Written Comments — Santa Monica City Council, August 22, 2023

August 20, 2023
Subject: OPPOSE - 16 L
Dear Santa Monica City Council,
We are disappointed to see some Councilmembers yet again hinting at the possibility of backing out of our Housing Element promises. AHPP, our local zoning, and their interaction with State density bonus law is all well defined in our Housing Element and any changes now to limit housing production would be in violation of state law and risk bringing the Builder’s Remedy back to Santa Monica.

However, for those who need a refresher, or for those who want to inaccurately argue that density bonus law was somehow unknown, we recommend watching this video clip of Councilmember Phil Brock and Planning Director David Martin discussing how State density bonus law allows projects to move forward at a larger size. https://www.youtube.com/watch?v=GNyVttdwgOk&t=16192s
The Housing Element has been adopted, the rezoning is done, the Builder’s Remedy projects have been settled, and state law says we’re now locked in. Please, stop pursuing these fruitless efforts to make changes and let’s move on to other issues which deserve this Council’s full attention.

Sincerely,
Bradley Ewing and Carl Hansen
Co-Chairs, Santa Monica Forward
Item 16.L
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1 Vernice Hankins
From: Andrew Hoyer <[email protected]>
Sent: Monday, August 21, 2023 10:26 AM
To: councilmtgitems; Lana Negrete; Phil Brock; Clerk Mailbox; Christine Parra; Gleam Davis; Jesse Zwick; Caroline Torosis; Oscar de la Torre; David White
Cc: Mouse Kim; Jen Regan; Mid City Neighbors; Stacy Dalgleish; Ellen Hannan; William Hamilton; Daniel Galamba
Subject: 8/22/28 City Council Meeting Item 16-L

EXTERNAL
Dear City Councilmembers,
The Board of Santa Monica Mid City Neighbors has voted to take a position on Item 16- L. It appears that the City Council was unaware of the full extent of the impacts of their decision to tie the state density bonus to the Affordable Housing Production Program. Given that it is now clear that this decision will actually reduce the amount of affordable housing to be built in Santa Monica and will lead to eight-story buildings throughout the entire city instead of only Downtown (the compromise forced on the public during the creation of the Downtown Community Plan) we ask that you revisit and reverse this uninformed and unwise decision.

Thank you,
Andrew Hoyer
SMMCN Board President
There is only one moment in time when it is essential to awaken. That moment is now. - Buddha
Item 16.L
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From: Tricia Crane <[email protected]>
Sent: Monday, August 21, 2023 10:39 AM
To: councilmtgitems; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; Denise Anderson-Warren
Subject: Support for Agenda Item 16-L - Call for review and full disclosure of Compounding impact of AHPP and the State Density Bonus

EXTERNAL
To: Santa Monica City Council and City Manager
From: Northeast Neighbors
Re Agenda Item 16-L, City Council meeting of August 22, 2023 Dear City Council and City Manager,
Northeast Neighbors supports Councilmember discussion item 16-L and we ask for a discussion and reconsideration of the April 11 vote by Council to be placed on the next City Council agenda.

It appears the Councilmembers were not fully informed about the impact of the Staff recommendation that Council amend the zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed-use Blvd. is 70 feet. We have learned that Councilmembers were not made aware that 70 feet is not actually a strict height limit.

Developers are well aware of the result of the April 11 vote by Council and are already pulling and resubmitting proposals to achieve much larger projects than were previously submitted. We have attended a virtual “community meeting” for one massive mixed-use housing development proposed for 2525 Wilshire Blvd. that is planned for upwards of 84 feet.

These new proposals are based on the unit compounding that resulted from the apparently ill-advised Council vote. The compounding elements include:
 Santa Monica City Council voted to upzone Wilshire Blvd. to 70 feet to implement the Housing Element required by the State.
 A 50% increase in projects is generated when a developer meets the required affordable housing (now 10%)
Item 16.L
08/22/23
3 of 23 Item 16.L
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2 Together these result in the potential for an unknown number of 100 + ft projects on Wilshire Blvd.

Residents want to know:

 Did the City Council have enough information to inform their vote on April 11?  Did staff clearly explain the compounding result of these two changes?  Did they give examples of the scale and impacts that would result?  Did the City Council understand exactly what they were approving? Affordable housing advocates are in distress and are expected to support this effort because  Santa Monica’s affordable housing requirement used to be 15% and consisted of various income levels. The result was you could build a 70 ft building with 100 units and 15 of them would have to have been affordable.

 Now the State formula applies and it only requires 10% affordable housing to be included in mixed use housing projects. When the developer meets that 10% affordable unit requirement, a density bonus kicks in and there is a 50% increase allowed of the number of ALL units in the housing development.

The result of this means that:
 Formerly 15 affordable were required out of 100 units  Now: 10 affordable units are required out of 150 units Additional Impacts of new huge projects will have a re-segregation effect because all of the affordable units can be built offsite (at a different location in another part of the city). This will result in concentrating units in surrounding (lower cost) neighborhoods, in direct violation of the stated purpose of inclusionary affordable housing.

All parking will be “unbundled,” which means it will be priced separately from the rents and not subject to rent controlled price increases. (New residents of these projects will be allowed to purchase preferential parking permits to park their cars on neighborhood streets.) In the environment where the State and City are pushing for electric cars, this will create insurmountable barriers to mobility since the charging infrastructure is not there nor is there any realistic plan to get it there.

We support the requests made in 16-L and request that it be fully explored as a Discussion item at the next Council meeting.

Thank you.

Tricia Crane
Chair, Northeast Neighbors
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From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, August 22, 2023 11:36 AM
To: Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; councilmtgitems; Denise Anderson-Warren
Cc: Clare Thomas
Subject: FOSP Supports Council Agenda Item 16-K on 8/22/23 - Call for review and full disclosure of Compounding impact of AHPP and the State Density Bonus

EXTERNAL
August 22, 2021
To: Mayor Gleam Davis and City Council members
From: Board of Directors, Friends of Sunset Park
RE: 8/22/23 agenda item 16K: Call for review and full disclosure of Compounding impact of AHPP and the State Density Bonus.

The FOSP Board supports Councilmember discussion item 16-K and we ask for a discussion and reconsideration of the April 11 vote by Council to be placed on the Agenda for the Sept. 12 meeting. We agree with the letter sent by Northeast Neighbors below and incorporate it herein in its entirety. Furthermore, the compounding impact of the AHPP and State Density Bonus could result in larger developments in Sunset Park as well, beyond what is required in our zoning ordinance implementing the Housing Element.

We support the requests made in 16-K and ask that the matter be fully explored as a Discussion item at the next Council meeting on Sept. 12.

Thank you.

Nikki Kolhoff
Vice President, Friends of Sunset Park
---------- Forwarded message ---------
From: Tricia Crane <[email protected]>
Date: Mon, Aug 21, 2023 at 10:38 AM
Subject: Support for Agenda Item 16-L - Call for review and full disclosure of Compounding impact of AHPP and the State Density Bonus
To: <[email protected]>, <[email protected]>, Oscar de la Torre <[email protected]>, Lana Negrete <[email protected]>, <[email protected]>, Phil Brock <[email protected]>, Jesse Zwick <[email protected]>, <[email protected]>, David White <[email protected]>, <[email protected]>, <[email protected]>, Denise Anderson-Warren <Denise.Anderson[email protected]> Item 16.L
08/22/23
5 of 23 Item 16.L
08/22/23
2 To: Santa Monica City Council and City Manager
From: Northeast Neighbors
Re Agenda Item 16-L, City Council meeting of August 22, 2023 Dear City Council and City Manager,
Northeast Neighbors supports Councilmember discussion item 16-L and we ask for a discussion and reconsideration of the April 11 vote by Council to be placed on the Agenda for the Sept. 12 meeting.

It appears the Councilmembers were not fully informed about the impact of the Staff recommendation that Council amend the zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed-use Blvd. is 70 feet. We have learned that Councilmembers were not made aware that 70 feet is not actually a strict height limit.

Santa Monica now faces the potential for an unknown number of 100 + ft housing development projects on Wilshire Blvd.

Residents want to know:

 Now the State formula applies and it only requires 10% affordable housing to be included in mixed use housing projects.

Additional Impacts of new huge projects will have a re-segregation effect because all of the affordable units can be built offsite (at a different location in another part of the city). This will result Item 16.L
08/22/23
6 of 23 Item 16.L
08/22/23
3 in concentrating units in surrounding (lower cost) neighborhoods, in direct violation of the stated purpose of inclusionary affordable housing.

We support the requests made in 16-L and ask that the matter be fully explored as a Discussion item at the next Council meeting on Sept. 12.

Thank you.

Tricia Crane
Chair, Northeast Neighbors
https://santamonicacityca.iqm2.com//Citizens/detail_meeting.aspx?ID=1377

Item 16.L
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From: Sam Weller <[email protected]>
Sent: Tuesday, August 22, 2023 10:55 AM
To: councilmtgitems; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; Denise Anderson-Warren
Subject: Re Agenda Item 16-L, City Council meeting of August 22, 2023

EXTERNAL
Dear SM City Council and City Manager,
Northeast Neighbors supports Councilmember discussion item 16-L and we ask for a discussion and reconsideration of the April 11 vote by Council to be placed on the Agenda for the Sept. 12 meeting.

It appears the Councilmembers were not fully informed about the impact of the staff recommendation that the Council amend the zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed-use Blvd. is 70 feet. We have learned that Councilmembers were not made aware that 70 feet is not a strict height limit.

Developers are well aware of the result of the April 11 vote by the Council and are already pulling and re-submitting proposals to achieve much larger projects than were previously submitted. We have attended a virtual “community meeting” for one massive mixed-use housing development proposed for 2525 Wilshire Blvd. that is planned for upwards of 84 feet. It could have been much bigger.

Santa Monica now faces the potential for an unknown number of 100 + ft housing development projects on Wilshire Blvd.

Residents want to know:
 Did the City Council have enough information to inform their vote on April 11?  Did staff clearly explain the compounding result of these two changes?  Did they give examples of the scale and impacts that would result?  Did the City Council understand exactly what they were approving? Affordable housing advocates are in distress and are expected to oppose this effort because  Santa Monica’s affordable housing requirement used to be 15% and consisted of various income levels. The result was you could build a 70 ft building with 100 units and 15 of them would have to have been affordable.

Item 16.L
08/22/23
8 of 23 Item 16.L
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2  Now the State formula applies and it only requires 10% of affordable housing to be included in mixed-use housing projects.

Additional Impacts of new huge projects will have a segregation effect because all of the affordable units can be built offsite (at a different location in another part of the city). This will result in concentrating units in surrounding (lower cost) neighborhoods, in direct violation of the stated purpose of inclusionary affordable housing.

All parking will be “unbundled,” which means it will be priced separately from the rents and not subject to rent-controlled price increases. (New residents of these projects will be allowed to purchase preferential parking permits to park their cars on neighborhood streets.) In the environment where the State and City are pushing for electric cars, this will create insurmountable barriers to mobility since the charging infrastructure is not there nor is there any realistic plan to get it there.

We support the requests made in 16-L and ask that the matter be fully explored as a Discussion item at the next Council meeting on Sept. 12.

Thank you.

Sam Weller
‐‐
Sam Weller
203‐981‐1653
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From: Wendy Dembo <[email protected]>
Sent: Tuesday, August 22, 2023 10:53 AM
To: councilmtgitems; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; Denise Anderson-Warren
Subject: Re Agenda Item 16-L, City Council meeting of August 22, 2023

EXTERNAL
Dear City Council and City Manager,
We have entrusted our City to you, please don't allow developers to ruin everything that makes Santa Monica There already is a plethora of overpriced empty housing. We don't need more, and we especially don't need more whic neighborhoods.

Northeast Neighbors supports Councilmember discussion item 16-L and we ask for a discussion and reconsid Council to be placed on the Agenda for the Sept. 12 meeting.

It appears the Councilmembers were not fully informed about the impact of the Staff recommendation th zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed-use Blvd. is 70 feet. We have learned that Councilmembers were not m strict height limit.

Developers are well aware of the result of the April 11 vote by the Council and are already pulling and re-sub much larger projects than were previously submitted. We have attended a virtual “community meeting” for on development proposed for 2525 Wilshire Blvd. that is planned for upwards of 84 feet. It could have been muc Santa Monica now faces the potential for an unknown number of 100 + ft housing development projec Residents want to know:
 Did the City Council have enough information to inform their vote on April 11?  Did staff clearly explain the compounding result of these two changes?  Did they give examples of the scale and impacts that would result?  Did the City Council understand exactly what they were approving? Affordable housing advocates are in distress and are expected to support this effort because Item 16.L
08/22/23
10 of 23 Item 16.L
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4  Santa Monica’s affordable housing requirement used to be 15% and consisted of various income le build a 70 ft building with 100 units and 15 of them would have to have been affordable.  Now the State formula applies and it only requires 10% of affordable housing to be included in projects.

Additional Impacts of new huge projects will have a re-segregation effect because all of the affordable a different location in another part of the city). This will result in concentrating units in surrounding (lower cost violation of the stated purpose of inclusionary affordable housing.

All parking will be “unbundled,” which means it will be priced separately from the rents and not subject to r (New residents of these projects will be allowed to purchase preferential parking permits to park their cars on the environment where the State and City are pushing for electric cars, this will create insurmountable barrier infrastructure is not there nor is there any realistic plan to get it there.

We support the requests made in 16-L and ask that the matter be fully explored as a Discussion item at the n

12. Thank you.

Wendy Dembo
Santa Monica Resident
https://santamonicacityca.iqm2.com//Citizens/detail_meeting.aspx?ID=1377

16. COUNCILMEMBER DISCUSSION ITEMS
- L. Councilmembers Brock, de la Torre and Parra request that the City Manager and City Attorney explain the fo between AHPP and the ability to be eligible for State Density Bonus and (2) whether AHPP requirements are consis under State Density Bonus law. Also, the City Manager and City Attorney are being asked to discuss the compound State Density Bonus on building height and density. On April 11, 2023 (Agenda item 10-b), the City Council voted to ensure consistency with State law and the City’s certified Housing Element that included an updated Affordable (AHPP).

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Em ail trackers can track if you opened the em ail, w hen you opened it, w here you Item 16.L
08/22/23
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From: diana hinek <[email protected]>
Sent: Tuesday, August 22, 2023 12:03 PM
To: councilmtgitems; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; Denise Anderson-Warren
Subject: Re Agenda Item 16-L, City Council meeting of August 22, 2023

EXTERNAL
Dear City Council and City Manager,
Northeast Neighbors supports Councilmember discussion item 16-L and we ask for a discussion and reconsideration of the April 11 vote by Council to be placed on the Agenda for the Sept. 12 meeting.

It appears the Councilmembers were not fully informed about the impact of the Staff recommendation that the Council amend the zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed-use Blvd. is 70 feet. We have learned that Councilmembers were not made aware that 70 feet is not a strict height limit.

Santa Monica now faces the potential for an unknown number of 100 + ft housing development projects on Wilshire Blvd.

Residents want to know:

Item 16.L
08/22/23
12 of 23 Item 16.L
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2  Now the State formula applies and it only requires 10% of affordable housing to be included in mixed-use housing projects.

Additional Impacts of new huge projects will have a re-segregation effect because all of the affordable units can be built offsite (at a different location in another part of the city). This will result in concentrating units in surrounding (lower cost) neighborhoods, in direct violation of the stated purpose of inclusionary affordable housing.

We support the requests made in 16-L and ask that the matter be fully explored as a Discussion item at the next Council meeting on Sept. 12.

Thank you.

Diana Hinek
Santa Monica Resident
https://santamonicacityca.iqm2.com//Citizens/detail_meeting.aspx?ID=1377

Item 16.L
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From: Susanne Jacobson <[email protected]>
Sent: Tuesday, August 22, 2023 12:58 PM
To: councilmtgitems; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; Denise Anderson-Warren
Subject: Stop the planned development! Re Agenda Item 16-L, City Council meeting of August 22, 2023

It appears the Councilmembers were not fully informed about the impact of the Staff recommendation that the Council amend the zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed-use Blvd. is 70 feet. We have learned that Councilmembers were not made aware that 70 feet is not a strict height limit.

Santa Monica now faces the potential for an unknown number of 100 + ft housing development projects on Wilshire Blvd.

Residents want to know:

 Did the City Council have enough information to inform their vote on April 11?  Did staff clearly explain the compounding result of these two changes?  Did they give examples of the scale and impacts that would result?  Did the City Council understand exactly what they were approving? Affordable housing advocates are in distress and are expected to support this effort because Item 16.L
08/22/23
14 of 23 Item 16.L
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2  Santa Monica’s affordable housing requirement used to be 15% and consisted of various income levels. The result was you could build a 70 ft building with 100 units and 15 of them would have to have been affordable.

 Now the State formula applies and it only requires 10% of affordable housing to be included in mixed-use housing projects.

Additional Impacts of new huge projects will have a re-segregation effect because all of the affordable units can be built offsite (at a different location in another part of the city). This will result in concentrating units in surrounding (lower cost) neighborhoods, in direct violation of the stated purpose of inclusionary affordable housing.

We support the requests made in 16-L and ask that the matter be fully explored as a Discussion item at the next Council meeting on Sept. 12.

Thank you.

Susanne Jacobson
Santa Monica Resident
https://santamonicacityca.iqm2.com//Citizens/detail_meeting.aspx?ID=1377

16. COUNCILMEMBER DISCUSSION ITEMS
- L. Councilmembers Brock, de la Torre and Parra request that the City Manager and City Attorney explain the following: (1) the relationship between AHPP and the ability to be eligible for State Density Bonus and (2) whether AHPP requirements are consistent with income requirements under State Density Bonus law. Also, the City Manager and City Attorney are being asked to discuss the compounding effects of the AHPP and State Density Bonus on building height and density. On April 11, 2023 (Agenda item 10- b), the City Council voted to amend the Zoning Ordinance to ensure consistency with State law and the City’s certified Housing Element that included an updated Affordable Housing Production Program (AHPP). ‐‐
Susanne Jacobson
310‐720‐5092
[email protected]
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From: Alex Maddalosso <[email protected]>
Sent: Tuesday, August 22, 2023 1:46 PM
To: councilmtgitems; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Phil Brock; Jesse Zwick; Caroline Torosis; David White; Santa Monica City Manager's Office; Douglas Sloan; Denise Anderson-Warren
Subject: Re Agenda Item 16-L, City Council meeting of August 22, 2023

EXTERNAL
Dear City Council and City Manager,
Northeast Neighbors supports Councilmember discussion item 16‐L and we ask for a discussion and reconsideration of the April 11 vote by Council to be placed on the Agenda for the Sept. 12 meeting.

It appears the Councilmembers were not fully informed about the impact of the Staff recommendation that the Council amend the zoning ordinance to comply with the 6th cycle housing element.

The height limit established for Mixed‐use Blvd. is 70 feet. We have learned that Councilmembers were not made aware that 70 feet is not a strict height limit.

Developers are well aware of the result of the April 11 vote by the Council and are already pulling and re‐ submitting proposals to achieve much larger projects than were previously submitted. We have attended a virtual “community meeting” for one massive mixed‐use housing development proposed for 2525 Wilshire Blvd. that is planned for upwards of 84 feet. It could have been much bigger.

Santa Monica now faces the potential for an unknown number of 100 + ft housing development projects on Wilshire Blvd.

Residents want to know:
∙ Did the City Council have enough information to inform their vote on April 11? ∙ Did staff clearly explain the compounding result of these two changes? ∙ Did they give examples of the scale and impacts that would result? ∙ Did the City Council understand exactly what they were approving? Affordable housing advocates are in distress and are expected to support this effort because ∙ Santa Monica’s affordable housing requirement used to be 15% and consisted of various income levels.

The result was you could build a 70 ft building with 100 units and 15 of them would have to have been affordable.

Item 16.L
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2 ∙ Now the State formula applies and it only requires 10% of affordable housing to be included in mixed‐use housing projects.

Additional Impacts of new huge projects will have a re‐segregation effect because all of the affordable units can be built offsite (at a different location in another part of the city). This will result in concentrating units in surrounding (lower cost) neighborhoods, in direct violation of the stated purpose of inclusionary affordable housing.
*All parking will be “unbundled,” which means it will be priced separately from the rents and not subject to rent‐controlled price increases. (New residents of these projects will be allowed to purchase preferential parking permits to park their cars on neighborhood streets.) In the environment where the State and City are pushing for electric cars, this will create insurmountable barriers to mobility since the charging infrastructure is not there nor is there any realistic plan to get it there. There needs to be 2 parking spots per unit in addition to additional parking for the retail stores. There are already issues with Whole Foods employees trying to park on our already packed residential streets.

Additionally we oppose the construction of additional minimalist, high density units with no STORAGE! These residents need somewhere to store their LUGGAGE, surf boards, Holiday decorations, blow up beds, linnens etc. Similar large new buildings have proven to have outside decks full of storage items getting rained on and ruined while additionally looking unattractive. Units build in this manner, with intention of building as many as possible and raising rent every year, create a transient resident, who realize they need to move once they get more money/stuff, and in turn are not vested participants in the neighborhood.

We support the requests made in 16‐L and ask that the matter be fully explored as a Discussion item at the next Council meeting on Sept. 12.

Thank you,
Alex
Alex Maddalosso
Santa Monica Resident
[email protected]
(310)213-0577
https://santamonicacityca.iqm2.com//Citizens/detail_meeting.aspx?ID=1377 Item 16.L
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August 22, 2023
Santa Monica City Council
c/o City Clerk
1685 Main St., Room 250
Santa Monica, CA 90401
RE: Agenda Item 16-K (Request that the City Manager and City Attorney explain the following:
(1) the relationship between AHPP and the ability to be eligible for State Density Bonus and (2) whether AHPP requirements are consistent with income requirements under State Density Bonus law)
Dear Hon. Councilmembers,
As you know, I serve as Vice Chair of the Santa Monica Planning Commission. I am submitting this comment letter in my individual capacity as a concerned citizen.

The information that is being requested as part of this item was provided to the City Council in the February 22, 2023 staff report regarding updates to the Zoning Code. I have attached relevant pages from that staff report as Exhibit A to this letter.

Last week, the Planning Commission had an opportunity to discuss Planning Department priorities and our work plan for this next year. As you know, there are many high-priority items that need to be covered over the next 12 months. To the extent that we can avoid adding additional work requests at this time, we should avoid doing so.

Best,
Ellis Raskin
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EXHIBIT A
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22 of 23 Item 16.L
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Item 16.L
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23 of 23 Item 16.L
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Santa Monica City CouncilAugust 22, 2023

Santa Monica City Council
August 22, 2023