it is inconceivable that Santa Monica’s unit mix requirements [i.e., prescribed percentages and ratios of studio, one, two and three-bedroom units] are potential constraints in the commercial zoning districts outside of the Downtown but would not be constraints within the Downtown (where there are also unit mix requirements). (See discussion immediately below.)
Prescriptive Bedroom Mix
A substantial constraint on multi-family housing production in nonresidential zones is the City’s insistence on prescribing bedroom-mixes for the new units. It is important to recall that when the City previously released its draft redlines of recommended Zoning Ordinance amendments to implement the Housing Element, the City revealed its intention to impose bedroom-mix requirements on all housing projects in commercial districts. (See September 8, 2021 Planning Commission Redline of Zoning Ordinance Amendments at pdf pp. 122-123.)
Housing Accountability Act
Yet another example of how the City discourages new housing production is the City’s reversal of its legal position regarding whether the Housing Accountability Act (“HAA”) (Gov’t Code § 65589.5) protects housing projects that need modifications or waivers from various overly prescriptive regulations (like ground floor minimum and maximum heights that simply do not work for grocery stores).
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Packet Pg. 1648 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 4 In this regard, on August 20, 2018, the Santa Monica Planning & Community Development Director and the City’s Housing & Economic Development Director jointly issued an Information Item to the Santa Monica City Council that included a decisiontree showing that the HAA protects housing projects once they are granted CUPs, variances, modifications or other such deviations from the Code. (See City Council Information Item (Aug. 10, 2018), p. 9.) But less than one month later, the City’s Planning Division Manager issued a Planning Commission Staff Report regarding the HAA and included a new decision-tree showing the opposite conclusion and denying HAA protections for such housing projects. (Planning Commission Supplemental Staff Report (Sept. 5, 2018), p. 2.) This change unquestionably impedes new housing production because--given the City’s hyper-prescriptive zoning regulations--waivers and modifications are frequently necessary for new housing projects.1 The City’s attempts to undercut the HAA are also reflected in the Downtown Community Plan’s arbitrary deviation from the HAA definition of what constitutes a mixed-use housing project. (See DCP Section 9.10.050(A)(2) versus Gov’t Code § 65589.5(h)(2)(B).)
Fees and Exactions
As HCD directed:
“Fees and Exaction: The element generally describes that typical development on identified sites will not require a conditional use permit and therefore no analysis of planning fees as potential constraints is necessary. However, the element should evaluate fees as constraints regardless of the RHNA or identified sites. Please see HCD’s prior
review.” (HCD Appendix (Feb. 8, 2022), p. 3.)
The Housing Element’s evaluation of impact fees on new housing development ignores the City’s intention to load up higher impact fees and exactions on housing projects to a greater degree than commercial projects, thereby disincentivizing housing as compared to commercial development (and existing commercial uses). In this regard, when the City issued its redline of recommended Zoning Ordinance amendments to implement the Housing Element programs, the redline included the following new requirements for housing projects receiving streamlined review:
9.31.165 Housing Projects
This section establishes requirements for housing projects; however, 100% affordable housing projects are exempt from A through E of this section. 1 For example, waivers and/or modifications (SMMC ch. 9.43) are typically needed for the development of sloping lots, which are common in Santa Monica.
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Packet Pg. 1649 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 5 B. Affordable Housing Commercial Linkage Fee. Applicants proposing mixeduse projects shall pay a fee 14 percent above the base fee as required by Chapter
9.68, Affordable Housing Commercial Linkage Fee Program.
C. Transportation Impact Fee. Housing projects shall pay an additional Transportation Impact Fee (TIF) 14 percent above the base fee required by Chapter 9.66, Transportation Impact Fee Program.
* * *
E. Transportation Demand Management. Housing Projects shall include the following Transportation Demand Management measures in addition to those required by Chapter 9.53, Transportation Demand Management:
1. For non-residential components of projects, provide the following:
a. A Transportation Allowance equivalent to at least 75% of the cost of a monthly regional transit pass, in accordance with Section 9.53.130(B)(2)(b)(viii). b. Bike valet, free of charge, during all automobile valet operating hours.
2. For residential components of projects, provide the following:
a. A Transportation Allowance equivalent to at least 75% of the cost of a monthly regional transit pass, in accordance with Section 9.53.130(B)(2)(c)(iv). b. Free on-site shared bicycles intended for resident and guest use. This shall be optional if Citywide bikeshare is available within a 2-block radius of the project site.
See September 8, 2021 Planning Commission Redline of Zoning Ordinance Amendments at pages 123-125 of the pdf.
The City is clearly attempting to hide these recommended fee and exaction increases that will be imposed on housing and mixed-use housing projects. These increases will, to at least some extent, undercut FAR and height increases and encourage retention of existing commercial uses. And yet these fee and exaction increases on housing are not disclosed or evaluated by the Housing Element’s constraints analysis.
Codes and Enforcement.
The City’s Unique “High-Rise” Definition
The City eventually added to its constraints analysis that as part of its local amendments to the California Building Code, Santa Monica defines any building with occupancy above 55’ to be a “high-rise” (Chapter 5, Section A(4)(b)) notwithstanding the State’s definition setting 75’ for that purpose. Health & Safety Code § 13210(b), 2019 Cal. Bldg. Code § 202.) (Appendix E, p. E-44.)
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Packet Pg. 1650 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 6 This local change in the definition first arose in November 1995. (Resolution No. 8967 (CCS).) The Resolution was based on, and we are not making this up: (a) the “close proximity” to multiple fault lines, (b) the number of “older structures” that are “prone to the quick spread of fire,” (c) “Santa Monica’s climate is primarily influenced by the Pacific Ocean and is characterized by infrequent rainfall and winds which come from the west during the daytime and from the north and northeast during the nighttime, with intermittent Santa Monica winds occurring from September to March,” (d) “structures in the City are situated in close proximity to each other” on lots that “are often very narrow or on hilly terrain,” and (e) “the need for emergency fire services . . . following a future earthquake.” These were the findings “unique to Santa Monica” that were invoked to justify the change to a 55’ definition of high-rise buildings.
For purposes of housing production, this is an extremely important local deviation from State Codes. It means that it will be financially infeasible for many housing projects to avail themselves of the added height above 55 feet.
It is simply implausible that the affluent and proactive City of Santa Monica has an objective and unmitigable health and safety need to adopt a much lower definition of high-rise than applies up and down the State, including in the nearby cities of Culver City, Beverly Hills and Los Angeles (including nearby Venice).
On-Off-Site Improvements
As the Planning Commission well knows from its lengthy Statements of Official Action for mixed-use housing projects, the City of Santa Monica regularly imposes numerous burdens, including on-site and off-site improvements, on new housing projects in Santa Monica. This includes street repaving, replacement of sidewalks, curbs and gutters, installation of street trees and street lighting, telecommunications vaults and conduit, etc.
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Packet Pg. 1651 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Vernice Hankins
From: Clerk Mailbox
Sent: Thursday, June 16, 2022 11:26 PM
To: councilmtgitems
Subject: FW: Housing Commission Recommendations to City Council regarding Draft Redline Revisions to the Adopted 6th Cycle Housing Element Update
From: Leonora <[email protected]>
Sent: Thursday, June 16, 2022 9:07 PM
To: Theresa Marasco <[email protected]>; leslielambert92 <[email protected]>; Council Mailbox <[email protected]>; Clerk Mailbox <[email protected]>; Planning Commission Comments <[email protected]>
Subject: Housing Commission Recommendations to City Council regarding Draft Redline Revisions to the Adopted 6th Cycle Housing Element Update
EXTERNAL
Below please find the recommendations passed by the Housing Commission on 6/16/22. - Ensure affordable housing is not just a paper exercise and obtain revenue sources to make affordable housing a reality, inclusive of increased efficiency in the current budgetary process, and more robust resources for affordable housing.
- Prioritize affordable housing in historically blue and green lined neighborhoods. - Inaction has contributed to the segregation that exists and the City should take meaningful action to physically redistribute affordable housing equitably across the city. Steps are long overdue. There are no neutral actions and the City cannot fail to act.
Leonora Camner
Housing Commissioner
On Behalf of Santa Monica Housing Commission
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Packet Pg. 1663 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) REPEAL ARTICLE 34 in the CA state constitution; USE public land for PUBLIC GOOD, end systematic housing violence & displacement. Article 34 of the CA constitution reads; “No low rent housing project shall hereafter be developed, constructed, or acquired in any manner by any state public body until, a majority of the qualified electors of the city, town or county, as the case may be..”
Localities that have been abusing their positions and segregating cities by race & class should not decide what happens to public land. Workers that commute into cities also have the right to decide what happens to public land, retirees, college students, and many others also have that right!
“Heidi Marston resigns from LASHA, citing difficulties in fulfilling LAHSA's mission without"fundamental shifts". In her resignation letter, Marston elaborates:
"Power and funding alone control homelessness. But in our current system, organizations like the one I lead, the Los Angeles Homeless Services Authority (LAHSA), are not given control over regulatory or policy decisions, service providers remain underfunded, and dedicated front-line employees of non-profit organizations and government entities are hamstrung by rules, red tape, and bureaucracy. Marston also points to low wages, high rents, restrictive zoning laws, and other "shadow monsters'' we must tackle in order to end homelessness." https://medium.com/@hmarston2/the-homelessness-crisis-a-monster-of-our-own-maki ng-be5975399ce1
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Packet Pg. 1664 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Structural Governance of the Social Housing Authority
The State Housing Authority - HCD will oversee
The Social Housing Authority; Community-led development of PS, affordable, & market-rate housing: Social Housing Agencies in each county in CA (ONE SOCIAL HOUSING AGENCY with selected progressive civil peers (community advocates) assigned to offices in each part of the county (likely NSEW & Mid-City, TBD);a group of progressive housing civil peers that implements & develops new community-owned affordable, market-rate, and PS rental housing on publicly owned land throughout LA County. Communities are well put together, mostly in walkable, pedestrian/bike-friendly built communities. The agency as a collective whole will capture vacancy numbers (parking lots, buildings (privately & publicly owned), to determine ownership/best use for vacant spaces.
The Social Housing Authority will override city councils in localities to partner directly with County BOS, and HCD to collect funding meant for homeless/housing 2 Item 8.B
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Packet Pg. 1665 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) spending, money goes into ONE TRUST account that must provide RECEIPTS of where/how much money is spent on specific projects.
Agency works with HUD to implement new guidelines for affordable homeownership for the blue-collar working class. Agency maintains ONE website/database that has a list of AVAILABLE community-owned affordable, market-rate, and PS rental housing. List of AVAILABLE affordable & market-rate homeownership opportunities.
Affordable housing waitlist for rental housing should be no longer than 6 months, 6 months is actually too long but should not exceed that. The social housing agency is focused on public safety, public safety means safety from heavy traffic violence and climate arson. This means the social housing team works to build communities that are walkable, bike, and pedestrian-friendly. Communities that have access to green space.
Communities that aren’t being heavily polluted by LAPD helicopter pilots (noise & fuel pollution linked to dementia, linked to cancer). Cars belong on the outside of multi-family communities, not within. Cars are occupying too much land space! Humans need land to live on, we shouldn’t NEED to drive everywhere. Create when possible 15-20 minute cities/small communities.
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Packet Pg. 1666 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Social Agency is primarily focused on the development of community-owned housing. However, the agency will be divided into 3 primary teams; PSH, affordable & market-rate rentals, affordable & market-rate homeownership; Permanent Supportive Housing- PSH for residents in need of wraparound services. Services could be needed short or long-term depending on the person.
This team is focused on securing housing for residents with low-to-no income, chronically homeless, FOSTER youth (up to age 24), disabilities etc. This team doesn’t provide the services it connects other agencies & non-profits to PS housing.
This team maintains a database of PSH units that are available and works to revamp/remodel the broken shelter housing system to turn them into PSH.
Again, ONE social service housing website for residents with varying needs.
Foster Youth: safe and clean group homes that provide guidance & structure to youth/young adults up to the age of 24.
REVAMP the broken Foster System; guidance comes from social workers that are based out of the revamped DPSS, non-profits, grassroots teams, etc.).
PSH shouldn’t feel carceral (jail-prison like).
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Packet Pg. 1667 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Supportive services are wraparound services in QUALITY family planning, STI/STD prevention/protection, mental, behavioral, & rehabilitation healthcare, etc, etc.
Introduce UBI, money that should come from another trust account will not come from the housing trust fund. UBI for foster youth, and adult residents not working or below the poverty line. UBI up to $1000 a month for completed work/ treatment assignments.
For displaced youth; completed schooling/work/etc. Standard UBI (no work /treatment assignments required) $300-$500.
Repeating; services are provided by A REVAMPED DPSS, by grassroots and non-profit teams, etc. Agency will provide a civil peer court system; will also be for any potential cases of alleged abuse happening from workers but all workers must have ongoing training, schooling, and teachings in proper behavior when interacting with residents in PSH communities, especially foster youth! Service teams should meet every few months to go over what is and what is not working, the social housing agency does not provide the service, they are simply making available the housing needed for the residents in need of PSH, possibly in need of long term care, healing, community.
The PSH Social Housing Team works with the DPSS to secure safe parking/dwelling zones within the county until PSH becomes available. All non-profit groups/service teams need to be an extension of this department (LASHA, DPSS, Grassroot teams, etc., etc.) Service teams should be able to contact PSH social agency team to find PSH, Safe parking/dwelling, and/or to receive money for temporary hotel/room stays (FEMA MONEY should be used as the ONE trust account is mostly for development/maintenance/admin of community-owned housing. ONE TRUST per county social agency/authority).
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Packet Pg. 1668 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-Owned affordable & market-rate Housing; residents are self-sufficient, can pass a criminal background check likely just need assistance securing an affordable or market-rate unit. Will work with residents with a prior eviction. Community-owned affordable & market-rate rental housing that is always affordable. Rent shouldn’t take more than 20-30% of a resident's total income after taxes. Establish an affordable rental market-rate price for the blue-collar working class. The affordable price should not be averaged with working-class/high income earners included in the calculation. Most workers, most jobs in LA County pay about $40,000. What is the average wage for the blue-collar worker??? Community-owned, market-rate units will likely be much cheaper than privately owned market-rate.
All local city affordable housing authorities would be moved into the social agency/demolished. There are too many moving parts of the housing programs/processes. We need ONE coordinated system with FUNCTIONING non-profits, social service teams an extension of the one agency. Social workers, field workers, and rehousing specialists should be able to utilize the agency/website to secure at a minimum safe parking/safe dwelling. Should be able to give food vouchers/stamps, etc. to those that need them.
Again, the housing team is likely divided by local cities in the county, likely by NSEW & mid-city, TBD. Each of those divided teams will be divided into the 3 groups of; PSH, affordable & market-rate rentals, affordable & market-rate homeownership) Public Safety- A civil peer board of housing (court) will be established to hear cases about any potential threats to public safety happening in Socially owned housing. The court will also hear about allegations of any abuse happening within the system and 6 Item 8.B
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Packet Pg. 1669 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) correct the action. PSA on appropriate behavior will be provided to all residents/staff that are part of the social housing community.
The goal of the Social Housing agency is to prevent displacement but they will support “JUST-CAUSE” eviction for tenants posing a risk/threat to other tenants. No gang activity or violence WILL be tolerated, the community has a right to safety, if that safety is ever threatened, residents in the community have the right to evict! Some PSH will be for residents in transition from jail/prison back into community living. Prevent ROOT CAUSE of problems that we are seeing in our community. Also, consider communities for disabled residents/ residents with special needs that may need long-term wraparound services. Consider partnership with community colleges for affordable housing for students/young adults up to age 24-25. Consider committed behavioral, mental, and rehabilitation health programs for residents with outstanding issues in above mentioned. Any committed programs should still be a place of healing, not further violence and trauma. Dismantle and rebuild existing programs in that area.
Fix the problems at the ROOT, save the next generation and again, ongoing training, and schooling, for workers in this field. HIGHER pay for workers in these fields! 7 Item 8.B
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Packet Pg. 1670 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) The private housing market can always exist if it likes but residents shouldn't be forced to rely on it. There are residents whose families have been dealing with generational housing violence as it relates to race & class, they cannot rely on a privately owned market that has no accountability! Rent has gone up by over 65% within the last 10 years in LA County with no rebuttal for the blue-collar working class, retirees, residents of generational housing violence and displacement, college students, foster youth, and many many others. 8 Item 8.B
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Packet Pg. 1671 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) 9 Item 8.B
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Packet Pg. 1672 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) This social agency will have nothing to do with private housing developments but it can purchase private housing and it can assist with securing housing for residents in privately owned housing. The Social Agency will maintain a website of AVAILABLE community-owned affordable, market-rate, and PS rental housing units. Privately owned units can also be listed. <<< WATCH CYBER FRAUD/SCAMS which is rampant on apartment rental websites.
The social agency is being created to develop and implement new housing developments on vacant publicly owned land and remodels for publicly owned vacant buildings. The agency cannot deny community-owned housing developments in any neighborhood in LA County, they are a county-wide team that implements new developments of community-owned PS, affordable, and market-rate housing in ALL CITIES in the county, this includes SANTA MONICA, BEVERLY HILLS,
WEST HOLLYWOOD, MARINA DEL REY, PASADENA, DOWNEY, LONG
BEACH, etc., etc., etc., ALL CITIES IN LA COUNTY! The intentional segregation as it relates to race & class MUST end, THE NIMBY violence MUST END!
For community-owned affordable & market-rate housing, long-term residents of LA County should get priority with housing placements, focusing on getting workers closer to their jobs. It is imperative for the health of humans, the health of the Earth, and other species that we reduce drive times, and reduce pollution. Preventing displacement is IMPERATIVE. The team can prevent displacement by subsidizing rent for tenants in privately owned units and/or helping move them to community-owned affordable housing.
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Packet Pg. 1673 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Affordable homeownership- full proposal coming soon, introduce co-ops, CLT’s, and resell requirements. The primary focus is blue-collar workers (affordable with resell requirements) and market-rate housing. Use money from market-rate sales to place into the ONE trust account. Insert grassroots team to help with restorative justice aspects of homeownership for residents impacted by systematic racial violence.
How do you think this story is going to end?????????
Short-term rentals- introduce tourism short-term stays, money goes into the ONE trust account.
Trust Account- One trust account that will be audited by city/state controllers. Money comes from HUD, Feds, State, Donations, & HHH. The annual state surplus budget must donate a portion into trust every year. The tourism industry should be donating a portion of total earnings into the trust. The cannabis industry should be donating a portion of money into the trust, should be redirecting money to communities impacted by the “pretend war on drugs” created by the U.S Gov’t. A small portion is for admin/resident manager fees (try to avoid outsourcing resident management to other companies, which could run up costs). The largest portion of the trust is for housing development/property maintenance.) How much are CA taxpayers giving in federal dollars to other states using the money for social services (TBD). 11 Item 8.B
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Packet Pg. 1674 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-owned housing cannot be sold to corporations. If TOPA is introduced, keep under CLT (land lease) to allow tenants to purchase their units but prevent corporations from being able to purchase***??? (verify). Also, any money given to nonprofits to build affordable housing should mean that that housing cannot be sold to a corporation. How and why are some non-profits that received Gov’t/Taxpayer money able to sell affordable buildings after a set number of years to private corporations? Housing would go back to the social agency OR TOPA if the non-profit wanted to be released from oversight/responsibility. The Social Agency can buy privately owned property and resell it to private owners/corporations but NOT publicly owned land/housing, not rent nor ownership. Again, community-owned developments are going to be built with the community in mind, with green space, stores, hospitals, etc., sometimes worked/developed within the communities.
Social Housing Plans ready for implementation;
https://htwws.org/santamonicaairport/
(Author notes, not part of the proposal)
-Examine the years that ADOS (American descendants of Survivors paid federal taxes but were not able to utilize public service. Examine displacement and communities that were intentionally burned t the ground by supremacists. Request reimbursement/hold percent of federal/state taxes to heal communities.
-Tenancy in common is a form of co-ownership of property in which each party owns an undivided interest that passes to his or her heirs at death. The interest is undivided 12 Item 8.B
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Packet Pg. 1675 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) because each tenant has rights in the whole property. Although ownership is in common, tenants may have equal or unequal shares.
-Joint tenancy is the joint ownership of property by two or more co-owners in which each co-owner owns an undivided portion of the property. On the death of one of the joint tenants, their interest is automatically passed to surviving tenants. -Real property- immovable property, a building, land, plants etc, (though buildings can actually be moved depending on).
-Just cause eviction in CLT - Community members causing violence when corrective action cannot be taken, not working. Racial violence & other forms of discrimination.
Peer court will recommend rehabilitation programs when permitted to do so, severe cases could result in immediate evictions.
-Land on Earth belongs to all of humanity.
-Land has not been fairly distributed to residents impacted by systematic housing violence as it relates to race & class.
-The aim of the Surplus Land Act (the "Act"); is to increase the availability of real property in California for affordable housing development by requiring the prioritization of affordable housing when selling or leasing public lands no longer necessary for agency use.
-"Feb. 5, 1866: Thaddeus Stevens Proposes Land Distribution Amendment" https://www.zinnedproject.org/news/tdih/thaddeus-stevens-freedmens-bill/ 13 Item 8.B
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Packet Pg. 1676 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -Foster City- examine the broken foster system, keeping families together whenever possible, family planning services, safe housing & family for youth that are not able to stay with their biological families.
To do;
-Write the state bar and include them on your housing emails. REQUIRE that the state bar authorize civil peers to oversee legal issues related to housing (LLP’s). -BLM the org must redirect funding into one trust that is overseen by a group of Black civil peers. Push money back into Black communities as direct UBI payment, as housing payments, treatment payments, crime & gang prevention, etc., etc. -Email OMBW/Watch for grants (GS)
-Civilian Eminent Domain of Public Land; communities protected from Climate arson; Free market exists for those that want to be part of it. -Establish Public Bank
-A PORTION of public land MUST remain PUBLICLY owned for use by the community.
-Agency divided into NSEW & Mid-City?!?! Civil Peer teams in NSEW & Mid-City ?? -If the BOS goes ROUGE, the social agency will partner with the state housing authority directly and override county BOS should they become non-compliant. 14 Item 8.B
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Packet Pg. 1677 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -representcal.org, why a constitutional convention is necessary, and how the CA constitution allows localities to abuse their position, allows illegal segregation as it relates to race & class.
-Examine pre-built tiny home/ADU placements in well put together communities that are affordable & supportive. Sheds are not tiny homes. Some residents already own tiny homes or they want to, can support themselves but need land. Communities likely could be supported in the valley.
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Packet Pg. 1678 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Vernice Hankins
From: HowTheWest Was Saved <[email protected]>
Sent: Monday, June 20, 2022 3:43 PM
To: councilmtgitems
Subject: 06/21/22 Santa Monica City council meeting; Comment on item 8B, Housing Element Attachments: SocialHousingAuthority.TieiraRyder.4-25-22.pdf
EXTERNAL
Hello,
We are asking HCD to support a county-led social housing team that is overseen by actual progressive housing advocates. Not much has changed in Santa Monica City's housing element and as a collective, we will NEVER get out of the housing crisis if we do not begin implementing a solid social housing policy across the entire U.S. Build more privately owned market-rate housing but residents cannot rely on a market that has proven unreliable!
The source has already granted us all permission to live on Earth.
Residents of varying "racial" & class backgrounds do not require the permission of another human to live anywhere on Earth. We must build housing in well-built communities that are walkable, bikefriendly, and affordable! The incorrectly zoned Santa Monica airport & penmar golf course MUST close in this housing cycle so that we can begin building housing surrounded by a large park! HCD, local residents are asking for your support in capturing PUBLIC land to be used for PUBLIC good. Localities that have been intentionally segregated by race & class cannot be expected to do the right thing.
https://htwws.org/social-housing-ca/
‐‐
Best,
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Packet Pg. 1679 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 Tieira
https://htwws.org/santamonicaairport/
https://youtu.be/WSFf00y-0uA To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.
Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
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Packet Pg. 1680 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
2021-2022
EXECUTIVE COMMITTEE
Julie Rusk, chair
John Maceri, past chair
Karen Gunn, vice chair
Jody Priselac, vice chair
Natalya Zernitskaya, secretary
Perry Roshan-Zamir, treasurer
BOARD OF DIRECTORS
Gary Avrech
Sheila Banani
Tara Baraukas
Claudia Bautista-Nichols
Lindsay Call
Stephanie Cohen
Timothy Conley
Donna Gentry
Ana Maria Jara
Shawn Landres
Ashley London
Janet Gollery McKeithen
Thomas McLaughlin
Jessy Morales
Tara Pomposini
Cynthia Rose
Laura Rosenbaum
Eric Shafer
Cecilia Tovar
Nat Trives
Angel Villaseñor
Michele Wittig
Leila Youssefi
Donald Zelaya
EMERITUS BOARD MEMBERS
Debra Farmer
Misti Kerns
The Human Relations Council of Santa Monica Bay Area is a non-profit organization that promotes a culture of fair treatment, inclusion and equal access to opportunities.
P.O. Box 1307 • Santa Monica, CA 90406 -1307
:hrcsantamonica.org :humanrelationscouncilsantamonicabay June 8, 2022
Re: June 28, 2022 Council Adoption of FY 2022/23 City of Santa Monica Budget Dear Mayor, City Council and City Staff:
The Human Relations Council (HRC) of Santa Monica Bay Area is a nonprofit organization that promotes a culture of fair treatment, inclusion, and equal access to opportunities. As such, we are deeply committed to equitable, sustained, creative and user-friendly community engagement and public participation. • We appreciate the City Council and staff commitment to greater access for public participation in Council and Board/Commission meetings through your support for “hybrid” meetings and provision of language access services.
This includes call-in and virtual options for public comment and readily available translation and interpretation services, particularly in Spanish and Amharic. We strongly believe that enabling greater public access in these ways is one required step to further the City’s goals of becoming a more equitable and inclusive community.
• We further encourage the City Council to provide the resources needed to support the City staff-created Equity Action Plan designed to ensure increased awareness, action and improved equity outcomes across all City departments.
In summary, we eagerly anticipate implementation progress across all departments on the City’s Equity Action Plan. Genuine and sustained progress on this Plan along with support for those who may not be able to attend in-person meetings and those who may need language support are foundational for a more diverse, equitable, and inclusive Santa Monica for all. When you adopt the FY 2022/23 City budget and department priorities, please adequately fund and restate your priority for this necessary and essential work.
Thank you for your service to the people who live, work and visit Santa Monica.
On Behalf of HRC Board With Kind Regards,
Julie Rusk
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Packet Pg. 1681 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Vernice Hankins
From: Debra Shepherd <[email protected]>
Sent: Tuesday, June 21, 2022 11:28 AM
To: councilmtgitems
Subject: Item 8B
EXTERNAL
Good day Councilmembers:
I'm writing to you as a 20 plus year resident of the city of Santa Monica. I am also a person with lived experience of homelessness. I am currently a participant in the housing voucher program.
I know that you have a lot of input about housing, but I don't know how much of it actually comes from people like me. I watch your meetings regularly. Most feedback comes from people, who are insulated by their privilege. They have no lived experience of struggling for basic necessities.
When a person is struggling to pay rent, or they are unhoused, it's like drowning. It's a crisis that requires extraordinary measures. For the last 20 years, I have watched people kill projects with their privilege, that would have provided hundreds of units of affordable housing. The number of required units from the state is the result of that. It's not the state of California unfairly singling out the city of Santa Monica. We earned this number. It's time for us to accept the requirement, and do whatever is necessary to meet it.
Best Regards,
Debra Shepherd
Santa Monica resident
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Packet Pg. 1682 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 Vernice Hankins
From: [email protected]
Sent: Tuesday, June 21, 2022 11:06 AM
To: Sue Himmelrich; Kristin McCowan; Phil Brock; Gleam Davis; Lana Negrete; Christine Parra; Oscar de la Torre
Cc: councilmtgitems
Subject: Agenda Item 8.B: Housing Element Draft Redline Revisions
EXTERNAL
Dear Santa Monica City Council,
As these Staff‐recommended revisions are reviewed, it should be noted that the Council’s actions in complying with the over‐reaching and counter‐productive state legislation will only serve to further undermine any future challenge the City may decide to undertake. Agenda Item 8.B Housing Element Draft Redline Revisions is simply the City’s latest action of acquiescence, dating back to 2019.
This sets the stage to further undermine the community wellbeing, further ration fixed amenities such as parks, and compromise the City’s already challenged long term financial situation.
To be specific, the financial downside is amplified by the simultaneous increase in (unfunded) service and infrastructure requirements and the initiative to convert destination retail space to residential, eliminating city sales tax revenues in the process. This strategy leaves significant tax increases on existing residents as the only option.
The reality of Santa Monica’s housing capacity and history of addition Santa Monica’s has added so much housing that its current stock translated into 1.78 residents per housing unit according to the 2020 census. To place this into context, the City of Los Angeles is 46% higher at 2.61 residents per housing unit. The Statewide average of 2.75 residents per housing unit is 54% higher than Santa Monica. Santa Monica has one of the lowest levels of any city in the state.
How did Santa Monica achieve such housing abundance? Since 1960, Santa Monica has added a net 1.5 housing units for each new resident, children included. This translates into 14,795 net new housing units servicing a net population increase of 9,794.
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Packet Pg. 1683 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 3 In fact, Santa Monica kept building new housing units even in decades that experienced net declines in city population! During the 1980s and 1990s, Santa Monica had a 4,230 net decline in population. Despite that decline, the city built 1,445 net new housing units during that same period.
To be clear, that 60‐year building trend was not in response any historical overcrowding. In 1960, the average number of people per housing unit in Santa Monica was 2.23. The 2.65 in the City of Los Angeles was 19% higher than Santa Monica. The average over the entire State in 1960 was 2.88, 29% higher than Santa Monica.
Moreover, since 1980s, Santa Monica has added 4,000 affordable housing units, representing about 70% of the housing stock added since 1980 and 10% of the City’s entire current multi‐ family housing stock.
Despite this housing abundance reality, the Council has yet to seriously challenge the arbitrary and onerous state allocations.
The state‐defined shortage in Santa Monica relates to residents, NOT housing.
To be clear, Santa Monica does not have a shortage of housing. According to the arbitrary RHNA process that this item relates to, the State has actually deemed that Santa Monica has a shortage of new residents.
By definition, any “solution” to this misdirected state‐defined “problem” provides no benefit to current residents and will – in fact – be to their detriment. If the Council continues to service this unsupported and unjustified RHNA process, it will be decreasing its ability to defend its residents, which is one of the City Council’s core responsibilities.
How does the State justify the need for increasing residents in Santa Monica? Out of the 8,895 units of housing being required by the State, 1,156 units (13%) are acknowledged as the true future organic growth requirement of the City in the next eight years. The other 7,739 units (87%) are related to hypothetical concepts of “existing need” which are defined as 4,300 units that should be built due to the existence of “high quality Item 8.B
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Packet Pg. 1684 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 4 transit areas” (HQTA) – bus stops – and 2,749 units due to proximity to places of employment.
Then there is a catchall of around 690 more units just for good measure.
How relevant is this “existing need”? The state’s definition of HQTA has been defined as basic bus service. Yet, the BBB’s (and LA Metro) actual transit utility is so low that ridership is at an all‐time low, and remains in a decline that predated the pandemic.
The jobs requirement is related to “workforce” housing. But, as cities such as Santa Monica are within larger metropolitan areas, the traditional (and only logical) concept has been to look at jobs and housing on a broader regional scale to account for the fact that as people change jobs, they do not need to change living location. Under the new state models, it appears that workers are conveniently assumed not to change jobs. But when they actually do, and they no longer work in Santa Monica, will they consequently lose their housing to make way for others who take their place in those Santa Monica jobs? Of course not.
This is an opportunity for Council action to defend the residents The prior City Council failed the residents in pushing back against this nonsensical State overreach at its inception.
Each iteration of staff compliance with State demands reduces the City’s ability to defend its residents.
Does the Council want to continue on this path? Many residents feel that there needs to be a significant policy course correction.
Thank you,
Marc L. Verville
Sunset Park
Santa Monica
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Packet Pg. 1685 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 5 Vernice Hankins
From: [email protected]
Sent: Tuesday, June 21, 2022 10:33 AM
To: councilmtgitems
Cc: [email protected]; Phil Brock; Gleam Davis; Oscar de la Torre; Sue Himmelrich; Kristin McCowan; Lana Negrete; Christine Parra; Jing Yeo; David Martin; David White Subject: City Council 6/21 agenda item 8-B -- Revised Husing Element
EXTERNAL
Dear City Council members,
Agenda item 8-B staff report:
http://www.acgov.org/board/bos_calendar/documents/DocsAgendaReg_11_18_21/GENERAL%20ADMINISTRATION/Re gular%20Calendar/Housing_Element_RHNA_11_18_21.pdf
1) On page 3 of 8 of the staff report for item 8-A on the City Council's 6/21 agenda, it says that overall housing capacity was increased to over 13,000 units.
Does that mean that Planning staff will then propose zoning changes to accommodate 13,000 additional housing units? Why do this when we're only required to zone for 9,000?
2) This plan includes allowing 300+ housing units at 4th/5th & Arizona, leaving no room for a park.
3) This plan includes allowing 700+ housing units at the Bergamot Arts Center. What will happen to the art galleries?
4) Up zoning even more of the city city than necessary for 9,000 housing units (which was a ridiculous number to begin with) will allow investors from near and far to buy up property for speculation.
This will not benefit residents and, if that much housing is actually built, it will create enormous stress on city infrastructure, especially water.
5) Will outdoor watering restrictions eventually move from 2x per week to 2x per month? Why not just cut down all the trees in the city and be done with it, rather than watch them sicken and die from lack of water?
6) We can also go ahead and replace all the remaining grass with decomposed granite, asphalt, and cement, thus creating a gigantic heat island in Santa Monica.
7) In addition, legislation currently moving through the state legislature will remove all parking requirements for new construction, so imagine thousands of new daily car trips as residents drive around looking for street parking.
What a great way to make a city unlivable.
Zina Josephs (Santa Monica resident since 1970)
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Packet Pg. 1686 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 6 Vernice Hankins
From: Daniel Galamba <[email protected]>
Sent: Tuesday, June 21, 2022 9:38 AM
To: councilmtgitems; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Sue Himmelrich; Kristin McCowan; Oscar de la Torre; Daniel Galamba
Subject: June 21, 2022 City Council Meeting: Please Oppose Item 8.B. Housing Element Draft Redline Revisions
EXTERNAL
Dear City Council,
I request that you oppose the draft Housing Element Redline Revisions.
These revisions are based on a ridiculous RHNA assessment of 9,000 units that will result in Santa Monica's population increasing by 20% over 8 years with all the resulting traffic, congestion, gridlock, public services and infrastructure that go along with it. All not paid by the State. California's and Los Angeles County's population has increased by about 2% over the past 10 years. Santa Monica's population has increased by only about 3% over this same 10 year period.
Therefore requiring a 20% increase in Santa Monica's population over 8 years is just simply up zoning so developers can make more money at our expense.
These 9,000 units include 6,000 affordable units that will cost about $3 billion. Again, not paid by the State. We don't have $440 million to pay our unfunded pension obligations let alone $3 billion for 6,000 affordable units. Therefore, over time the requirement that these units be affordable will be dropped and market rate units will then go in there because there will be the money for that. This is just a two‐step process so developers can make more money at our expense. This will destroy our City as developers did in Westwood and West Los Angeles in the 1980's. Now people don't want to live in West Los Angeles anymore or come to Westwood Village or West Los Angeles anymore and both Westwood Village and West Los Angeles are going down hill and I don't want the same thing to happen to us in Santa Monica and it will.
I therefore request that you suspend working with the State on these Housing Element Revisions and join other cities (e.g. Pasadena) in legal action against the State until the State accepts a RHNA that reflects a realistic 2‐3% population growth in Santa Monica over 8 years. Please don't let our City of Santa Monica be looted by greedy developers as they did in Westwood and West Los Angeles in the 1980's. Thank you.
Sincerely,
Dr Daniel Galamba
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Packet Pg. 1687 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Vernice Hankins
From: Nancy Coleman <[email protected]>
Sent: Tuesday, June 21, 2022 3:01 PM
To: councilmtgitems; Sue Himmelrich; Gleam Davis; [email protected]; Christine Parra; Phil Brock; Oscar de la Torre; Lana Negrete; Jing Yeo; David Martin Subject: Item 8B
EXTERNAL
To: Mayor Himmelrich and Council Members
From: Nancy Coleman
Date: June 21, 2022
Re Item 8 B, Housing Element
8 B Housing Element
While I understand that the goal of tonight’s effort is to approve a state acceptable Housing Element there are a number of questions still outstanding. The Council needs to think about where parks will be when all city‐owned property is designated for affordable housing. Santa Monica is already a park pour community.
The increased height and FAR for Neighborhood Commercial streets is not acceptable. 55 feet is too high. If state bonuses are applied it will be even higher.
1) On page 3 of 8 of the staff report for item 8-A on the City Council's 6/21 agenda, it says that overall housing capacity was increased to over 13,000 units.
Does that mean that Planning staff will then propose zoning changes to accommodate 13,000 additional housing units? Why do this when we're only required to zone for 9,000 and this is too many for the city. 2) This plan includes allowing 300+ housing units at 4th/5th & Arizona, leaving no room for a park. 3) This plan includes allowing 700+ housing units at the Bergamot Arts Center. What will happen to the art galleries? 4) Up zoning even more of the city, including the increased heights of up to 84 feet in a portion of the DCP and Bergamot plus state bonuses will make the City of Santa Monica have the look of downtown Miami. is the than necessary for 9,000 housing units?
Item 8.B
06/21/22
37 of 38 Item 8.B
06/21/22
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Packet Pg. 1688 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2 This will not benefit residents and, if that much housing is actually built, it will create enormous stress on city infrastructure, especially water.
Nancy Coleman
Item 8.B
06/21/22
38 of 38 Item 8.B
06/21/22
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Packet Pg. 1689 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Casey Nichols
To: Housing Update
Subject: Lincoln / Ocean Park Project
Date: Tuesday, July 12, 2022 9:24:43 AM
EXTERNAL
Dear Santa Monica Housing Update Team,
I am reading through the latest update of Santa Monica's Housing Element. It looks like we're relying on the Lincoln and Ocean Park project for a substantial number of new homes.
What is the status of this project? Has it been entitled by the city? There's very little information available online.
Please let me know at your soonest convenience. I am working on a comment letter to HCD and I want to make sure I have all accurate information.
Thank you,
Casey
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Packet Pg. 1690 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Michael Clarke
To: Planning Commission Comments
Subject: 3-A
Date: Tuesday, March 1, 2022 8:14:42 PM
EXTERNAL
I support the HCD Response Memo submitted by Commissioners Fresco, Lambert, and Landres. It strikes me as a good faith effort to comply with state housing laws which unfortunately is not something we've done a good job of so far.
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Packet Pg. 1691 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Vernice Hankins
From: Mario Fonda-Bonardi <[email protected]>
Sent: Tuesday, March 15, 2022 1:33 PM
To: councilmtgitems
Subject: 4A SB9 Study session
EXTERNAL
Hi Council members
The discussion on S9 revolves around how much over densification should the City allow before the character of the R1 is completely lost and it becomes effectively an R2 or R3 district? One of the hinge points is should each lot split by SB9 also be allowed to have an ADU (a single R1 lot could become 4 units: 2 single family homes plus 2 ADUs). SB9 does not REQUIRE a City to allow ADU’s in each of the split lots so it becomes an opportunity for the CIty to exercise some discretion in protecting the character of our R‐1 neighborhoods ADUs by themselves are over‐all beneficial, but when crammed into tiny lots already split from the normal R1‐ lot size, they can become a plague. By state laws ADUs can already be just 4’ from side and rear setback lines and up to 24’ high, so they can present quite an invasion of privacy for all the backyards they look into, not to mention shading and parking overload.
Therefore I would ask that you not allow ADUs in lots already split using SB9.
However if you are forced to compromise I would argue for 3 criteria before an ADU can be allowed in a lot split by SB9.
1. The remaining lot should be at least 5000 square feet
2. It should have at least two parking spaces (not tandem)
3. No tree with a diameter greater than 3” should be removed in building the ADU Such conditions would substantially but not perfectly protect the character of the R‐1 neighborhood.
Needless to say there is a high probability that the State will next year try to water down the few protections (such as this not mandating ADUs in lots split by SB9) against overdensification that SB9 provides. There is no reason to do this damage to ourselves now.
Your favorable consideration of this request is greatly appreciated.
Mario Fonda‐Bonardi AIA
[email protected]
310‐699‐0374
Item 4.A
03/15/2021
1 of 1 Item 4.A
03/15/2021
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Packet Pg. 1692 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Alicia Casilli
From: HowTheWest Was Saved <[email protected]>
Sent: Monday, May 9, 2022 10:21 AM
To: Planning Commission Comments
Cc: Housing Elements@HCD
Subject: Comment on item 9AM; Housing Element; PLANNING COMMISSION MEMBER DISCUSSION ITEMS Attachments: PenmarGolfCourse+SMAirportproposal.TieiraRyder.pdf; SocialHousingAuthority.TieiraRyder.4-25-22.pdf; HousingType211.jpg; Housingtype3.jpg; HousingType1.jpg
Categories: PC
EXTERNAL
Hello,
Attached you will find the proposal to build housing at the incorrectly zoned Santa Monica Airport + Penmar golf course. Residents in need of safe, clean, and affordable housing have waited long enough and localities are abusing their positions. We need the city attorney to step in to take the FAA to court again to get the airport closed sooner than 2028. Also MEASURE LC is likely illegal since it seems to violate CA's Surplus Land Act.
We should be using public land for public good! We can keep a hospital/helicopter pad landing in the final design for the incorrectly zoned airport & penmar golf course but that land should be used mostly for dense housing in a walkable community that is surrounded by a large park. Right now it's being used as a Rich persons playground as 60,000+ residents are unhoused in LA County, as even more residents live one paycheck away from being unhoused! To make it clear, YES, your favorite barista does deserve housing that they can afford close to their job in Santa Monica.
Best,
Tieira
https://htwws.org/santamonicaairport/
Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
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Packet Pg. 1693 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 1/11
HOW THE WEST WAS SAVED
"In the future when it's asked how the west was saved, the story will be that the people of the west saved themselves from ongoing systematic violence"
THE PROGRESSIVE SPACE
When The Santa Monica Airport Closes…
By Bear Writer On 05/30/2021
Update: A Letter from HCD (Department of Housing & Community development) to Santa Monica City’s planning team regarding the upcoming housing element. How The West Was Saved (Tieira R.), Our current direction is not left
or right, but forward towards
progress.
How The West Was Saved is an
open space for discussions on
progressive solutions to the
Western world. Our team is
currently focused on solutions
to affordable housing in the
Greater Los Angeles area. We
are committed to progress, we
are committed to change for
the betterment of everyone in
society.
Follow Us
Petition:
Close the
incorrectly
zoned Santa
Monica
airport and
build housing
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Packet Pg. 1694 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 2/11
along with some other wonderful housing advocates were mentioned as consideration for the comments that HCD gave to Santa Monica regarding a compliant housing element. Thank You HCD for rejecting Santa Monica’s non-compliant housing element, we must hold cities accountable for housing production so that residents can finally have the housing that they are owed!
https://www.smgov.net/
When the incorrectly zoned Santa Monica airport closes, a closure that should be happening in this upcoming housing element cycle (2021-2022), a walkable community that includes
majority affordable housing should be developed. The
location is perfect for a community-owned, walkable/bike-friendly residential neighborhood that includes a variety of housing types for working-class residents on the westside, students, seniors, those living with disabilities, and many others in need of affordable housing.
(Author does not
own the rights to
all of the photos
attached, via
social media. All
rights reserved to
original owners)
Taras Grescoe
@grescoe
“I’ve been living my life wrong.”
—literally everyone in North America.
6:23 AM · Aug 30, 2021
1.4K Reply Share
Read 26 replies
CONTACT HTWWS
Your name
Your email
Subject
Your message (optional)
Submit
Target: To The
CA State
Attorney General
Rob Bonta & To
The California
Housing Authority
(HCD)
SIGN THIS
PETITION
Welcome back,
Tieira!
Not Tieira? Click here.
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from Tieira Ryder
Action by: Tieira Ryder
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Packet Pg. 1695 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 3/11
To be clear, this community would include both communityowned rental and homeownership options. This pro-housing advocacy effort should be led by a housing advocate that understands the needs of the local community, someone that likely falls within the working class and has the best interest of the local community in mind. When it comes to renting, rent should never exceed 20-30% of a resident’s total income after
taxes. Please keep in mind, the average worker in LA makes about $39,000 a year, this rental housing would be catered to those workers but the community itself would be mixedincome meaning it would also include market-rate units (still cheaper usually than private market-rate housing).
Along with market-rate rentals & homeownership opportunities, business placements would be considered throughout the
community.
Housing proposal for the Santa Monica airport
(Please note that Penmar golf course is also being requested for this project.
The exact community plans would need to be confirmed & this is just a proposed housing plan for the vacant land space. The proposal was created by Tieira R.)
Affordable Homeownership;
1. Affordable, reasonably priced homeownership for working-class residents, priority for long-term residents living or working in the Santa Monica, Venice, & Mar Vista zip codes.
2. Consider a set number of market-rate “for-sale” homes.
3. A variety of home types should be considered for development but especially multi-family housing such as plexes, condos, townhomes, and apartments. Consider co-op ownership.
4. Priority consideration should also go to first-time
homeowners in LA County, my recommendation is residents that have lived/worked at least 10 years in LA County.
5. Priority consideration for historically displaced residents from supposed marginalized communities. Consider a 30-40% “right to return”, “right to housing” for ADOS families (African
descendants of Survivors), & for other residents impacted by systematic housing violence. (Google the history of displaced Black families in Santa Monica, Venice, and/or Manhattan Beach if you need more info.)
6. The millennial generation should also receive a percentage of priority consideration, they currently own a measly 18% of the homes in Los Angeles. “Equity is defined as “the state, quality or ideal of being just, impartial and fair.” The concept of equity is synonymous with fairness and
justice.”
DONATE TO HTWWS
Cashapp Me
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Packet Pg. 1696 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 4/11
7. At no time would a small or large equity firm be granted permission to purchase a home within the community nor would an option be granted to purchase the community as a whole.
8. My recommendation on income qualifications for residents that are first-time buyers is; working-class residents making between $30,000-$130,000.
9. If potential owners require financing, ownership could be subject to credit union or bank approval. Consider public, city-owned bank.
10. The actual cost of homes should match that of the actual average wage of what most working-class residents make. There would likely be re-sell requirements as affordability would be protected by a trust.
Affordable Rental Housing;
1. Community-owned rental housing in mixed-income
developments.
2. The recommended height for apartment buildings is 6-7 stories.
3. Set an “affordable rental rate” based on what the average person from the working class makes. At this moment, most workers in LA make about $39,000 a year. Affordability is usually priced for residents in the $17,000-$70,000 range.
4. Community-owned market-rate rentals to be included, most likely still cheaper than the private market-rate rental housing.
5. No income restrictions once residents are housed.
https://www.nhlp.org/resources/lihtc-admissions-rentsgrievance-procedures/
6. Reserve a portion of the housing for limited to no-income residents. Consider the following; subsidize with HUD and/or new digital voucher program; subsidize low to no income residents with market-rate apartment & business rentals; consider HCID/HACLA westside chapter. Social services for housing, food, and health care should be ONE efficient program.
7. Affordable bachelors, studios, 1, 2, and 3 bedrooms.
8. As with affordable homeownership, the rental units & placements would be for various types of community members but especially keeping in mind our core working class which includes
the essential workforce, students, seniors, veterans, those living with disabilities, etc. etc.
9. Student apartments would be bachelor-sized apartments with smaller fridges and MUST have a kitchen area sink and a small area to put a hot plate (or something similar) so they can cook if needed. (Similar to this https://urbanize.city/la/post/micro-unitapartment-building)
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Packet Pg. 1697 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 5/11
More info on the proposed community as a whole;
1. priority consideration for business placements within the community.
2. Open park space, recreation center within the walkable community. Cars can exist on the outside of the community, not within.
3. Consider the possible need to build new schools.
4. Consider a quality westside public transit system especially for college students between SMC and/or UCLA. (cut down on car traffic congestion because students wouldn’t need to drive)
5. College student housing should have its own small park area that has a WIFI and outdoor/indoor workspace for them.
6. Consider large home space for displaced minors within the community aka a “group home” to provide stability.
7. Request consideration for golf course closure(s) as well as other vacant land plots and buildings that have
potential use for affordable housing that is communityowned and suits apartments, condos, townhomes, small and/or tiny homes for locals. Request more interim housing and healthcare sites on the westside for residents with long-term behavioral health needs.
The overall progressive housing goal is to adopt a similar social housing policy for each city in California (all of the U.S) with prohousing community advocates from said cities leading the efforts.
The private market can obviously always exist but it can’t compete against itself, forcing residents to beg for housing that is priced much higher than most can afford. That doesn’t sound like freedom to me!
California’s Housing Crisis
The current CA housing crisis is literally wiping out and pushing the blue-collar working class, students, senior citizens, and many other residents into poverty! In the last 10 years, rent has gone up well over 65% in the city of Los Angeles, in that same amount of time the number of unhoused residents increased by at least 50%! There are currently 60,000+
unhoused residents in LA County and the median income can no longer afford a rent-controlled studio in cities like Santa Monica!
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Packet Pg. 1698 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 6/11
It’s time to return ownership to the residents of Los
Angeles, our right to clean, safe, and affordable housing is being denied!
Side Notes:
Walkable communities are
essential
https://planning.lacity.org/plans-policies/housing-element (LA City Housing Element)
What is a community land trust?
“Starting at about $600 per month for a studio, rents in the Los Angeles Eco-Village are less than half the price of some comparable apartments nearby, and prices aren’t raised unless community members agree to it. That’s possible because the land beneath the co-op is owned by the Beverly/Vermont Community Land Trust, which has pledged to make the land permanently affordable regardless of rising housing prices.”
Renters need to earn $95,000 to afford rent-controlled
studio in Santa Monica, new report says
A household earning the Los Angeles area’s median income cannot afford a rentcontrolled studio in Santa Monica, according to a new report from the city’s Rent Control Board. By U.S. Department of Housing and Urban Development affordability standards, a family would need an income of at least $95,429 to afford a studio, which is about … Continue reading
Santa Monica Daily Press 1
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Packet Pg. 1699 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 2/22/22, 7:31 PM When the Santa Monica airport closes… – How The West Was Saved https://htwws.org/santamonicaairport/ 7/11
https://laist.com/2021/02/02/community-land-trusts-los-angelesaffordable.php An email from the Santa Monica planning team regarding
use of the airport in this upcoming housing element
“Hi , Thanks for sharing your proposal and thoughts for the airport. Please note that since the airport is slated to close at the end of 2028 and conversion to any other use would take time, the airport is not realistically being considered in the planning for the 6 cycle Housing Element Update
(October 2021 – July 2029). It will most certainly be a consideration in the following housing element cycle
(beyond 2029). However, to get to that point, there will need to be a public process around the future of the airport given the significant community interest and varying views on its future use so I hope you will continue on to be engaged in that separate effort.”
Quotes from an LA Times article regarding the Santa
Monica airport
“The opening of a the 227-acre site on the Westside — in close proximity to jobs, good schools and transit — is a once-in-ageneration opportunity. Housing has to be a part of the equation. “Since the 1980s, Santa Monica has approved the construction of millions of square feet of office space, transforming it into a hub for both the tech and entertainment industries, with a daytime population that swells by more than 150,000 people. But this explosive job growth has not been accompanied by a proportional increase in housing units.” “Santa Monica’s estimated population of 92,478 residents in 2019 was only a blip above what it was in 1970, when 88,289 people called the city home. This growing imbalance between jobs and housing has created a massive influx of daily commuters into Santa Monica (even well-compensated tech employees) who either can’t find or can’t afford housing near these job centers. Meanwhile, population in neighboring jurisdictions has swelled, displacing lower-income residents. The result is more and more commuters crowding the freeways from increasingly distant parts of Southern California.”
The plan to turn Santa Monica Airport into a park is irresponsible.
The Westside needs housing
th
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Packet Pg. 1700 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) REPEAL ARTICLE 34 in the CA state constitution; USE public land for PUBLIC GOOD, end systematic housing violence & displacement. Article 34 of the CA constitution reads; “No low rent housing project shall hereafter be developed, constructed, or acquired in any manner by any state public body until, a majority of the qualified electors of the city, town or county, as the case may be..”
Localities that have been abusing their positions and segregating cities by race & class should not decide what happens to public land. Workers that commute into cities also have the right to decide what happens to public land, retirees, college students, and many others also have that right!
“Heidi Marston resigns from LASHA, citing difficulties in fulfilling LAHSA's mission without "fundamental shifts". In her resignation letter, Marston elaborates:
"Power and funding alone control homelessness. But in our current system, organizations like the one I lead, the Los Angeles Homeless Services Authority (LAHSA), are not given control over regulatory or policy decisions, service providers remain underfunded, and dedicated front-line employees of non-profit organizations and government entities are hamstrung by rules, red tape, and bureaucracy. Marston also points to low wages, high rents, restrictive zoning laws, and other "shadow monsters'' we must tackle in order to end homelessness." https://medium.com/@hmarston2/the-homelessness-crisis-a-monster-of-our-own-maki ng-be5975399ce1
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Packet Pg. 1701 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Structural Governance of the Social Housing Authority
The State Housing Authority - HCD will oversee
The Social Housing Authority; Community-led development of PS, affordable, & market-rate housing: Social Housing Agencies in each county in CA (ONE SOCIAL HOUSING AGENCY with selected progressive civil peers (community advocates) assigned to offices in each part of the county (likely NSEW & Mid-City, TBD); a group of progressive housing civil peers that implements & develops new community-owned affordable, market-rate, and PS rental housing on publicly owned land throughout LA County. Communities are well put together, mostly in walkable, pedestrian/bike-friendly built communities. The agency as a collective whole will capture vacancy numbers (parking lots, buildings (privately & publicly owned), to determine ownership/best use for vacant spaces.
The Social Housing Authority will override city councils in localities to partner directly with County BOS, and HCD to collect funding meant for homeless/housing 2 11.A.h
Packet Pg. 1702 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) spending, money goes into ONE TRUST account that must provide RECEIPTS of where/how much money is spent on specific projects.
Agency works with HUD to implement new guidelines for affordable homeownership for the blue-collar working class. Agency maintains ONE website/database that has a list of AVAILABLE community-owned affordable, market-rate, and PS rental housing. List of AVAILABLE affordable & market-rate homeownership opportunities.
Affordable housing waitlist for rental housing should be no longer than 6 months, 6 months is actually too long but should not exceed that. The social housing agency is focused on public safety, public safety means safety from heavy traffic violence and climate arson. This means the social housing team works to build communities that are walkable, bike, and pedestrian-friendly. Communities that have access to green space.
Communities that aren’t being heavily polluted by LAPD helicopter pilots (noise & fuel pollution linked to dementia, linked to cancer). Cars belong on the outside of multi-family communities, not within. Cars are occupying too much land space! Humans need land to live on, we shouldn’t NEED to drive everywhere. Create when possible 15-20 minute cities/small communities.
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Packet Pg. 1703 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Social Agency is primarily focused on the development of community-owned housing. However, the agency will be divided into 3 primary teams; PSH, affordable & market-rate rentals, affordable & market-rate homeownership; Permanent Supportive Housing- PSH for residents in need of wraparound services. Services could be needed short or long-term depending on the person.
This team is focused on securing housing for residents with low-to-no income, chronically homeless, FOSTER youth (up to age 24), disabilities etc. This team doesn’t provide the services it connects other agencies & non-profits to PS housing.
This team maintains a database of PSH units that are available and works to revamp/remodel the broken shelter housing system to turn them into PSH.
Again, ONE social service housing website for residents with varying needs.
Foster Youth: safe and clean group homes that provide guidance & structure to youth/young adults up to the age of 24.
REVAMP the broken Foster System; guidance comes from social workers that are based out of the revamped DPSS, non-profits, grassroots teams, etc.).
PSH shouldn’t feel carceral (jail-prison like).
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Packet Pg. 1704 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Supportive services are wraparound services in QUALITY family planning, STI/STD prevention/protection, mental, behavioral, & rehabilitation healthcare, etc, etc.
Introduce UBI, money that should come from another trust account will not come from the housing trust fund. UBI for foster youth, and adult residents not working or below the poverty line. UBI up to $1000 a month for completed work/ treatment assignments.
For displaced youth; completed schooling/work/etc. Standard UBI (no work /treatment assignments required) $300-$500.
Repeating; services are provided by A REVAMPED DPSS, by grassroots and non-profit teams, etc. Agency will provide a civil peer court system; will also be for any potential cases of alleged abuse happening from workers but all workers must have ongoing training, schooling, and teachings in proper behavior when interacting with residents in PSH communities, especially foster youth! Service teams should meet every few months to go over what is and what is not working, the social housing agency does not provide the service, they are simply making available the housing needed for the residents in need of PSH, possibly in need of long term care, healing, community.
The PSH Social Housing Team works with the DPSS to secure safe parking/dwelling zones within the county until PSH becomes available. All non-profit groups/service teams need to be an extension of this department (LASHA, DPSS, Grassroot teams, etc., etc.) Service teams should be able to contact PSH social agency team to find PSH, Safe parking/dwelling, and/or to receive money for temporary hotel/room stays (FEMA MONEY should be used as the ONE trust account is mostly for development/maintenance/admin of community-owned housing. ONE TRUST per county social agency/authority).
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Packet Pg. 1705 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-Owned affordable & market-rate Housing; residents are self-sufficient, can pass a criminal background check likely just need assistance securing an affordable or market-rate unit. Will work with residents with a prior eviction. Community-owned affordable & market-rate rental housing that is always affordable. Rent shouldn’t take more than 20-30% of a resident's total income after taxes. Establish an affordable rental market-rate price for the blue-collar working class. The affordable price should not be averaged with working-class/high income earners included in the calculation. Most workers, most jobs in LA County pay about $40,000. What is the average wage for the blue-collar worker??? Community-owned, market-rate units will likely be much cheaper than privately owned market-rate.
All local city affordable housing authorities would be moved into the social agency/demolished. There are too many moving parts of the housing programs/processes. We need ONE coordinated system with FUNCTIONING non-profits, social service teams an extension of the one agency. Social workers, field workers, and rehousing specialists should be able to utilize the agency/website to secure at a minimum safe parking/safe dwelling. Should be able to give food vouchers/stamps, etc. to those that need them.
Again, the housing team is likely divided by local cities in the county, likely by NSEW & mid-city, TBD. Each of those divided teams will be divided into the 3 groups of; PSH, affordable & market-rate rentals, affordable & market-rate homeownership) Public Safety- A civil peer board of housing (court) will be established to hear cases about any potential threats to public safety happening in Socially owned housing. The court will also hear about allegations of any abuse happening within the system and 6 11.A.h
Packet Pg. 1706 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) correct the action. PSA on appropriate behavior will be provided to all residents/staff that are part of the social housing community.
The goal of the Social Housing agency is to prevent displacement but they will support “JUST-CAUSE” eviction for tenants posing a risk/threat to other tenants. No gang activity or violence WILL be tolerated, the community has a right to safety, if that safety is ever threatened, residents in the community have the right to evict! Some PSH will be for residents in transition from jail/prison back into community living. Prevent ROOT CAUSE of problems that we are seeing in our community. Also, consider communities for disabled residents/ residents with special needs that may need long-term wraparound services. Consider partnership with community colleges for affordable housing for students/young adults up to age 24-25. Consider committed behavioral, mental, and rehabilitation health programs for residents with outstanding issues in above mentioned. Any committed programs should still be a place of healing, not further violence and trauma. Dismantle and rebuild existing programs in that area.
Fix the problems at the ROOT, save the next generation and again, ongoing training, and schooling, for workers in this field. HIGHER pay for workers in these fields! 7 11.A.h
Packet Pg. 1707 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) The private housing market can always exist if it likes but residents shouldn't be forced to rely on it. There are residents whose families have been dealing with generational housing violence as it relates to race & class, they cannot rely on a privately owned market that has no accountability! Rent has gone up by over 65% within the last 10 years in LA County with no rebuttal for the blue-collar working class, retirees, residents of generational housing violence and displacement, college students, foster youth, and many many others. 8 11.A.h
Packet Pg. 1708 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) 9 11.A.h
Packet Pg. 1709 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) This social agency will have nothing to do with private housing developments but it can purchase private housing and it can assist with securing housing for residents in privately owned housing. The Social Agency will maintain a website of AVAILABLE community-owned affordable, market-rate, and PS rental housing units. Privately owned units can also be listed. <<< WATCH CYBER FRAUD/SCAMS which is rampant on apartment rental websites.
The social agency is being created to develop and implement new housing developments on vacant publicly owned land and remodels for publicly owned vacant buildings. The agency cannot deny community-owned housing developments in any neighborhood in LA County, they are a county-wide team that implements new developments of community-owned PS, affordable, and market-rate housing in ALL CITIES in the county, this includes SANTA MONICA, BEVERLY HILLS,
WEST HOLLYWOOD, MARINA DEL REY, PASADENA, DOWNEY, LONG
BEACH, etc., etc., etc., ALL CITIES IN LA COUNTY! The intentional segregation as it relates to race & class MUST end, THE NIMBY violence MUST END!
For community-owned affordable & market-rate housing, long-term residents of LA County should get priority with housing placements, focusing on getting workers closer to their jobs. It is imperative for the health of humans, the health of the Earth, and other species that we reduce drive times, and reduce pollution. Preventing displacement is IMPERATIVE. The team can prevent displacement by subsidizing rent for tenants in privately owned units and/or helping move them to community-owned affordable housing.
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Packet Pg. 1710 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Affordable homeownership- full proposal coming soon, introduce co-ops, CLT’s, and resell requirements. The primary focus is blue-collar workers (affordable with resell requirements) and market-rate housing. Use money from market-rate sales to place into the ONE trust account. Insert grassroots team to help with restorative justice aspects of homeownership for residents impacted by systematic racial violence.
How do you think this story is going to end?????????
Short-term rentals- introduce tourism short-term stays, money goes into the ONE trust account.
Trust Account- One trust account that will be audited by city/state controllers. Money comes from HUD, Feds, State, Donations, & HHH. The annual state surplus budget must donate a portion into trust every year. The tourism industry should be donating a portion of total earnings into the trust. The cannabis industry should be donating a portion of money into the trust, should be redirecting money to communities impacted by the “pretend war on drugs” created by the U.S Gov’t. A small portion is for admin/resident manager fees (try to avoid outsourcing resident management to other companies, which could run up costs). The largest portion of the trust is for housing development/property maintenance.) How much are CA taxpayers giving in federal dollars to other states using the money for social services (TBD). 11 11.A.h
Packet Pg. 1711 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) Community-owned housing cannot be sold to corporations. If TOPA is introduced, keep under CLT (land lease) to allow tenants to purchase their units but prevent corporations from being able to purchase***??? (verify). Also, any money given to nonprofits to build affordable housing should mean that that housing cannot be sold to a corporation. How and why are some non-profits that received Gov’t/Taxpayer money able to sell affordable buildings after a set number of years to private corporations? Housing would go back to the social agency OR TOPA if the non-profit wanted to be released from oversight/responsibility. The Social Agency can buy privately owned property and resell it to private owners/corporations but NOT publicly owned land/housing, not rent nor ownership. Again, community-owned developments are going to be built with the community in mind, with green space, stores, hospitals, etc., sometimes worked/developed within the communities.
Social Housing Plans ready for implementation;
https://htwws.org/santamonicaairport/
(Author notes, not part of the proposal)
-Examine the years that ADOS (American descendants of Survivors paid federal taxes but were not able to utilize public service. Examine displacement and communities that were intentionally burned t the ground by supremacists. Request reimbursement/hold percent of federal/state taxes to heal communities.
-Tenancy in common is a form of co-ownership of property in which each party owns an undivided interest that passes to his or her heirs at death. The interest is undivided 12 11.A.h
Packet Pg. 1712 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) because each tenant has rights in the whole property. Although ownership is in common, tenants may have equal or unequal shares.
-Joint tenancy is the joint ownership of property by two or more co-owners in which each co-owner owns an undivided portion of the property. On the death of one of the joint tenants, their interest is automatically passed to surviving tenants. -Real property- immovable property, a building, land, plants etc, (though buildings can actually be moved depending on).
-Just cause eviction in CLT - Community members causing violence when corrective action cannot be taken, not working. Racial violence & other forms of discrimination.
Peer court will recommend rehabilitation programs when permitted to do so, severe cases could result in immediate evictions.
-Land on Earth belongs to all of humanity.
-Land has not been fairly distributed to residents impacted by systematic housing violence as it relates to race & class.
-The aim of the Surplus Land Act (the "Act"); is to increase the availability of real property in California for affordable housing development by requiring the prioritization of affordable housing when selling or leasing public lands no longer necessary for agency use.
-"Feb. 5, 1866: Thaddeus Stevens Proposes Land Distribution Amendment" https://www.zinnedproject.org/news/tdih/thaddeus-stevens-freedmens-bill/ 13 11.A.h
Packet Pg. 1713 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -Foster City- examine the broken foster system, keeping families together whenever possible, family planning services, safe housing & family for youth that are not able to stay with their biological families.
To do;
-Write the state bar and include them on your housing emails. REQUIRE that the state bar authorize civil peers to oversee legal issues related to housing (LLP’s). -BLM the org must redirect funding into one trust that is overseen by a group of Black civil peers. Push money back into Black communities as direct UBI payment, as housing payments, treatment payments, crime & gang prevention, etc., etc. -Email OMBW/Watch for grants (GS)
-Civilian Eminent Domain of Public Land; communities protected from Climate arson; Free market exists for those that want to be part of it. -Establish Public Bank
-A PORTION of public land MUST remain PUBLICLY owned for use by the community.
-Agency divided into NSEW & Mid-City?!?! Civil Peer teams in NSEW & Mid-City ?? -If the BOS goes ROUGE, the social agency will partner with the state housing authority directly and override county BOS should they become non-compliant. 14 11.A.h
Packet Pg. 1714 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The Social Housing Authority
(created by Tieira Ryder; 4/25/22 https://htwws.org/social-housing-ca/) -representcal.org, why a constitutional convention is necessary, and how the CA constitution allows localities to abuse their position, allows illegal segregation as it relates to race & class.
-Examine pre-built tiny home/ADU placements in well put together communities that are affordable & supportive. Sheds are not tiny homes. Some residents already own tiny homes or they want to, can support themselves but need land. Communities likely could be supported in the valley.
15 11.A.h
Packet Pg. 1715 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1716 Attachment: Public Comments Received by City on Housing Element since February
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Packet Pg. 1717 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element
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Packet Pg. 1718 Attachment: Public Comments Received by City on Housing Element since February From: Frisco Fayer
To: Housing Update
Cc: Nancy Chou
Subject: May 26th ADU workshop
Date: Tuesday, May 31, 2022 10:03:57 AM
EXTERNAL
Good morning,
I missed the majority of the May 26th workshop your office hosted regarding ADUs in Santa Monica.
At the end of the presentation someone mentioned that the video and materials would be posted to the website.
Have they been posted? I have looked but cannot find them.
Thank you,
Frisco
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Packet Pg. 1719 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Dylan Cohen
To: Housing Update
Subject: Pico Boulevard (Santa Monica, CA) - Zoning & Housing Element Date: Wednesday, June 1, 2022 4:06:18 PM
Importance: High
EXTERNAL
Hello,
I am inquiring about the potential zoning and housing element change regarding Pico Boulevard, specifically between 20th and 30th street, with the current zoning as NC.
Below is my understanding of the current and potential change regarding this stretch of Pico Blvd.
Housing Element: The Property’s existing zoning will allow a 2-story project, retail at street level and one level of apartments above. The Property has recently been up zoned as a part of the city of Santa Monica’s new Housing Element which was passed last year in an effort to meet state RHNA housing requirements. Under the new zoning a 5-6 story building could be built. This new zoning which corresponds to the Housing Element (HE) will not take effect until it is approved by City Council. It was scheduled to go before City Council March 22 for approval. Due to recent state HCD scrutiny planning is revisiting the zoning density, which could affect the subject, and staff is working on an update to the HE which they are aiming to take back to Council sometime over the summer. The goal is now to finish the up zoning by October.
Can you please confirm (i) if the above paragraph is accurate (ii) is there a scheduled City Council Meeting for this soon, if so, what date and is there a date certain on finalizing (iii) what is the proposed FAR, Height Limit, Density, and Setbacks for this portion of Pico Blvd.
I really appreciate your insight and feedback on this. The best number to reach me to discuss is 310-403-1404.
Thank you,
Dylan Cohen
Associate
Pegasus Investments Real Estate Advisory Inc.
1901 Avenue of the Stars, Suite 630 | Los Angeles, CA 90067 P (310) 691-1350 x 129 | C (310) 403-1404 | F (310) 691-1353 [email protected]
www.PegasusInvestments.com
BRE Lic 02082314
The information above has been obtained from sources believed reliable. While we do not doubt its accuracy we have not verified it and make no guarantee, warranty or representation about it. It is your responsibility to independently confirm its accuracy and completeness. Any projections, opinions, assumptions, or estimates used are for example only and do not represent
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Packet Pg. 1720 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) the current or future performance of the property. The value of this transaction to you depends on tax and other factors which should be evaluated by your tax, financial, and legal advisors. You and your advisors should conduct a careful, independent investigation of the property to determine to your satisfaction the suitability of the property for your needs.
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Packet Pg. 1721 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: T
To: Planning CPC; [email protected]
Cc: Housing Elements@HCD; [email protected]; Housing Update; [email protected]; Council Mailbox; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Councilmember Bonin; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Mar Vista Voice; [email protected]; Wayne Liebman; Andrew Lewis; Leonora; Mike Draskovic; [email protected]; [email protected]; [email protected]; [email protected]; Livable Communities Initiative; Lindsay; Haley Feng; Hailey Reyna Subject: Public Hearing General Comment; May, 19, 2022 (Los Angeles Housing Element amendments) Date: Friday, May 6, 2022 8:29:14 PM
Attachments: SocialHousingAuthority.TieiraRyder.4-25-22.pdf PenmarGolfCourse+SMAirportproposal.TieiraRyder.pdf
EXTERNAL
Hello,
First, Thank You to the LA City planning team for the work that you all are doing. I have a general comment regarding the updates and I want to start by saying that we have a county-wide housing crisis and that we need to address that matter as such. Thus far, LA City is one of the main planning teams in Los Angeles County proving that they want to provide a compliant housing element and that they are actually working to further fair housing.
Other cities in Los Angeles county are actually hiring consultants to NOT submit compliant housing elements & they are trying to find ways to NOT build housing! #ILLEGAL
I believe that the LA team will need more support in rezoning from the state, specifically in capturing PUBLIC land from localities abusing their positions like Santa Monica City, Beverly Hills, and many others. We have plenty of public land across Los Angeles county that can be used for some of the outlined social housing models like CLTs, co-ops, and communityowned PS, affordable, & market-rate rental housing. There are many progressive advocates in Los Angeles that are ready to begin implementing a solid social housing policy today. We cannot rely solely on privately-owned housing, the class that is primarily being displaced (Blue-collar workers & residents with low to no income), need to be able to hold their own cards in the housing game. The "affordable threshold" continues to get higher and higher and it's true that, when we build more housing, rent should go down but even then, it still likely won't go down enough for some blue-collar workers & other residents with limited incomes (disabilities, students, retirees, etc).
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Packet Pg. 1722 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) I want to remind you what city we are in, we are in Los Angeles where the AirBnb market is BOOMING. There is currently not enough accountability/enforcement within the private housing market which is currently lending MANY of their units for AirBnb/Short term usage (establish a rental registry please). I want to kindly remind you that we are in a city where some ppl can afford to pay $5,000-$10,000 a month for rent but many essential workers, college students, retirees, & others cannot afford to pay that much. In my opinion, for community-owned affordable rental housing, the "affordable rent" price needs to be based on the average of the blue-collar essential worker class. It's not fair to include the high earners in that average. With community-owned housing, we can set an affordable market-rate price that will be cheaper than privately-owned market-rate rental housing but the average we set should be based on that class's total average. Once residents are housed in community-owned housing, let's go ahead and rent stabilize them to avoid displacement. I hope that made sense!
Attached, you will find a proposal for mixed-income housing, both rent & homeownership, for the incorrectly zoned Santa Monica airport. I was in the Venice/Santa Monica area today and strangely, the small airplanes leaving the "Santa Monica airport" were only flying low & circling over the Venice community. The small plane owners avoided flying over the Santa Monica residents so not to disturb them by causing noise & fuel pollution. If the state supports LA City, LA City can sue the FAA & SM City to win back over the airport that actually belongs to Venice & Mar Vista residents as much as it does Santa Monica residents. This should be a pretty easy win because 1.
Santa Monica's measure LC likely violates the state's "Surplus land Act" and Article 34 isn't relevant because the development isn't for low-income housing but for mixed-income. The incorrectly zoned airport along with penmar golf course will allow for a beautiful community-owned housing development that is surrounded by a large park/rec center/hospital. I've talked to many students at SMC that are in need of housing, we need to deliver on that for them!
Thank You again to the Los Angeles City planning team! I'm looking forward to furthering fair housing & ending the housing crisis. I believe that your team can lead by example because the truth is, we have a state-wide crisis
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Packet Pg. 1723 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) and we need all jurisdictions to do their part to eradicate poverty & to provide stable safe, clean, and affordable housing. "A Right to Housing" already exists under international law (Thank You to the person CC'd on this email for letting me know that)!
I'd recommend establishing a trust fund account for community-owned housing to maintain the quality of the community. I know the NIMBYS & some of our elected officials are going to do everything that they can to drop all of us off in the desert, but we can't allow that! This land belongs to all of us so says the Lord! NIMBYS can keep their SFH's if they want, but they do not own all the land around the SFH.
--
Best,
Tieira
https://htwws.org/santamonicaairport/
Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
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Packet Pg. 1724 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Carmen Joseph
To: Housing Update
Subject: Re: ADU grant funding
Date: Thursday, May 26, 2022 7:06:31 PM
EXTERNAL
Hi!
I’d like to be included on any email lists with regards to ADUs in SM and workshops in the future.
Thank you.
> On May 25, 2022, at 11:37 AM, Housing Update <[email protected]> wrote:
>
> Hi Carmen,
>
> Thank you for your interest. To attend the workshop all you need to do is access the meeting through one of the below methods. No prior registration is needed.
>
> When: Thursday, May 26, 2022, at 6:00-7:30 PM
>
> How to access the Virtual Public Workshop:
>
> * Via Web Browser: https://urldefense.com/v3/__https://primetime.bluejeans.com/a2m/liveevent/edhzygae__;!!OfuUnHCITYtmmjM!uVvuE-J9feTFbf5Km5VWEbAA_oE4wymVyj1GkGc7aS5rhxvWmvzlNrVO-qdmafc19QBKwiYSEfXjYqhIFnuu6vkWAfShzM$ >
> * Via Mobile Device:
>
> o Open this link : https://urldefense.com/v3/__https://primetime.bluejeans.com/a2m/liveevent/edhzygae__;!!OfuUnHCITYtmmjM!uVvuE-J9feTFbf5Km5VWEbAA_oE4wymVyj1GkGc7aS5rhxvWmvzlNrVO-qdmafc19QBKwiYSEfXjYqhIFnuu6vkWAfShzM$ >
> o Download the app if you don't have it already
>
> o Enter event ID : edhzygae
>
> * Via Phone:
>
> o Dial +1 (415) 466-7000
>
> o Enter the participant PIN: 1935240 followed by # to confirm. >
>
>
>
> Please email [email protected] if you have any questions > -----Original Message-----
> From: Carmen Joseph <[email protected]>
> Sent: Tuesday, May 24, 2022 4:12 PM
> To: Housing Update <[email protected]>
> Subject: ADU grant funding
>
> EXTERNAL
>
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Packet Pg. 1725 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) > I am interested in attending the virtual workshop on ADU grants. Please include me. Thank you. > Carmen Joseph
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Packet Pg. 1726 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Joanna Rodriguez-Noyola
To: Housing Update
Subject: RE: ADU Prototype Plans
Date: Thursday, March 3, 2022 11:45:29 AM
EXTERNAL
Thank you,
I was able to figure out the 311 messaging system for our ADU inquiries, do you know how long they take to reply usually?
For the prototypical plans, I could see the city of SM doing something similar to LADBS:
https://www.ladbs.org/adu/standard-plan-program/approved-standard-plans Thanks!
Joanna Rodríguez-Noyola, AIA
R-ND+A
r-nda.com
[email protected]
+1.760.209.3050
From: Housing Update
Sent: Thursday, March 3, 2022 11:00 AM
To: Joanna Rodriguez-Noyola
Subject: RE: ADU Prototype Plans
Hi Joanna,
There currently is no process to submit prototypical ADU plans. If you have any questions regarding any ADU standards, please submit an inquiry through the City’s 311 system… https://www.santamonica.gov/process-explainers/santa-monica-311 Thank you for taking the survey! If you have any additional input on issues that you have experienced, please feel free to reply to this email with them. Regarding upper story outdoor space, these standards were included to address privacy issues; however, I will take note of them for future consideration.
Best,
The Housing Team
From: Joanna Rodriguez-Noyola <[email protected]>
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Packet Pg. 1727 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Sent: Wednesday, March 2, 2022 6:54 PM
To: Housing Update <[email protected]>
Subject: ADU Prototype Plans
EXTERNAL
Hi,
I’m an architect working on several ADUs in Santa Monica and am interested in submitting Prototypical ADU plans through the city of Santa Monica, what is the process for this? I have filled out the housing element ADU survey but would also like to provide input to the planners based on comments I receive from clients (please increase the upper story deck area!).
Thank you!
Joanna Rodríguez-Noyola, AIA
R-ND+A
r-nda.com
[email protected]
+1.760.209.3050
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Packet Pg. 1728 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Erik Felix
To: Jing Yeo
Cc: Paavo Monkkonen; Housing Update; City of Santa Monica Subject: Re: Interested in learning more about your 6th Cycle Housing Element process Date: Thursday, April 14, 2022 10:56:36 AM
Attachments: Questions from UCLA AFFH Study.pdf
EXTERNAL
Hi Jing,
I received your out of office reply last week so just wanted to follow up. I tried calling the planning office but the phone number on the site just leads to voicemail. I spoke with the 311 operator and they said email is the most direct way to reach you. As I mentioned in my previous email, we were hoping to meet this month to discuss the city's experience developing its 6th Cycle Housing Element. Attached is more background on the project along with questions that would lead our conversation. I've also shared my availability again, and included an evening window of time for Tuesday in case that is more convenient for you.
Mondays: 9 am - 2 pm
Tuesdays: 4:30 pm - 6 pm
Thursdays: 3:30 pm - 6 pm
Fridays: 9 am - 6 pm
We look forward to hearing from you.
Best,
Erik
On Mon, Apr 4, 2022 at 8:06 AM Erik Felix <[email protected]> wrote:
Hello Jing,
My name is Erik Felix and I am a graduate student researcher with the UCLA Lewis Center for Regional Policy Studies. I am working with Professor Paavo Monkkonen on a research project regarding the 6th Cycle Housing Element update process. We are interviewing planners involved with this process in a few cities. Would you be available this month to discuss your experience developing the City of Santa Monica's Housing Element? Please let me know if there's a 30-60 minute window of time that works for you during the following days and times:
Mondays: 9 am - 2 pm
Thursdays: 3:30 pm - 6 pm
Fridays: 9 am - 6 pm
Best,
Erik
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Packet Pg. 1729 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Sharyl Beebe
To: Housing Update
Subject: RE: Join Us for a Workshop on Accessory Dwelling Units! Date: Thursday, May 19, 2022 6:53:37 PM
EXTERNAL
Yes, I have a question………….I don’t see a registration button or do I just save this email and click on the link at the correct time?
Sharyl Beebe, AICP, CERT
Prism Permits
PO Box 283
Malibu, CA 90265
310-403-4365
*Please note that mynormal business operations and schedules may be impacted by the COVID-19 situation, and are subject to change as I monitor and incorporate temporary policies and guidelines including those disseminated by WHO, CDC and other authorities. Thank you in advance for your patience and understanding during this challenging time.
CONFIDENTIAL NOTICE
This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by e-mail and destroy all copies of the original message.
From: Housing Update <[email protected]>
Sent: Thursday, May 19, 2022 11:36 AM
To: undisclosed-recipients:
Subject: Join Us for a Workshop on Accessory Dwelling Units!
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Packet Pg. 1730 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Join Us for a Virtual Workshop on Accessory Dwelling Units The City of Santa Monica is hosting a virtual public workshop to provide a project update and policy briefing on the City's Accessory Dwelling Unit (ADU) Accelerator project, funded by the Southern California Association of Governments (SCAG) and Regional Early Action Planning (REAP) grant program. You are being sent this invite as you have previously participated in a survey regarding your experience and/or interest in ADUs and have asked to be kept informed about this project.
The workshop’s purpose is to share project information, such as:
How ADUs can serve State and local housing needs
Key opportunities and challenges for ADUs in Santa Monica based on research performed thus far
Next steps for the project, including improved communication materials, handouts, and prototypical plans.
This will be another opportunity for you to provide input to help Santa Monica get the best results from this grant-funded project!
When: Thursday, May 26th, 2022 from 6:00PM to 7:30PM
How to Access the Virtual Public Workshop
Via Web Browser:
https://primetime.bluejeans.com/a2m/live-event/edhzygae Via Mobile Device:
https://primetime.bluejeans.com/a2m/live-event/edhzygae (requires download of mobile app)
Enter Event ID: edhzygae
Via Phone:
Dial: +1 (415) 466-7000
Enter the Participant PIN: 1935240 followed by #.
For more information, please visit the Housing Element website or email [email protected] if you have any questions.
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Packet Pg. 1731 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Join our Mailing List
Check out the Project Website
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Packet Pg. 1732 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Sharyl Beebe
To: Housing Update
Subject: RE: Join Us for a Workshop on Accessory Dwelling Units! Date: Friday, May 20, 2022 3:32:05 PM
EXTERNAL
Thanks! Have a happy weekend!
Shay
Sharyl Beebe, AICP, CERT
Prism Permits
PO Box 283
Malibu, CA 90265
310-403-4365
*Please note that mynormal business operations and schedules may be impacted by the COVID-19 situation, and are subject to change as I monitor and incorporate temporary policies and guidelines including those disseminated by WHO, CDC and other authorities. Thank you in advance for your patience and understanding during this challenging time.
CONFIDENTIAL NOTICE
This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by e-mail and destroy all copies of the original message.
From: Housing Update <[email protected]>
Sent: Friday, May 20, 2022 2:58 PM
To: Sharyl Beebe <[email protected]>
Subject: RE: Join Us for a Workshop on Accessory Dwelling Units! Hi Sharyl,
No registration needed. All you need to do is click on the link provided at the time of the workshop.
From: Sharyl Beebe <[email protected]>
Sent: Thursday, May 19, 2022 7:04 PM
To: Housing Update <[email protected]>
Subject: RE: Join Us for a Workshop on Accessory Dwelling Units!
EXTERNAL
Yes, I have a question………….I don’t see a registration button or do I just save this email and click on the link at the correct time?
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Packet Pg. 1733 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Join Us for a Virtual Workshop on Accessory Dwelling Units The City of Santa Monica is hosting a virtual public workshop to provide a project update and policy briefing on the City's Accessory Dwelling Unit (ADU) Accelerator project, funded by the Southern California Association of Governments (SCAG) and Regional Early Action Planning (REAP) grant program. You are being sent this invite as you have previously participated in Sharyl Beebe, AICP, CERT
Prism Permits
PO Box 283
Malibu, CA 90265
310-403-4365
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From: Housing Update <[email protected]>
Sent: Thursday, May 19, 2022 11:36 AM
To: undisclosed-recipients:
Subject: Join Us for a Workshop on Accessory Dwelling Units!
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Packet Pg. 1734 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) a survey regarding your experience and/or interest in ADUs and have asked to be kept informed about this project.
The workshop’s purpose is to share project information, such as:
How ADUs can serve State and local housing needs
Key opportunities and challenges for ADUs in Santa Monica based on research performed thus far
Next steps for the project, including improved communication materials, handouts, and prototypical plans.
This will be another opportunity for you to provide input to help Santa Monica get the best results from this grant-funded project!
When: Thursday, May 26th, 2022 from 6:00PM to 7:30PM
How to Access the Virtual Public Workshop
Via Web Browser:
https://primetime.bluejeans.com/a2m/live-event/edhzygae Via Mobile Device:
https://primetime.bluejeans.com/a2m/live-event/edhzygae (requires download of mobile app)
Enter Event ID: edhzygae
Via Phone:
Dial: +1 (415) 466-7000
Enter the Participant PIN: 1935240 followed by #.
For more information, please visit the Housing Element website or email [email protected] if you have any questions.
Join our Mailing List
Check out the Project Website
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Packet Pg. 1735 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins))
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Packet Pg. 1736 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Join Us for a Virtual Workshop on Accessory Dwelling Units From: Joel Cichowski
To: Housing Update
Subject: Re: Join Us for a Workshop on Accessory Dwelling Units! Date: Thursday, May 19, 2022 11:58:11 AM
EXTERNAL
Hi,
Is this workshop for building professionals or is it for homeowners? Thanks,
Joel
Joel Cichowski, Architect, Principal
site - specific architecture
1618 Ocean Park Blvd.Santa Monica, CA 90405
tel: (310) 663-8473 site-specificarchitecture.com
On May 19, 2022, at 11:36 AM, Housing Update
<[email protected]> wrote:
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Packet Pg. 1737 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) The City of Santa Monica is hosting a virtual public workshop to provide a project update and policy briefing on the City's Accessory Dwelling Unit (ADU) Accelerator project, funded by the Southern California Association of Governments (SCAG) and Regional Early Action Planning (REAP) grant program. You are being sent this invite as you have previously participated in a survey regarding your experience and/or interest in ADUs and have asked to be kept informed about this project.
The workshop’s purpose is to share project information, such as:
How ADUs can serve State and local housing needs
Key opportunities and challenges for ADUs in Santa Monica based on research performed thus far
Next steps for the project, including improved communication materials, handouts, and prototypical plans.
This will be another opportunity for you to provide input to help Santa Monica get the best results from this grant-funded project!
When: Thursday, May 26th, 2022 from 6:00PM to 7:30PM
How to Access the Virtual Public Workshop
Via Web Browser:
https://primetime.bluejeans.com/a2m/live-event/edhzygae Via Mobile Device:
https://primetime.bluejeans.com/a2m/live-event/edhzygae (requires download of mobile app)
Enter Event ID: edhzygae
Via Phone:
Dial: +1 (415) 466-7000
Enter the Participant PIN: 1935240 followed by #.
For more information, please visit the Housing Element website or email [email protected] if you have any questions.
Join our Mailing List
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Packet Pg. 1738 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Check out the Project Website
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Packet Pg. 1739 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Casey Nichols
To: Housing Update
Subject: Re: Lincoln / Ocean Park Project
Date: Wednesday, July 13, 2022 11:04:30 AM
EXTERNAL
Hello,
I am following up on my question regarding the Lincoln / Ocean Park project. What is the current status?
Thank you,
Casey
------- Original Message -------
On Tuesday, July 12th, 2022 at 9:23 AM, Casey Nichols <[email protected]> wrote:
Dear Santa Monica Housing Update Team,
I am reading through the latest update of Santa Monica's Housing Element. It looks like we're relying on the Lincoln and Ocean Park project for a substantial number of new homes.
What is the status of this project? Has it been entitled by the city? There's very little information available online.
Please let me know at your soonest convenience. I am working on a comment letter to HCD and I want to make sure I have all accurate information.
Thank you,
Casey
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Packet Pg. 1740 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Frisco Fayer
To: Housing Update
Cc: Nancy Chou
Subject: Re: May 26th ADU workshop
Date: Friday, June 3, 2022 10:02:43 AM
EXTERNAL
Hi, I'm following up re the below.
Thanks much,
Frisco
On Tue, May 31, 2022 at 10:03 AM Frisco Fayer <[email protected]> wrote:
Good morning,
I missed the majority of the May 26th workshop your office hosted regarding ADUs in Santa Monica.
At the end of the presentation someone mentioned that the video and materials would be posted to the website.
Have they been posted? I have looked but cannot find them.
Thank you,
Frisco
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Packet Pg. 1741 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Frisco Fayer
To: Housing Update
Cc: Nancy Chou
Subject: Re: May 26th ADU workshop
Date: Friday, June 10, 2022 9:18:11 AM
EXTERNAL
thanks!
On Thu, Jun 9, 2022 at 4:33 PM Housing Update <[email protected]> wrote:
Hello,
You can access the presentation and recording at the link below:
https://santamonica.gov/housing-element-update-2021-to-2029-adus Thank you for your interest,
Housing Team
From: Frisco Fayer <[email protected]>
Sent: Friday, June 3, 2022 10:02 AM
To: Housing Update <[email protected]>
Cc: Nancy Chou <[email protected]>
Subject: Re: May 26th ADU workshop
EXTERNAL
Hi, I'm following up re the below.
Thanks much,
Frisco
On Tue, May 31, 2022 at 10:03 AM Frisco Fayer <[email protected]> wrote:
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Packet Pg. 1742 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Good morning,
I missed the majority of the May 26th workshop your office hosted regarding ADUs in Santa Monica.
At the end of the presentation someone mentioned that the video and materials would be posted to the website.
Have they been posted? I have looked but cannot find them.
Thank you,
Frisco
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Packet Pg. 1743 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: [email protected] on behalf of Planning CPC To: T
Cc: [email protected]; Housing Elements@HCD; [email protected]; Housing Update; [email protected]; Council Mailbox; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Councilmember Bonin; [email protected]; [email protected]; [email protected]; [email protected]; councilmember.harris[email protected]; [email protected]; [email protected]; Mar Vista Voice; [email protected]; Wayne Liebman; Andrew Lewis; Leonora; Mike Draskovic; [email protected]; [email protected]; [email protected]; [email protected]; Livable Communities Initiative; Lindsay; Haley Feng; Hailey Reyna Subject: Re: Public Hearing General Comment; May, 19, 2022 (Los Angeles Housing Element amendments) Date: Wednesday, May 11, 2022 4:21:27 PM
EXTERNAL
Good afternoon,
Please note your initial submission has been received and it will be distributed accordingly to the City Planning Commission for the special meeting of May 19, 2022.
Thank you,
Cecilia Lamas, Commission Executive
Asst.
- City Planning Commission (CPC)
- Harbor Area Planning Commission
200 N. Spring St., Room 272
Los Angeles, CA 90012
T: (213) 978-1299 | Planning4LA.org
Note: Regular Day Off Alternating Friday
On Fri, May 6, 2022 at 8:28 PM T <[email protected]> wrote:
Hello,
First, Thank You to the LA City planning team for the work that you all are doing. I have a general comment regarding the updates and I want to start by saying that we have a county-wide housing crisis and that we need to address that matter as such. Thus far, LA City is one of the main planning teams in Los Angeles County proving that they want to provide a compliant housing element and that they are actually working to further fair housing. Other cities in Los Angeles county are actually hiring consultants to NOT submit compliant housing elements & they are trying to find ways to NOT build housing! #ILLEGAL
I believe that the LA team will need more support in rezoning from the state, specifically in capturing PUBLIC land from localities abusing their
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Packet Pg. 1744 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) positions like Santa Monica City, Beverly Hills, and many others. We have plenty of public land across Los Angeles county that can be used for some of the outlined social housing models like CLTs, co-ops, and communityowned PS, affordable, & market-rate rental housing. There are many progressive advocates in Los Angeles that are ready to begin implementing a solid social housing policy today. We cannot rely solely on privatelyowned housing, the class that is primarily being displaced (Blue-collar workers & residents with low to no income), need to be able to hold their own cards in the housing game. The "affordable threshold" continues to get higher and higher and it's true that, when we build more housing, rent should go down but even then, it still likely won't go down enough for some blue-collar workers & other residents with limited incomes (disabilities, students, retirees, etc).
I want to remind you what city we are in, we are in Los Angeles where the AirBnb market is BOOMING. There is currently not enough accountability/enforcement within the private housing market which is currently lending MANY of their units for AirBnb/Short term usage (establish a rental registry please). I want to kindly remind you that we are in a city where some ppl can afford to pay $5,000-$10,000 a month for rent but many essential workers, college students, retirees, & others cannot afford to pay that much. In my opinion, for community-owned affordable rental housing, the "affordable rent" price needs to be based on the average of the blue-collar essential worker class. It's not fair to include the high earners in that average. With community-owned housing, we can set an affordable market-rate price that will be cheaper than privatelyowned market-rate rental housing but the average we set should be based on that class's total average. Once residents are housed in communityowned housing, let's go ahead and rent stabilize them to avoid displacement. I hope that made sense!
Attached, you will find a proposal for mixed-income housing, both rent & homeownership, for the incorrectly zoned Santa Monica airport. I was in the Venice/Santa Monica area today and strangely, the small airplanes leaving the "Santa Monica airport" were only flying low & circling over the Venice community. The small plane owners avoided flying over the Santa Monica residents so not to disturb them by causing noise & fuel pollution.
If the state supports LA City, LA City can sue the FAA & SM City to win back over the airport that actually belongs to Venice & Mar Vista residents
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Packet Pg. 1745 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) as much as it does Santa Monica residents. This should be a pretty easy win because 1. Santa Monica's measure LC likely violates the state's "Surplus land Act" and Article 34 isn't relevant because the development isn't for low-income housing but for mixed-income. The incorrectly zoned airport along with penmar golf course will allow for a beautiful community-owned housing development that is surrounded by a large park/rec center/hospital. I've talked to many students at SMC that are in need of housing, we need to deliver on that for them!
Thank You again to the Los Angeles City planning team! I'm looking forward to furthering fair housing & ending the housing crisis. I believe that your team can lead by example because the truth is, we have a statewide crisis and we need all jurisdictions to do their part to eradicate poverty & to provide stable safe, clean, and affordable housing. "A Right to Housing" already exists under international law (Thank You to the person CC'd on this email for letting me know that)!
I'd recommend establishing a trust fund account for community-owned housing to maintain the quality of the community. I know the NIMBYS & some of our elected officials are going to do everything that they can to drop all of us off in the desert, but we can't allow that! This land belongs to all of us so says the Lord! NIMBYS can keep their SFH's if they want, but they do not own all the land around the SFH.
--
Best,
Tieira
https://htwws.org/santamonicaairport/
Walkable, bike-friendly communities that are affordable are the right of every
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Packet Pg. 1746 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) single human being. These communities are great for humanity, other species, and the Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
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Packet Pg. 1747 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Housing Update
To: Samuel Tolkin; Housing Update
Subject: RE: The ADU Workshop
Date: Thursday, June 9, 2022 4:32:55 PM
Attachments: image001.png
Hello Commissioner Tolkin,
You can access the presentation and recording at the link below:
https://santamonica.gov/housing-element-update-2021-to-2029-adus Thank you for your interest,
Housing Team
From: Samuel Tolkin <[email protected]>
Sent: Saturday, June 4, 2022 6:14 AM
To: Housing Update <[email protected]>
Subject: The ADU Workshop
EXTERNAL
I was wondering if staff had recorded this workshop which I had wanted to attend but at the last minute could not. If so was there a way I could access it.
Please advise.
Thanks,
Samuel Tolkin
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Packet Pg. 1748 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Samuel Tolkin
To: Housing Update
Subject: Re: The ADU Workshop
Date: Thursday, June 9, 2022 6:28:54 PM
Attachments: image001.png
EXTERNAL
Thank you.
Great!
-----Original Message-----
From: Housing Update <[email protected]>
To: Samuel Tolkin <[email protected]>; Housing Update <[email protected]> Sent: Thu, Jun 9, 2022 4:32 pm
Subject: RE: The ADU Workshop
Hello Commissioner Tolkin,
You can access the presentation and recording at the link below:
https://santamonica.gov/housing-element-update-2021-to-2029-adus Thank you for your interest,
Housing Team
From: Samuel Tolkin <[email protected]>
Sent: Saturday, June 4, 2022 6:14 AM
To: Housing Update <[email protected]>
Subject: The ADU Workshop
EXTERNAL
I was wondering if staff had recorded this workshop which I had wanted to attend but at the last minute could not. If so was there a way I could access it.
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Packet Pg. 1749 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Please advise.
Thanks,
Samuel Tolkin
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Packet Pg. 1750 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Housing Update
To: Nina Girvetz; Housing Update
Subject: RE: We missed the Housing webinar!
Date: Thursday, June 9, 2022 4:42:23 PM
Hello,
Apologies for the delayed reply.
You can access the presentation and recording at the link below:
https://santamonica.gov/housing-element-update-2021-to-2029-adus Thank you for your interest,
Housing Team
-----Original Message-----
From: Nina Girvetz <[email protected]>
Sent: Friday, May 27, 2022 2:01 PM
To: Housing Update <[email protected]>
Subject: We missed the Housing webinar!
EXTERNAL
Hi There!
We unavoidably missed the webinar yesterday evening, and wondered if it was recorded. We are also very interested in any programs the city has to help folks like us with duplex zoning and an ancient guest house we would love to raze and replace with a two unit rental.
We were the very first residential participants in the city’s remarkable solar initiative 15(?) years ago. We had such a great experience—and are hoping there is similar help for us in this regard.
I look forward to hearing from you!
Warmest regards,
Nina Girvetz
Ocean Park, Santa Monica
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Packet Pg. 1751 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Entertainers Unite
To: Sue Himmelrich; Phil Brock; Oscar de la Torre; Kristin McCowan; Christine Parra; Lana Negrete Subject: Save our Earth; Close the incorrectly zoned Santa Monica airport and build multi-family housing surrounded by greenery!
Date: Tuesday, February 22, 2022 7:33:12 PM
Attachments: SantaMonicaAirportproposal.pdf
EXTERNAL
Our coastal cities need fewer cars and more housing surrounded by open green space and fresh air. My GOD, look what we have done to the Earth, we cannot go on like this! From the heavy helicopter usage from police, the constant flying of airplanes, and the fuel from single usage vehicles, how much more can our Earth take? Did you all see how many people privately flew into and out of LA for the super bowl? Do residents that live here fulltime NOT deserve a quality life? Clean air? Affordable housing? Are tourists really more important than locals???! And wouldn't tourists have a better experience of locals were better-taken care of?!?!
Please support more housing that is surrounded by a large park and less parking storage on our coastal cities! Did we really build a massive freeway through a city instead of housing surrounded by rapid transit and open green space??? We cannot go on like this!
Linked below is the proposal that has been sent to the State Housing Authority & the State Attorney General Rob Bonta. We are going to take the FAA to court again to force the closure of the airport sooner than 2028. I'm not kidding when I say this, my breathing has changed in the last 10 years in LA and I'm a person that works out. Our air quality has changed and for the sake of this place we all call home, Earth, we must do more to protect her. I won't tell you my name in this email but in some languages it actually means Earth, so consider this a letter from Earth herself asking for your help.
With Love,
The Earth
https://htwws.org/santamonicaairport/
https://twitter.com/grescoe/status/1432333275738087426? s=20&t=8OPECBOaEaukuMjdKbnGeA
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Packet Pg. 1752 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 9/21/ Item 9-B
Mathew Millen <[email protected]>
Tue 9/20/2022 2:21 PM
To: Planning Commission Comments <[email protected]>;Planning <[email protected]>
1 attachments (1 MB)
HCDsanta2.pdf;
EXTERNAL
Opposition to Housing Element attached
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Packet Pg. 1779 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Agenda September 21
William Johnson <[email protected]>
Wed 9/21/2022 12:36 PM
To: Planning Commission Comments <[email protected]> Cc: Jing Yeo <[email protected]>;Planning <[email protected]>
EXTERNAL
Item 9-B
I own an 80+ year old triplex in Santa Monica on a lot zoned R-3 and 3,600 square feet. State law prohibits me from demolishing or remodeling with the result of less than 3 units. Santa Monica zoning law prohibits me from constructing more than 2 units given the size of the lot. The building is at the end of its useful life, and I am prohibited from building a single family home, duplex, triplex or anything on my own property. And the City proposes to make permanent the state prohibition on reducing units scheduled to expire in 2030. Do each of the members of the Planning Commission endorse this policy and outcome? If not, what remedies do they see or advocate for a property owner in my position? Sent from my iPhone
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Packet Pg. 1780 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Item 9b - SM Forward Letter
Carl Hansen <[email protected]>
Wed 9/21/2022 5:46 PM
To: Planning Commission Comments <[email protected]> 1 attachments (95 KB)
PC Letter 9B (21-Sep-22).pdf;
EXTERNAL
Dear Planning Commissioners,
Please find attached a letter from Santa Monica Forward commenting on Item 9B on your agenda tonight.
Best,
Abby Arnold and Carl Hansen
Co-chairs, Santa Monica Forward
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Packet Pg. 1781 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) September 21, 2022
Re: Agenda Item 9-B
Dear members of the Santa Monica Planning Commission:
Santa Monica Forward is highly concerned with the proposed revisions to the Housing Element. At the last minute, with little opportunity for community input, and after HCD has already approved the prior draft, you are now considering revisions to program implementation deadlines which will likely delay full Housing Element implementation by several years.
We fear that these significant revisions will risk HCD certification. The changes presented tonight are a multi-year delay, all the way out to the new statutory deadline, after Santa Monica had originally proposed faster implementation well in advance of the original deadline. In our view, this is a highly unnecessary risk unless we have unambiguous feedback from HCD that such delays are acceptable. HCD is well aware of how long housing takes to permit in Santa Monica and we are concerned that they will not look kindly upon us kicking the can down the road on implementation with such a pressing need for housing today. 1
Santa Monica Forward recommends a more reasonable implementation timeframe, in line with previous Housing Element drafts. At most, by June 30th, 2023. We believe that will guarantee HCD certification and avoid the risk of significant penalties with the state.
Sincerely,
Abby Arnold and Carl Hansen
Co-chairs, Santa Monica Forward
1 See HCD Annual Progress Report data ranking Santa Monica near last in California for time to entitlement and permitting; https://www.hcd.ca.gov/apr-data-dashboard-and-downloads
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Packet Pg. 1782 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: T
To: Housing Elements@HCD; [email protected]
Cc: Councilmember Bonin; [email protected]; [email protected]; [email protected]; [email protected]; Housing Update; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Subject: Social Housing Authority- Los Angeles
Date: Tuesday, August 9, 2022 2:10:06 PM
Attachments: PenmarGolfCourse+SMAirportproposal.TieiraRyder.pdf SocialHousingAuthority.TieiraRyder.4-25-22.pdf
EXTERNAL
Hello HCD,
My name is Tieira Ryder and I'm a Los Angeles based housing advocate that is currently working with other community members that have the hopes of bringing forward a Social Housing Authority. We have too many moving parts of the "housing and no home services" in Los Angeles county and we must create a streamlined housing system that is going to work for all LA residents. Further, we cannot continue to allow the private housing market to be the only system of housing available to the people of LA that have varying housing needs, a private market that has proved very unreliable by the way.
Under the social housing authority, we would have one county-led housing system that operates in each part of LA (NSEW + unincorporated). We would have teams working to develop new social housing for mixed-income residents, new housing developments for PSH, affordable housing homeownership options for LA residents, and rehabs of existing/empty buildings across LA. Further, we would establish ONE housing trust account where all money meant for housing and homeless services would go into.
I'm also looking into asking working-class residents to front their loans for ownership developments and asking blue-collar workers to leave a portion of their tax dollars into the trust account, to withhold a portion of federal/state taxes until we have the housing that is necessary for all of LA.
The social housing team would work in collaboration with the planning4LA team while overriding all other authorities. Our primary focus would be social housing and public land use. I'm asking that the state step in and override local jurisdictions like Beverly Hills, Santa Monica, & others to give the people access to the PUBLIC land that they need. We were promised affordable housing 10 years ago and we still don't have it. We've waited long
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Packet Pg. 1783 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) enough and we cannot wait any longer.
Attached, you will find my proposal for social housing. Along with community ownership of rental properties, I'd like the social housing teams to handle CLT's, co-ops, and TOP. Thank You for your attention regarding the matter of housing that was promised generations ago but still hasn't come.
One last story before I go, in 2016 I worked for a tech company in Santa Monica. I was there for 2-3 years or so and during that time I applied for affordable housing in Santa Monica. I sent the information that was needed.
Since that time I have been displaced from the Westside and I was laid off from that tech position. Even though I applied for housing at that time, Santa Monica City is now saying that they don't have the information that is needed to get affordable housing under whatever "guidelines" they've created. I worked in the city for a period of time and was not able to secure housing in that time and the city has mysteriously lost the information that I provided to them. How can we continue with a non-functioning housing system like this? Santa Monica brought tech jobs into the city and now refuses to provide housing for workers. The 10FWY easy during the morning rush is a testament to bad housing policy, it's climate arson against the Earth.
Please let me know a time when you're available to speak. I'm looking forward to hearing from you!
Best,
Tieira
https://htwws.org/santamonicaairport/
Walkable, bike-friendly communities that are affordable are the right of every single human being. These communities are great for humanity, other species, and the
11.A.h
Packet Pg. 1784 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) Earth itself! Everything in the HUE-MANS life does NOT need to be a drive away.
11.A.h
Packet Pg. 1785 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: T
To: Housing Elements@HCD
Cc: Cc:; [email protected]; Mayor Helpdesk; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; councilmember.ridley[email protected]; Councilmember Bonin; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; councilmember.harris[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; housing; [email protected]; [email protected]; [email protected]; [email protected]; Black Agenda-SM; [email protected]; Planning Commission Comments; Housing Update; [email protected]; [email protected]; [email protected]; cc: Timmi Tway; Cindy Gordon; Haley Feng; Leonora; [email protected]; [email protected]; Sue Himmelrich; SmHousing Mailbox; Gleam Davis; Council Mailbox; Christine Parra; Lana Negrete; Oscar de la Torre; Santa Monica Black Lives Assc.; Kristin McCowan; Phil Brock; [email protected]; [email protected]; Ashley London; [email protected]; Andria McFerson; Alexander Flamer IV; Barry Snell; [email protected]; [email protected]; Miss Compton; Keith Coleman; [email protected]; [email protected]; WESTCOAST COLLECTIVE PODCAST; [email protected]; Karen S. Gunn; Delana Gbenekama; Ericka L; Nikel E Hall; Erika Mitchell; [email protected]; George Brown; Jonathan Gregory; [email protected]; Robin Gordon; Janeen Jackson; Kimberly Herron; [email protected]; [email protected]; Donna Brown; Joseph Metoyer; Jennell Maze; Kathryn Jeffery; Rana Kirkland; Kera Blades; Tony Murphy; Mulugeta Tad; Tieira Ryder; Robbie Jones; Nat Trives; [email protected]; [email protected]; Andrew Lewis; [email protected] Subject: Thank You HCD for declining Santa Monica city"s non-compliant housing element for the 2nd time! Date: Thursday, February 10, 2022 2:38:07 PM
Attachments: SantaMonicaAirportproposal.TieiraRyder.pdf HCDCommnts (1).pdf
EXTERNAL
Thank You HCD for declining Santa Monica city's non-compliant housing element for the 2nd time in a row! To Santa Monica Mayor Sue Himmelrich, to the Santa Monica city council (PHIL BROCK WE NEED YOU), & to the Santa Monica planning team, housing advocates are absolutely ready to have a meaningful conversation on how to bring the housing element into compliance if only you'd kindly return our emails and calls.
Attached to this email you will find a proposal for safe, clean, & affordable housing at the incorrectly zoned Santa Monica airport. The airport MUST close sooner than 2028 so that we can begin building majority communityowned affordable & market housing that is surrounded by a large open park.
Along with the airport, the plan includes Penmar golf course. Along with these locations, I'm happy to discuss other areas that are suitable for housing, both market-rate & affordable.
Residents from the working middle & blue-collar class, senior citizens, students, and many others all deserve access to housing that they can afford.
Cities like Santa Monica have been hoarding land & other resources that are desperately needed to live a happy and healthy life! I kindly request that all mentioned, including the state Attorney General, Rob Bonta,
11.A.h
Packet Pg. 1786 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) consider this proposal so we can begin to restore JUSTICE to the community members that are owed it!
Lastly, I said this in my last email and I want to repeat it again because I DO HEAR the concern from community members. It is not lost on me that we need critical investments in corrective behavioral, mental, and rehabilitation healthcare. It's critical that we invest in the well-being of residents, specifically those dealing with disorders/illnesses that could cause them to react violently towards others. I understand that some people are just violent because of their ego, but some ppl are violent because they are not mentally well. To leave them without the services that they need is a crime against humanity, it's a crime against the community that we claim we all want to keep safe! I also know that the violent conditions of poverty are causing most of the problems that we are seeing.
On a personal side note; I'm working on a personal story about generational displacement at the hands of systematic violence. You can read more about that here; https://diaryoftieiraryder.com/how-the-west-was-saved-blackhistory/.
Thank You again to Paul & the HCD team for rejecting the noncompliant housing element. I'm glad that I & other wonderful housing advocates were mentioned & taken into consideration in the rejection letter that was sent to Santa Monica City. We are passionate about the work that we are doing and we know that the work we are doing will benefit and make all of our lives much better! I'm excited for the re-birth of our nation and I'm glad that you are too!!!
Thank You to all the progressive housing advocates as well that are cc'd on this email!
Tieira Ryder
www.HTTWS.org/santamonicaairport
11.A.h
Packet Pg. 1787 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Samuel Tolkin
To: Housing Update
Subject: The ADU Workshop
Date: Saturday, June 4, 2022 6:14:13 AM
EXTERNAL
I was wondering if staff had recorded this workshop which I had wanted to attend but at the last minute could not. If so was there a way I could access it.
Please advise.
Thanks,
Samuel Tolkin
11.A.h
Packet Pg. 1788 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Mail Delivery Subsystem
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Subject: Undeliverable: Join Us for a Workshop on Accessory Dwelling Units! Date: Thursday, May 19, 2022 11:38:04 AM
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From: Housing Update <[email protected]>
Subject: Join Us for a Workshop on Accessory Dwelling Units! Thread-Topic: Join Us for a Workshop on Accessory Dwelling Units! Thread-Index: Adhrr1Z93AIB6iX2QC6vyWJ3/ioqVA==
Date: Thu, 19 May 2022 18:36:24 +0000
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11.A.h
Packet Pg. 1789 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Merlee konecki
To: Housing Update
Subject: Way TOO MUCH
Date: Saturday, August 20, 2022 7:58:28 AM
EXTERNAL
Hello, we are citizens of Santa Monica for over 50 years and see that there is TOO MUCH HOUSING DEVELOPMENT in our small city. "WHY" when we need water as we are in drought conditions. It also LOOKS BAD as TOO CROWDED! Again "WHY" I am waiting for your response!
Merlee J. Konecki
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Packet Pg. 1790 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Nina Girvetz
To: Housing Update
Subject: We missed the Housing webinar!
Date: Friday, May 27, 2022 2:01:34 PM
EXTERNAL
Hi There!
We unavoidably missed the webinar yesterday evening, and wondered if it was recorded. We are also very interested in any programs the city has to help folks like us with duplex zoning and an ancient guest house we would love to raze and replace with a two unit rental.
We were the very first residential participants in the city’s remarkable solar initiative 15(?) years ago. We had such a great experience—and are hoping there is similar help for us in this regard.
I look forward to hearing from you!
Warmest regards,
Nina Girvetz
Ocean Park, Santa Monica
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Packet Pg. 1791 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) From: Elizabeth Lerer
To: Housing Update
Subject: Workshop on Objective Design Standards
Date: Monday, August 22, 2022 9:06:54 AM
EXTERNAL
Dear Staff,
Please make a recording of this “workshop” available for those that have a scheduling conflict.
Please notify me about how to access a recoding of the "Workshop on Objective Design Standards”.
Thank you,
Elizabeth Lerer
[email protected]
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Packet Pg. 1792 Attachment: Public Comments Received by City on Housing Element since February 2022 (5191 : Housing Element Adoption (90 mins)) 1 Vernice Hankins
From: Daniel Galamba <[email protected]>
Sent: Thursday, October 6, 2022 9:19 AM
To: councilmtgitems; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Sue Himmelrich; Kristin McCowan; Oscar de la Torre; Daniel Galamba
Subject: City Council Meeting Oct 11, 2022 Item 11.A.: Please oppose Approval of Addendum to FEIR for 6th Cycle Housing Element to City's General Plan and adoption of 6th Cycle Housing Element of City's General Plan
EXTERNAL
The item number was not included in my e‐mail below. Thank you.
Dr Daniel Galamba
________________________________________
From: Daniel Galamba <[email protected]>
Sent: Monday, October 3, 2022 2:42 PM
To: [email protected]; [email protected]; Phil Brock; Christine Parra; [email protected]; [email protected]; [email protected]; [email protected]; Daniel Galamba Subject: City Council Meeting Oct 11, 2022: Please oppose Approval of Addendum to FEIR for 6th Cycle Housing Element to City's General Plan and adoption of 6th Cycle Housing Element of City's General Plan Dear City Council,
I urge you to oppose approval of the Addendum to FEIR for the 6th Cycle Housing Element to the City's General Plan and adoption of the 6th Cycle Housing Element of the City's General Plan.
Approval of this Plan would require at least 8,895 new units in Santa Monica resulting in a population increase of about 20%. We don't have the roads and infrastructure and support services to accommodate a 20% population increase.
Also, this 20% increase is completely unrealistic. California's, Los Angeles County's and Santa Monica's population has increased 2‐3% over the past 10 years, not 20%. Out of the 8,895 units of housing being required by the State, 1,156 units (13%) are acknowledged as the true future organic growth requirement of the city in the next eight years corresponding to a population increase of about 2.5%, not 20%. The remaining 7,739 units are simply so developers can make more money at the expense of the people of Santa Monica. This overdevelopment will destroy our City of Santa Monica and then people won't want to live in Santa Monica anymore or come to Santa Monica anymore and then we'll go downhill as happened in Westwood and West Los Angeles in the 1980's when overdevelopment was allowed to run rampant.
Make no mistake about it. These 8,895 units will be done at the expense of destroying our low and moderate income rent controlled housing and replacing it with luxury housing as happened in Westwood and West Los Angeles in the 1980's. This happened to me personally when a developer purchased our 2‐story moderate income rent controlled apartments and destroyed them and replaced them with a big, ugly 4‐story condominium building that only rich people could afford and were not under rent control. We've already lost about 9,000 rent‐controlled apartments here in Santa Monica since the Ellis Act took effect and we shouldn't encourage the loss of more. Otherwise, we will end up being a bi‐furcated city with the rich at the top, the poor at the bottom in public housing and not much in between. I want Santa Monica to be a city where people of various economic levels can afford to live.
I understand that about 90% of the cities in Southern California have not had their plans approved yet by the State, about 180 cities. I recommend that we join with many of them in a lawsuit against the State as well as having our own Item 11.A
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Packet Pg. 1793 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) 2 lawsuit against the State. Force the State to accept the 1,156 units acknowledged as the true future organic growth requirement of the city in the next eight years, not 8,895 units. Don't roll over and play dead to the State or the Southern California Association of Governments, SCAG. The survival of our City of Santa Monica depends upon it. Thank you.
Sincerely,
Dr Daniel Galamba
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Packet Pg. 1811 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
September 2, 2022
John Keho
Planning and Development Services Director
City of West Hollywood
8300 Santa Monica Boulevard
West Hollywood, CA 90069
Dear John Keho:
RE: 8500 Santa Monica Boulevard – Letter of Technical Assistance The purpose of this letter is to provide technical assistance to the City of West Hollywood (City) regarding the mixed-used infill project to be located at 8500 Santa Monica Boulevard. The proposed project would result in the construction of a six-story, 30-unit mixed-use building containing ground floor commercial space and upper story market-rate and affordable housing units. The project would provide three units that would be affordable to very low-income (VLI) households, two units that would be affordable to moderate income (MI) households, and 25 market rate units. The proposed project utilizes the State Density Bonus Law (SDBL) (Gov. Code, § 65915) to achieve a density bonus and is subject to the City’s inclusionary zoning requirements.
The California Department of Housing and Community Development (HCD) received a complaint regarding the subject project, and the City requested technical assistance from HCD regarding the relationship of the SDBL and the City’s inclusionary zoning ordinance (Ordinance) (WHMC, § 19.22.030). Specifically, the City seeks guidance on whether the requirement that a project include one MI unit for every VLI or LI unit conflicts with state housing law (especially the SDBL). Additionally, the City seeks guidance on how to best calculate base density in a zone without an associated dwelling units per acre density standard and how to consider concession requests that would increase a project’s FAR. Coincidentally, these latter topics are addressed in the August 31, 2022 Letter of Technical Assistance to the City of Santa Monica. That letter will be provided to the City instead of replicating the information in this letter.
The City’s Ordinance applies a 20% inclusionary requirement on all developments containing more than ten housing units. Applied to the subject project, this means that 5 units1 of the 22 base density units must be affordable. However, the Ordinance requires that for every VLI or LI unit provided, the applicant must also provide a MI unit. (WHMC, § 19.22.030(F)). The applicant argues that this requirement reduces the economic 1 Rounded up to 5 units from 4.4 units
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Packet Pg. 1812 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) feasibility of SBDL-enabled projects because, in practice, it requires that a project include more affordable units to qualify for a density bonus than are required by the SDBL. The applicant indicates that it would have preferred to construct 4 VLI units and 1 MI unit (to earn an additional SDBL concession) but were disincentivized from doing so because it would necessitate adding another MI unit. It should be noted that the SDBL offers much greater incentives for projects that include VLI/LI units than MI units, thereby incentivizing the former. For instance, to achieve the maximum 50% density bonus, a project needs to provide only 15% VLI units compared to 44% MI units (Gov.
Code, § 65915, subd. (f)). Conversations with City staff indicate that the mandated MI unit requirement is in place to support the City in its effort to produce enough housing for moderate-income households. Absent this requirement (the City contends), SDBLenabled projects would largely consist only of VLI/LI units and market rate units. This letter explores the ways that inclusionary zoning ordinances and SDBL implementation ordinances can and should be harmonized to best achieve the important functions of each.
Inclusionary Zoning
Inclusionary zoning is a vitally important affordable housing production tool used across California. Properly implemented, it can and has resulted in the production of significant amounts of deed-restricted affordable housing – often without the need of government subsidy. Unsurprisingly, many local agencies have adopted or are considering adopting inclusionary zoning ordinances. HCD strongly supports these efforts. However, some inclusionary requirements can hinder, rather than facilitate, the production of affordable housing. This is because inclusionary requirements can sometimes negatively affect the economic feasibility of residential development projects. A project that is not economically feasible will not be constructed and will provide no affordable units at all.
The state inclusionary zoning statute addresses these limitations, providing that a local agency must provide alternative means of compliance (e.g., in lieu fees) and that rental inclusionary requirements in excess of 15% may be subject to review by HCD to consider economic feasibility (Gov. Code, §§ 65850, subd. (g); 65850.1). For more information, please see HCD’s Rental Inclusionary Housing Memo.
State Density Bonus Law
First adopted in 1979 and strengthened over the years, the SDBL is one of the most powerful tools in the production of affordable housing. The SDBL facilitates both the construction of 100% affordable projects as well as projects that provide primarily market rate units. It allows the latter to build more market rate units than would typically be allowed in exchange for including affordable units. Like with inclusionary zoning requirements, the affordable units are often provided without the use of government subsidy. Within the context of market rate development, the SDBL is explicit regarding the importance of maintaining the economic viability of projects. It provides that, “The Legislature finds and declares that the intent behind the Density Bonus Law is to allow Item 11.A
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Packet Pg. 1813 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) public entities to reduce or even eliminate subsidies for a particular project by allowing a developer to include more total units in a project than would otherwise be allowed by the local zoning ordinance in exchange for affordable units. It further reaffirms that the intent is to cover at least some of the financing gap of affordable housing with regulatory incentives, rather than additional public subsidy.” (Gov. Code, § 65915, subd. (t).) The SDBL provides direction regarding the relationship between itself and inclusionary zoning requirements. It confirms that an affordable unit provided to satisfy an inclusionary requirement also earns the applicant the benefits and protections of the SDBL (e.g., a density bonus, concessions, development standard waivers, etc.) (Gov.
Code, § 65915, subd. (o)(6).) It also provides that an affordable unit in a SDBL-enabled project is not subject to affordable housing impact fees, including inclusionary zoning fees and in-lieu fees. (Gov. Code, § 65915.1).
Relationship to SDBL
Beyond the language provided by the SDBL, a few court cases address situations in which local ordinances or interpretations have affected the mechanics of the SDBL.
Chief among them is Latinos Unidos Del Valle De Napa Y Solano v. County of Napa2 which settled the matter of whether an affordable unit can serve both as an “inclusionary unit” meeting a local inclusionary zoning requirement and as a “target unit” qualifying a project for a density bonus. It can, and the statute was subsequently amended to reflect this. If this were not the case, for instance, a project attempting a earn a 50% density bonus by providing 15% VLI units would need to provide 15% affordable units to meet the 15% inclusionary requirement and an additional 15% affordable units to earn the density bonus. This would require the project to provide 30% affordable units – twice the amount contemplated by either the SDBL or the local inclusionary ordinance. A more recent case, Schreiber v. City of Los Angeles reinforces the finding made in Latinos, “A local ordinance is preempted if it conflicts with the density bonus law by increasing the requirements to obtain its benefits.”3 These cases provide a helpful lens through which to evaluate the practical effects of local ordinances upon the operation of the SDBL.
Local agencies should maintain an awareness of potential unintended impacts of local inclusionary requirements on SDBL applications.
The City should be prepared to grant a request for a SDBL concession to modify provisions of the inclusionary ordinance, especially ordinances that mandate the level of affordability of inclusionary units or their ratios. The SDBL can be used to modify or waive provisions of an inclusionary ordinance. For example, a mixed-income project that relies on tax credits may need to waive a requirement that affordable units be dispersed among the market rate units. This is because tax credits and other affordable housing funding programs sometimes require the affordable units to be consolidated within a single building or on a separate parcel.
2 (2013) 217 Cal.App.4th 1160, 1165-66 [159 Cal.Rptr.3d 284, 287-88]. 3 (2021) 69 Cal.App.5th 549, 558 [284 Cal.Rptr.3d 587, 594].
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Packet Pg. 1814 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) Governmental Constraints in Housing Element Law
Housing elements are required to contain analysis of potential and actual governmental constraints on the development of housing for all income levels. (Gov. Code, § 65583, subd. (a)(5).) This includes, but is not limited to, analysis of land use controls, building codes and their enforcement, and locally adopted ordinances that directly impact the cost and supply of residential development. After identifying governmental constraints, the City must implement programs to remove those governmental constraints to the development of housing where legally possible. (Gov. Code, § 65583, subd. (c)(3).) This analysis extends to a local agency’s inclusionary ordinance. As described above, under Government Code section 65850.1, an inclusionary requirement of 15% or less is not subject to scrutiny by HCD. Above this percentage, however, the local agency should carefully consider local development conditions to ensure that a higher percentage would not constitute a governmental constraint by rendering projects economically infeasible. HCD has observed that typically inclusionary requirements are in the 15-20% range. This is not to say that a higher or lower level is categorically unreasonable, but that this range has been proven functional in many areas (especially in high-cost, highdevelopment-pressure areas).
With a base density of only 22 units, the subject project does not present the most helpful scenario to examine how the City’s Ordinance relates to the SDBL. Instead, consider a hypothetical scenario in West Hollywood where the base density of a site allows 100 units and the developer seeks a 35% density bonus (35 units) by providing 20% LI units. The project would be required by the Ordinance to set aside 20 units (20% of 100 units) as affordable housing. To earn the density bonus, 20 units (20% of 100 units) would have to be LI units per the SDBL. On its surface, this project would appear to handily meet the City’s inclusionary requirements and the eligibly threshold of the SDBL. However, the mandated MI units requirement necessitates an additional 19 MI units.4 This results in a substantially higher percentage of affordable units than required by the SDBL, as summarized in the table below.
4 Per the WHMC, § 19.22.030 F. “…When two or more affordable units are constructed, the units shall be allocated alternately with the first unit allocated for a low or very low income household and the second allocated for a moderate income household, alternative between low or very low, and moderate income until all units are assigned a level of affordability.”
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Packet Pg. 1815 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) Overall Units LI Units MI Units Market Rate
Units
Affordable %
of Overall
Project
Without
Mandated
MI Units
135 20 0 115 14.8%
With
Mandated
MI Units
135 20 19 96 28.9%
It is the overall percentage of affordable units in a project that is of primary concern when evaluating economic feasibility. By requiring that 28.8% of the overall development be made up of affordable units, the City is in practice imposing an inclusionary requirement nearly 50% higher than its generally applicable 20% and significantly higher than the requirements of the SDBL. This may reduce the economic feasibility of the project because while affordable units are similarly expensive to build as market-rate units, the affordable units do not generate equivalent income. SDBL enables developers to build affordable housing without government subsidy – by allowing the allowing the market rate units to offset the costs of the affordable units.
The City’s mandated moderate-income unit requirement makes this more difficult and may constitute a governmental constraint in its current form.
It should be noted that the City’s practice of allowing an applicant to combine multiple density bonuses may lessen the real-world impact of the mandated moderate unit requirement. However, this practice is problematic for several reasons. First, it is not codified, so applicants have no way of knowing about it when planning a project.
Second, it can only be used to achieve up to the SDBL-defined maximum of a 50% density bonus, which may limit its compensatory value in certain circumstances. Third, no bonus is given until the 10% minimum threshold is met for certain income categories, which limits its use on smaller projects (like the subject project).
Recommendations
HCD makes the following recommendations to help the City implement both the City’s local inclusionary ordinance and the SDBL. This guidance is tailored to West Hollywood but is also intended to be helpful to other jurisdictions. • Substitutions. Allow more deeply affordable units to be substituted for less deeply affordable units. For example, an applicant should be able to substitute a VLI for a MI unit if they so desire. This approach is consistent with the SDBL’s approach to incentivizing more deeply affordable units. It also alleviates concerns that the local agency is disincentivizing more deeply affordable units in favor of less deeply affordable units – and risking fair housing and discrimination complaints.
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Packet Pg. 1816 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) • Upper Limit to Inclusionary Requirement. Inclusionary requirements that mandate that the units be provided at certain affordability levels or in certain ratios of affordability levels should only apply up to the point that the project meets the total inclusionary percentage required. Once the overall affordability threshold is met, no additional inclusionary units should be required regardless of any affordability level ratios. Consider the example of a jurisdiction where the generally applicable inclusionary requirement is 20% and there is a one-to-one ratio requirement of MI to VLI/LI units. If the applicant proposes less than 20% affordable units to achieve a density bonus (e.g., 15% VLI to achieve the maximum density bonus) the jurisdiction would require that 5% additional affordable units be added to the project to reach the 20% inclusionary threshold despite the fact that its ratio would require 15% MI units. • Integrate Language. The provisions of the City’s inclusionary ordinance and its SDBL implementation ordinance should be integrated with the expectation that projects will be subject to both. The benefits and protections of the SDBL apply to all projects that meet the statutory minimum percentage of affordable units.
This is to say that in jurisdictions with inclusionary zoning requirements the effects of the SDBL should be anticipated. When drafting the ordinance, a local agency should consider a diverse range of project types to explore how requirements affect each. As a starting point, the local agency should consider large vs. small projects and projects that rely on the seven eligibility categories of the SDBL (Gov. Code, § 65915, subd. (b)(1)(A-G).) Finally, the analysis should consider the final overall percentage of affordable units in each scenario to most accurately evaluate economic feasibility.
Conclusion
HCD applauds West Hollywood’s commitment to affordable and recognizes the challenges of harmonizing State housing law and local ordinances. HCD appreciates the City’s pragmatic and progressive approach to housing policy. This letter is intended to provide helpful context and guidance and help local agencies throughout the state work to achieve their housing goals. If you have questions or need additional information, please contact Brian Heaton at [email protected].
Sincerely,
Shannan West
Housing Accountability Unit Chief
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Packet Pg. 1817 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins))
(310) 451-3669
October 10, 2022
VIA E-MAIL
Santa Monica City Council
1685 Main Street, Room 102
Santa Monica, CA 90401
Re: Agenda Item 11-A
Adoption of Resolution Amending the 6th Cycle (2021-2029) Housing Element to the City’s General Plan and Approval of Addendum to the Final Environmental Impact Report for the 6th Cycle (2021-2029) Housing Element
Our File No. 639.67
Dear Councilmembers:
This letter is submitted on behalf of the Santa Monica Housing Council (“SMHC”) regarding the City’s proposed Amended 6th Cycle Housing Element. I am writing with regard to Programs 2.D and 2.C.
Program 2.D
Program 2.D reads as follows:
The City shall update the density bonus ordinance, Santa Monica Municipal Code Chapter 9.22, to ensure consistency with State Density Bonus Law and integration with the City’s land use system, including the AHPP. The ordinance will clarify how to apply State density bonus law in the City’s commercial and mixed-use districts that do not have maximum density controls, including application of State density bonuses to floor area dedicated to residential uses.
The amendments to the Municipal Code shall also set forth a voluntary by-right menu of incentives & concessions that do not require following the process under Government Code Section 65915(d) for approval. Requests for “off-menu” [email protected]
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Packet Pg. 1818 Attachment: Written Comments (5191 : Housing Element Adoption (90 mins)) Santa Monica City Council
October 10, 2022