From: Brian O"Neil
To: councilmtgitems; Lana Negrete; Caroline Torosis; Jesse Zwick; [email protected]; Barry Snell; Ellis Raskin; Natalya Zernitskaya
Cc: David White; PNA
Subject: 12/17/24 City Council Meeting - Item 16.0 - OPPOSE Date: Tuesday, December 17, 2024 1:37:27 PM
EXTERNAL
December 17, 2024
To: Mayor Negrete and City Council members
From: Board of Directors, Pico Neighborhood Association (PNA) Re: 12/17/24 Item 16.O -- Administrative Approval for Development in Non-Residential Zones –OPPOSE
The PNA Board is writing to oppose Item 16.O., which would allow all “housing projects” (as defined by California’s Housing Accountability Act) proposed in all nonresidential zones except the Bergamot Area Plan to be processed through an Administrative Approval process regardless of the size of the parcel upon which the housing project is located.
PNA Board concurs with all six concerns outlined by FOSP in its 12/17/24 letter to council (see below).
Thank you for your studied consideration of these concerns.
December 17, 2024
To: Mayor Negrete and City Council members
From: Board of Directors, Friends of Sunset Park
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
Re: 12/17/24 Item 16.O -- Administrative Approval for Development in Non-Residential Zones –OPPOSE
The FOSP Board is writing to oppose Item 16.O., which would allow all “housing projects” (as defined by California’s Housing Accountability Act) proposed in all nonresidential zones except the Bergamot Area Plan to be processed through an Administrative Approval process regardless of the size of the parcel upon which the housing project is located.
We are very concerned that you would move forward with
this without the following information:
1. No Baseline or Progress Established. You aren’t asking for any data relating to our development activity before instructing staff.
We expect
decisions that impact residents to be based on data.
Prior to any
procedural changes being made, you must request data from staff that includes: number of applications, status of each application, number of units in process by number of bedrooms and income levels, size of units, height of buildings, FAR of buildings, and aggregate progress toward each income-level RHNA target now.
2. No Evidence Process Needs to be Faster, that this Process Slows or Would be Faster With Change. Without the information from #1, you don’t know we are “behind” and need to “speed up.”
Furthermore, you
have presented no information about the difference in timelines of a housing project with and without a public process.
3. No Evidence Process is More Expensive, that the Expense is Preventing Housing, or the that Cost Savings for a Project Resulting from the Change. Again, without the information from #1, you don’t know we are “behind” and need to “speed up.”
Furthermore, you have
presented no information about the costs of the process with and without a public process. We have yet to see any full public accounting of a project so that we can see not only what the public process costs, but how that compares to the overall costs and profits of a project. We shouldn’t be asked to forego public engagement for an unknown benefit to developers.
4. No Information About How Many Parcels are Impacted by Size. “All
non-residential zones” is a huge area and includes parcels of many sizes, many with contiguous ownership.The previous change that removed the public for projects under 1 acre was limited in size because otherwise we risk fundamentally altering the character of our Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
neighborhoods in a complete end-run around the planning process. We need an inventory of all parcels by size, classification, and current use, along with an analysis of what the impact would be of losing each use to residential development.For example, we have no hardware store left in Santa Monica. How many resident-serving non-residential uses would we lose? Furthermore, where is the anlaysis of converting entire swaths of land to dense development? The Santa Monica Airport Business Park is 47 acres and redeveloping it was intended to be the subject of a public area plan. This ordinance does a complete end run around the LUCE and a total disregard of the Sunset Park neighborhood.
5. No Analysis of Impact on State Housing Laws. Given the fluidity of state housing laws, it’s imperative to understand how such an ordinance relates to our compliance with the current housing element and how it impacts our future obligations to build more market rate units. We already saw that council is unwilling to request an amendment to current the staff “error” upzoning Ocean Park Boulevard based on the unsubstantiated claim that it would trigger Builders Remedy. We are very concerned that enacted this ordinance could then never be reversed, lest staff and council claim a reversal would throw us into another Builders Remedy.
6. No Evidence Such an Ordinance Makes Housing More
Affordable.We have said many times before that we do not object to affordable housing, we object to projects that do not comply with local zoning.Here, there are no affordability requirements in this proposal.
We do NOT need more market-rate housing and we cannot continue to approve projects with 10%-15% affordable units, which leaves us unable to meet our affordability targets while overburdening our limited resources with market-rate units. Trickle down housing does not work.
Furthermore, we are disappointed that council fails to require 30% affordable consistent with Prop A.
As we have shown, there are simply too many unknowns, both respect to where we are and what the impacts would be of this ordinance.The new Council’s decision to push this forward in its very first meeting creates the perception that they will be governing based on ideology, rather than data or evidence, for the purposes of increasing market rate housing density, regardless of its impact on existing neighborhoods and residents.
No ordinance should be ordered, and no ordinance can be taken seriously, without first requesting all of the information above from staff.
Then, ONLY IF a need can be demonstrated for expanding the existing Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
streamlining provisions, it still should be limited as follows:
·Acreage should be capped (as it was by the previous Council) ; ·Parcels should expressly exclude (1) the Airport, and (2) the Santa Monica Business Park on Ocean Park Blvd., in addition to the Bergamot Area Plan;
·Streamlining should ONLY be provided to those projects that conform to existing zoning, without any state bonuses; and ·Streamlining should only be allowed for projects that achieve 30% affordable AND are consistent with local zoning WITHOUT state bonuses.
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
From: nancy hall
To: councilmtgitems
Cc: [email protected]
Subject: Agenda Item 16 - December 17, 2024 - Oppose
Date: Tuesday, December 17, 2024 1:23:31 PM
EXTERNAL
December 17, 2024
Re : Agenda item 16 - oppose
Dear City Council,
As a concerned neighbor, I urge you to oppose Agenda item 16, which, if passed, will suspend public review, and relegate the process of development to administrative decree.
Many years were devoted to crafting a master plan and vision for our city, only to be ignored, in favor of some supreme government power.
Please do your duty as an elected official, and do not deny the public participation in shaping the future of our beloved city.
Sincerely,
Nancy Hall
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
1 David Yakobson
From: Bruce Leddy <[email protected]>
Sent: Tuesday, December 17, 2024 11:59 AM
To: Clerk Mailbox; Lana Negrete; Ellis Raskin; Jesse Zwick; Barry Snell; Natalya Zernitskaya; Caroline Torosis; Dan Hall
Cc: David White
Subject: ITEM 16.O - Oppose
Follow Up Flag: Follow up
Flag Status: Flagged
EXTERNAL
December 17, 2024
To: Mayor Negrete and City Council Members
From: The Board of NOMA (North of Montana Association)
Re: Item 16.O - OPPOSE
The NOMA Board opposes Item 16.O which would allow housing projects proposed in nonresidential zones to be streamlined through Administrative Approval. While we recognize the need for more affordable housing in Santa Monica, such an ordinance would do nothing to increase affordability while giving the greenlight to developers to circumvent local control and public input.
The state has mandated that we create nearly 70% of our RHNA number units as "affordable" but we are falling woefully short of that requirement. Therefore, any ordinance written to streamline the development process must include an affordability component or we will continue our current path of significantly over-building market rate, and drastically under-building affordable units. Such a path will put us in direct conflict with the state mandates and may jeopardize our approved Housing Element and Pro-housing designation.
We urge you to reject 16.O until it includes language that requires a minimum of 30% affordable units in order for a development project to qualify for Administrative Approval consideration.
Thank you for your attention to this matter.
Sincerely,
Bruce Leddy
Chair, NOMA
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Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
1 David Yakobson
From: John Lin <[email protected]>
Sent: Tuesday, December 17, 2024 11:48 AM
To: councilmtgitems
Subject: Item 16.O More housing!
EXTERNAL
I love living and working in Santa Monica! Thank you for making it easier for the community to grow so we can share this great city with more neighbors!
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
2 David Yakobson
From: Tricia Crane <[email protected]>
Sent: Tuesday, December 17, 2024 11:46 AM
To: Lana Negrete; Ellis Raskin; Caroline Torosis; Jesse Zwick; Dan Hall; Natalya Zernitskaya; Barry Snell; councilmtgitems
Subject: OPPOSE City Council Agenda Item 16.O, December 17, 2024
EXTERNAL
To: Mayor Negrete and City Council members
From: Northeast Neighbors
Re: Opposition to Agenda Item 16.O, December 17, 2024: Administrative Approval for Development in Non-Residential Zones
The Board of Northeast Neighbors joins with the leaders of other neighborhood associations to Oppose Item 16.O., which would allow all “housing projects” (as defined by California’s Housing Accountability Act) proposed in all nonresidential zones except the Bergamot Area Plan to be processed through an Administrative Approval process regardless of the size of the parcel upon which the housing project is located.
No ordinance should be ordered by the Council until a data-driven need can be demonstrated to expand the existing streamlining provisions. Unless and until such analysis has been done, the current limits should stand:
Acreage continue to be capped
Parcels should expressly exclude (1) the Airport, and (2) the Santa Monica Business Park on Ocean Park Blvd., in addition to the Bergamot Area Plan Streamlining should ONLY be provided to those projects that conform to existing zoning, without any State bonuses
Streamlining should only be allowed for projects that achieve 30% affordable as required by Proposition A and are consistent with local zoning irrespective of State bonuses.
The Board of Northeast Neighbors
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
3 David Yakobson
From: Caro Vilain <[email protected]>
Sent: Tuesday, December 17, 2024 11:38 AM
To: councilmtgitems
Subject: I strongly support 16O
EXTERNAL
Dear council,
I strongly support item 16O.
The current process wastes time and resources both for the city and the applicant.
It is also misleading, as it leads the less informed public to believe that they have the power to influence the outcome of these projects when the law actually prevents that.
Our city staff is already stretched very thin and this is only making their job harder, while only generating frustrations on all fronts.
Thank you for this item, and I hope you all support it.
Caro Vilain, 90404
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
4 David Yakobson
From: Elizabeth Van Denburgh <[email protected]>
Sent: Tuesday, December 17, 2024 10:43 AM
To: Lana Negrete; Ellis Raskin; Caroline Torosis; Jesse Zwick; Dan Hall; Natalya Zernitskaya; Barry Snell; councilmtgitems
Cc: David White; David Martin
Subject: 12/17/2024 City Council Meeting - Item 16.0 - Administrative Approval for Development in Non-Residential Zones - OPPOSED by Wilshire Montana Neighborhood Coalition (Wilmont) Board of Directors
EXTERNAL
Mayor Negrete and City Council members,
The Wilshire Montana Neighborhood Coalition (Wilmont) Board of Directors opposes Item 16.O., which would allow all “housing projects” (as defined by California’s Housing Accountability Act) proposed in all nonresidential zones except the Bergamot Area Plan to be processed through an Administrative Approval process regardless of the size of the parcel upon which the housing project is located.
We are very concerned that you would move forward with this without the following information:
1. No Baseline or Progress Established. You aren’t asking for any data relating to our development activity before instructing staff. We expect decisions that impact residents to be based on data. Prior to any procedural changes being made, you must request data from staff that includes: number of applications, status of each application, number of units in process by number of bedrooms and income levels, size of units, height of buildings, FAR of buildings, and aggregate progress toward each income-level RHNA target.
2. No Evidence that Process Needs to be Faster or that this Process Slows or Would be Faster with Proposed Change. Without the information from #1, you don’t know if we are “behind” and need to “speed up.” Furthermore, you have presented no information about the difference in timelines of a housing project with and without a public process.
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
5 3. No Evidence Process is More Expensive, that the Expense is Preventing Housing, or the Cost Savings for a Project Resulting with Proposed Change. Again, without the information from #1, you don’t know if we are “behind” and need to “speed up.” Furthermore, you have presented no information about the costs of the process with and without a public process. We have yet to see any full public accounting of a project so that we can see not only what the public process costs, but how that compares to the overall costs and profits of a project. We shouldn’t be asked to forego public engagement for an unknown benefit to developers.
4. No Information About How Many Parcels are Impacted by Size. “All nonresidential zones” is a huge area and includes parcels of many sizes, many with contiguous ownership. The previous change that removed the public for projects under one acre was limited in size because otherwise we risk fundamentally altering the character of our neighborhoods in a complete end-run around the planning process. We need an inventory of all parcels by size, classification, and current use, along with an analysis of what the impact would be of losing each use to residential development. For example, we have no hardware store left in Santa Monica. How many resident-serving non-residential uses would we lose? Furthermore, where is the analysis of converting entire swaths of land to dense development? The Santa Monica Airport Business Park is 47 acres and redeveloping it was intended to be the subject of a public area plan. This ordinance does a complete end run around the LUCE and a total disregard of the Wilmont neighborhood.
5. No Analysis of Impact on State Housing Laws. Given the fluidity of state housing laws, it’s imperative to understand how such an ordinance relates to our compliance with the current housing element and how it impacts our future obligations to build more market rate units. We already saw that council is unwilling to request an amendment to correct the staff “error” upzoning Ocean Park Boulevard based on the unsubstantiated claim that it would trigger Builders Remedy. We are very concerned that if enacted this ordinance could then never be reversed, lest staff and council claim a reversal would throw us into another Builders Remedy.
6. No Evidence Such an Ordinance Makes Housing More Affordable. We have said many times before that we do not object to affordable housing, we object to projects that do not comply with local zoning. Here, there are no affordability requirements in this proposal. We do NOT need more market-rate housing and we cannot continue to approve projects with 10%-15% affordable units, which leaves us unable to meet our affordability targets while overburdening our limited resources with market-rate units. Trickle down housing does not work. Furthermore, we are disappointed that council fails to require 30% affordable consistent with Prop A.
As we have shown, there are simply too many unknowns, both with respect to where we are and what the impacts would be of this ordinance. The new Council’s decision to push this forward in its very first meeting creates the perception that they will be governing Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
6 based on ideology, rather than data or evidence, for the purposes of increasing market rate housing density, regardless of its impact on existing neighborhoods and residents and the overall city’s budget. Housing is a revenue loser for the city; we need capital improvements to provide revenue to the city for all the proposed housing. As well, giving city land to SM College and SMMUSD, who pay no property taxes, we lose the ability for these lands to provide revenue for a densifying city with only housing.
No ordinance should be ordered, and no ordinance can be taken seriously, without first requesting all of the information above from staff. Then, ONLY IF a need can be demonstrated for expanding the existing streamlining provisions, it still should be limited as follows:
· Acreage should be capped (as it was by the previous Council) ; · Parcels should expressly exclude (1) the Airport, and (2) the Santa Monica Business Park on Ocean Park Blvd., in addition to the Bergamot Area Plan; · Streamlining should ONLY be provided to those projects that conform to existing zoning, without any state bonuses; and
· Streamlining should only be allowed for projects that achieve 30% affordable as required by Proposition A AND are consistent with local zoning WITHOUT state bonuses.
Respectfully,
Wilmont Board of Directors
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
7 David Yakobson
From: Jason Mastbaum <[email protected]>
Sent: Tuesday, December 17, 2024 10:03 AM
To: councilmtgitems
Subject: support 16O
EXTERNAL
Thank you for placing this item on the agenda.
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
1 David Yakobson
From: [email protected]
Sent: Monday, December 16, 2024 11:03 PM
To: councilmtgitems
Cc: [email protected]; [email protected]
Subject: City Council 12/17/24 agenda item 16.0 -- OPPOSE!
EXTERNAL
December 16, 2024, 2024
To: Mayor Negrete and City Council members
From: Board of Directors, Friends of Sunset Park
Re: 12/17/24 Item 16.O -- Administrative Approval for Development in Non-Residential Zones – OPPOSE
The FOSP Board is writing to oppose Item 16.O, which would allow all “housing projects” (as defined by California’s Housing Accountability Act) proposed in all nonresidential zones except the Bergamot Area Plan to be processed through an Administrative Approval process regardless of the size of the parcel upon which the housing project is located.
We are very concerned that you would move forward with this without the following information:
1. No Baseline or Progress Established. You aren’t asking for any data relating to our development activity before instructing staff. We expect decisions that impact residents to be based on data. Prior to any procedural changes being made, you must request data from staff that includes: number of applications, status of each application, number of units in process by number of bedrooms and income levels, size of units, height of buildings, FAR of buildings, and aggregate progress toward each income-level RHNA target now.
2. No Evidence Process Needs to be Faster, that this Process Slows or Would be Faster With Change. Without the information from #1, you don’t know we are “behind” and need to “speed up.” Furthermore, you have presented no information about the difference in timelines of a housing project with and without a public process.
3. No Evidence Process is More Expensive, that the Expense is Preventing Housing, or the that Cost Savings for a Project Resulting from the Change. Again, without the information from #1, you don’t know we are “behind” and need to “speed up.” Furthermore, you have presented no information about the costs of the process with and without a public process. We have yet to see any full public accounting of a project so that we can see not only what the public process costs, but how that compares to the overall costs and profits of a project. We shouldn’t be asked to forego public engagement for an unknown benefit to developers.
4. No Information About How Many Parcels are Impacted by Size. “All non-residential zones” is a huge area and includes parcels of many sizes, many with contiguous ownership. The previous change that removed the public for projects under 1 acre was limited in size because otherwise we risk fundamentally altering the character of our neighborhoods in a complete end-run around the planning process. We need an inventory of all Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
2 parcels by size, classification, and current use, along with an analysis of what the impact would be of losing each use to residential development. For example, we have no hardware store left in Santa Monica. How many resident-serving non-residential uses would we lose? Furthermore, where is the anlaysis of converting entire swaths of land to dense development? The Santa Monica Airport Business Park is 47 acres and redeveloping it was intended to be the subject of a public area plan. This ordinance does a complete end run around the LUCE and a total disregard of the Sunset Park neighborhood.
5. No Analysis of Impact on State Housing Laws. Given the fluidity of state housing laws, it’s imperative to understand how such an ordinance relates to our compliance with the current housing element and how it impacts our future obligations to build more market rate units. We already saw that council is unwilling to request an amendment to current the staff “error” upzoning Ocean Park Boulevard based on the unsubstantiated claim that it would trigger Builders Remedy. We are very concerned that enacted this ordinance could then never be reversed, lest staff and council claim a reversal would throw us into another Builders Remedy.
6. No Evidence Such an Ordinance Makes Housing More Affordable. We have said many times before that we do not object to affordable housing, we object to projects that do not comply with local zoning. Here, there are no affordability requirements in this proposal. We do NOT need more market-rate housing and we cannot continue to approve projects with 10%-15% affordable units, which leaves us unable to meet our affordability targets while overburdening our limited resources with market-rate units. Trickle down housing does not work.
Furthermore, we are disappointed that council fails to require 30% affordable consistent with Prop A.
As we have shown, there are simply too many unknowns, both respect to where we are and what the impacts would be of this ordinance. The new Council’s decision to push this forward in its very first meeting creates the perception that they will be governing based on ideology, rather than data or evidence, for the purposes of increasing market rate housing density, regardless of its impact on existing neighborhoods and residents.
No ordinance should be ordered, and no ordinance can be taken seriously, without first requesting all of the information above from staff. Then, ONLY IF a need can be demonstrated for expanding the existing streamlining provisions, it still should be limited as follows:
· Acreage should be capped (as it was by the previous Council) ; · Parcels should expressly exclude (1) the Airport, and (2) the Santa Monica Business Park on Ocean Park Blvd., in addition to the Bergamot Area Plan; · Streamlining should ONLY be provided to those projects that conform to existing zoning, without any state bonuses; and
· Streamlining should only be allowed for projects that achieve 30% affordable AND are consistent with local zoning WITHOUT state bonuses.
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024
1 David Yakobson
From: Santa Monica Forward <[email protected]> Sent: Saturday, December 14, 2024 5:54 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Natalya Zernitskaya Cc: councilmtgitems
Subject: Santa Monica Forward Support for 16.M and 16.O
EXTERNAL
Honorable Mayor Negrete and Councilmembers,
The Santa Monica Forward Steering Committee has reviewed and supports items 16.M and 16.O.
16.M We applaud the Council for proposing necessary and well-thought out procedural changes that will improve efficiency, transparency, and public participation in conducting the city’s business. We support this rule change as a needed step to bring order to City Hall.
16.O This procedural change will help streamline the process for desperately needed new housing. These projects are already required to be approved under state law, meaning additional unnecessary process only delays the production of new housing and substantially adds to the costs. Santa Monica voters showed their strong support this November for new housing and not for unnecessary process.
Thank you for your consideration of our position.
Sincerely,
Brad Ewing and Carl Hansen
Co-Chairs, Santa Monica Forward
Item 16-O
December 17, 2024
Item 16-O
December 17, 2024