Cities Index.
Agenda packet, first session

Santa Monica City Council
May 13, 2025

Document
Agenda packet, first session
Meeting
May 13, 2025
Body
Santa Monica City Council
Pages
12
Original file
280.9 MB
Text extracted from the city's file for reading and search. Open the original on santamonicacityca.iqm2.com. That file is the official record.

Your diligence demonstrates sincere respect for the community and is very much appreciated. We would like assurance this and any future proposed projects would be adequately and appropriately adjusted and the design flaws that were pointed out by the Board would be remedied by the new redesign submission.

Presented within this correspondence are some observations that persist within the community about the safety of the proposed project that is hoped will be seriously examined by the developer as they go about their design.

It was stated during the ARB meetings that there was a Mobility assessment conducted, and no problems were found. Entrance and exit from the three nearby alleys that are too narrow for vehicles to travel in both directions are impractical, unrealistic, and unsafe.

Additionally, let’s not forget that Lincoln Boulevard is Highway One along this stretch. This is a major thoroughfare not only for commuters and visitors, but more importantly as a route for emergency vehicles to reach those in need of life-saving services. Protection of public safety vitally includes a plan for the evacuation of residents during small and large-scale disaster events.

People not only need housing; they also need it to be safe with adequate infrastructure. These Public Safety issues should be seriously explored by the City’s Mobility Assessment, Administrative staƯ, Public Safety personnel, Boards, Commissions, Councils, and any other appropriate specialists before these newly proposed density bonus projects are approved in an attempt to satisfy the State’s position. Safety matters must have been of the highest priority on the list of considerations when the City’s Zoning Code was put in place.

The problematic and unrealistic designs that plague this particular proposed development in and of itself creates multiple disturbing safety hazards and unacceptable risks to the community in the short run and would contribute to the safety impact of future proposed developments.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1975 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) It was stated during the November 4, 2024 ARB meeting, this is but one of many similar projects of this scale that were inevitable in years to come. Lining Lincoln Boulevard and other streets with excessively large and densely populated developments in an eƯort to help alleviate California’s housing shortage is dangerous. It is horrifying to envision the level of catastrophic gridlock and the disastrous outcomes it would cause. How would the thousands of high-density building residents and existing neighborhood residents evacuate eƯectively and not be trapped in gridlock? That concept imperils the entire community, including those the State intends to help house.

Granted, housing is vitally important, but not at the expense of protection of people’s lives by setting aside common-sense, practical, and realistic levels of density capacity.

At the November 4, 2024 ARB meeting, during their presentation, the representative for the proposed development stated they got “Lucky” because there was existing resident parking on the other side of the narrow alley instead of a building wall being at edge of the neighboring property.

Clarification of that statement is respectively requested. Was this considered lucky because they would rather have their dozens of new residents hope those existing spaces were at times empty enough so there would be safer room to pull in and out of their crowded parking structure? Or was it lucky because their high-rise’s residents would “only” take the chance of hitting a pedestrian, bicyclist, or current residents’ parked or moving vehicles rather than hitting a neighboring residential building’s wall?
A well-designed development that is safe, responsible, realistic and practical for both existing neighborhood residents & prospective new building occupants does not even partly rely on the good fortune of “only” hitting something besides the wall of someone’s home.

The following is an aerial view of the block in question:

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1976 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 10th St. across Top; Lincoln Blvd. along Bottom; Pearl St. at Left; Cedar St. at Right of Photo (Alleyways Present as an Upside-Down “T” Between the Streets Listed Above) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1977 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) TraƯic calming measures were implemented on Pearl Street many years ago to help improve safety as was necessary for the density present at that time. In addition to installing a four-way stop sign at each and every intersection along Pearl Street from Lincoln Boulevard to Centinela Avenue, other safety measures were taken. Amongst those were the installation of an island and double yellow lines to prevent vehicles exiting the alley that runs parallel to Lincoln Boulevard from making a left turn towards Lincoln Boulevard. There is too little room for vehicles to traverse across the westbound lane of traƯic on Pearl Street to line up at the traƯic light at the corner of Pearl Street and Lincoln Boulevard as is illustrated in the photographs below:

Traffic Lined Up on Pearl Street at Lincoln Blvd. Two Sets of Double Yellow Lines- Crossing Prohibited Island and Two Sets of Double Yellow Lines - Crossing Prohibited Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1978 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Imagine increasing traƯic many-times fold and the inadequacies the existing traƯic safety measures would provide. Dozens more vehicles exiting the alley would need to turn right, entering a neighborhood full of pedestrians, bicyclists, and other vehicles, compounding the danger.

Accessing the parking structure from the alley that empties onto Cedar Street could allow those exiting the proposed building parking structure to make a right turn onto Cedar Street and then a right or left turn onto Lincoln Boulevard. TraƯic would severely back up in the alley as vehicles attempt to enter the heavy day-long traƯic, not to mention the bumper-to-bumper traƯic during rush hour and during summer from beach visitors. The potential for accidents would greatly increase, causing further delays.

View of Alley from Cedar Street
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1979 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) The alley between Pearl Street and Cedar Street that exits onto 10th Street presents the same problems, except that it would impact more residents living on Pearl Street and Cedar Street who access their homes through the alley and would direct cars even deeper into the neighborhood.

Alley Between Pearl St. & Cedar Street from 10th St. View of Typical Congestion in Same Alley

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1980 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) View along Pearl St. Toward Lincoln Blvd. Showing Center Divider Island & Striping Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1981 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Other areas in Santa Monica have acknowledged the dangers of increased traƯic being channeled into residential neighborhoods. The photograph below shows the signage and implementation of traƯic controls near the Trader Joe’s on Pico which does not allow exiting into the residential neighborhood by a right turn, instead requiring those exiting the parking lot to turn left onto 33rd Street. These sensible measures demonstrate respect for the safety of the community:

Signage Directing TraƯic to Turn Left Onto 33rd Street toward Pico Boulevard Away from the Residential Neighborhood While Exiting the Parking Lot Adjacent to Trader Joe’s

Part of the reason neighbors are being so vigilant about new projects is because we trusted there would not be approval for a project like the nearby Chick-fil-A, a flawed business model with no dining area on premise, very few parking spaces, not even suƯicient for employees, resulting in patrons parking throughout the neighborhood, littering their discarded garbage on residents yards, exhibiting hostility towards residents, creating not only an unsightly nuisance, but a health and safety hazard. Additionally, crowds gather in nearby private parking lots and alleys, at times creating conflict and substantial noise. Most relevant to the topic at hand, their Drive-Thru is very frequently backed up for blocks onto Lincoln Boulevard, exacerbating traƯic on Lincoln Boulevard in the very Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1982 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) same area as the proposed development. Perhaps there was not suƯicient community input and community involvement voicing our concerns during the review and approval process and flawed Mobility reviews; a misstep that should not be repeated.

Thank you for your attention and consideration,
Pearl Street Area Neighborhood Residents

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1983 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 21 David Yakobson
From: Hank Koning <[email protected]>
Sent: Tuesday, May 13, 2025 9:26 AM
To: councilmtgitems; Caroline Torosis; Natalya Zernitskaya; Dan Hall; Barry Snell; Lana Negrete; Jesse Zwick; Ellis Raskin
Subject: Item 12A City Council Hearing, 5/13/2025 Item 12A

EXTERNAL
Mayor, City Council Members,
I urge you all to approve item 12A on tonight's hearing agenda.

Adequate housing, both market rate and affordable, is essential for a healthy, balanced City.

Please remove unnecessary and costly barriers to housing production.

Kind regards.
____________________
Hank Koning, FAIA, LFRAIA, LEED AP Founding Principal
KoningEizenberg| 1454 25th Street, Santa Monica, CA 90404 Direct: 424 220 2733 (incl. VM and SMS texts)
www.kearch.com
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1984 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 22 David Yakobson
From: [email protected]
Sent: Tuesday, May 13, 2025 8:56 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE

EXTERNAL
Dear Council Members,
I oppose Agenda Item 12A.

Thank you for considering my opinion for Santa Monica
John Dahl
Santa Monica Resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1985 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 23 David Yakobson
From: Lynda Dorf <[email protected]>
Sent: Tuesday, May 13, 2025 8:47 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE! Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I am a resident and business owner in the City of Santa Monica. I currently live on 32nd Street, just around the corner from the property at 2644 30th Street which is the subject of this Item.

I strongly object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. As you all should know, there is not a single building in the neighborhood which approaches 85 feet in height, and that includes the Santa Monica Business Park which is across the street.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85-foot building.
2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Lynda Eisenstat Dorf
2633 32nd Street

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1986 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 24 David Yakobson
From: Phillip Tate <[email protected]>
Sent: Tuesday, May 13, 2025 8:45 AM
To: councilmtgitems; Lana Negrete; Jesse Zwick; Caroline Torosis; Ellis Raskin; Natalya Zernitskaya; Dan Hall; Barry Snell
Cc: Ross Fehrman; Rachel Kwok; Jing Yeo; Armine Chaparyan Subject: SUPPORT - item 12A, LUCE and zone change for 2644 30th Street

EXTERNAL
Good morning Councilmembers. My name is Phillip Tate and I have been a resident of Sunset Park since 2008. I am writing to support the LUCE and zone change for 2644 30th Street.

This property is in the main neighborhood commercial strip for the Sunset Park and Ocean Park neighborhoods. The property has been commercial since at least as long as I've been here and, from what I'm told, well before that. It seems like the switch to single family zoning was unintentional. Approving the proposed zoning and LUCE changes essentially restores the status quo, but denying the request will essentially change the nature of our commercial corridor in what I think will be detrimental ways.

In order for the neighborhood serving retail and restaurants to survive and thrive they need to be surrounded by a mix of daytime and nighttime users. The existing office buildings provide a supply of daytime users that help us maintain the neighboring uses we all enjoy. While I fully support the idea that the city needs housing, maintaining erroneously placed single family housing on this site is not going to provide enough volume of housing to compensate for the daytime users that are needed to sustain our local businesses. Personally, I like having restaurants, cafes, yoga studios, pet stores, etc within walking and biking distance and don't want to have to get into a car to drive to an alternative in Los Angeles so I want the infrastructure in place that allows those businesses to thrive. Part of the infrastructure is daytime users. In this instance, the daytime users are already there so the question is whether to allow an apparent clerical error to destroy that infrastructure. Also, given the city's current budget constraints, killing off a use that generates tax increment is not particularly prudent.

I appreciate considering my thoughts on the matter.

Phillip Tate
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1987 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 25 David Yakobson
From: Casey Garner <[email protected]>
Sent: Tuesday, May 13, 2025 8:39 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Casey Garner
90401
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1988 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 26 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1989 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 27 David Yakobson
From: Charlotte Johnson <[email protected]>
Sent: Tuesday, May 13, 2025 8:30 AM
To: councilmtgitems; Dan Hall; Lana Negrete
Subject: proposal 12A

EXTERNAL
Dear Council Members. As a resident of santa monica, i am asking you all to vote NO on all 5 proposals on item 12A. It is ridiculous that 3 developments would even be considered in such a small area. I am already afraid to walk down Wilshire after dark. This would place an undue burden on this area and take away much needed parking.

Again, please vote NO on all 5 proposals.

Thank you.

Charlotte Johnson
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1990 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 28 David Yakobson
From: Darko Suvak <[email protected]>
Sent: Sunday, May 11, 2025 9:20 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE! Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Darko Suvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1991 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 29 David Yakobson
From: Jerry Bass <[email protected]>
Sent: Tuesday, May 13, 2025 8:19 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Fwd: 5-13-25 SM City Council Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE

EXTERNAL
From: [email protected]
Subject: 5-13-25 SM City Council Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE
Date: May 12, 2025 at 9:36:36 PM PDT
To: [email protected]
Cc: [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected]
Council Members:

Oppose the removal of the owner occupancy requirement in SB 9. Protects our neighborhoods from land speculators—keep the owner occupancy requirement ASIS! Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE Staff is recommending that the City Council vote to remove the SB9 owner occupancy requirement that was added to SB9 in order to help it pass in the State legislature. Now our own City Council is being encouraged by City staff to remove the owner-occupancy requirement. The owner occupancy requirement in SB9 was meant to encourage multigenerational housing. Removing it will open up neighborhoods to land speculators.

Below is the proposed revision that appears on page 256 of the attached Staff Report.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1992 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 30 Thank you.

Sincerely,
Jerry Bass— 40 year resident of Santa Monica
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1993 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 31 David Yakobson
From: Mark Borenstein <[email protected]>
Sent: Tuesday, May 13, 2025 8:10 AM
To: councilmtgitems
Subject: Comments to Item 12A on the May 13 Council Agenda

EXTERNAL
RE: ITEM 12A - May19, 2025: Objection to Proposed Amendment Removing Owner-Occupancy Requirement from Santa Monica’s SB9 Ordinance and “Clarifying” A Vacant Lot Can Be Split Under SB9 (Staff Recommendation #2)
Dear City Council Members
My name is Mark Borenstein, and I live at 1024 Stanford Street. The Council will consider at its May 13 meeting proposed amendments to the City’s SB9 Ordinance, SMMC 9.31.125. The proposed amendments are quite significant. They are included in 381 pages of changes to City ordinances..

The proposed changes result from the request by Councilmembers Zwick, Zernitskaya, and Hall that, “in conjunction with necessary updates arising out of SB 450, and in order to facilitate diverse housing choices in the City’s highest opportunity areas, the City Council directs the City Manager and the City Attorney to return with an ordinance to amend the City’s regulations governing ministerial approval for certain lot splits and duplexes on parcels zoned for single-unit residential by: (1) removing the owneroccupancy requirement for lot splits and duplexes and clarifying that vacant or demolished parcels… are eligible for lot splits and duplexes…”
I object to the proposed changes to the SB9 ordinance that purport to eliminate the owner occupancy requirement for lot splits, or to clarify that vacant parcels are eligible for lot splits. Here are my reasons:

1. The Staff Report observed that the Planning Commission recommended against deleting the owner occupancy requirement.

This proposed ordinance on both subjects is not required by SB450, which is supposed to be one of the reasons for amending the local Santa Monica SB9 ordinance. In fact, SB450 could have changed the owner occupancy requirement, but did not. And SB450 does not say anything about splitting vacant lots. SB450 cannot be the justification for amending the City’s ordinance on these two subjects.

The SB9 law is contained Government Code §66411.7. In section 66411.9(g)(1), a city “shall require an applicant for an urban lot split to sign an affidavit stating that the applicant intends to occupy one of the housing units as their principal residence for a minimum of three years from the date of the approval of the urban lot split.” Santa Monica cannot remove the owner occupancy requirement from its local ordinance and still comply with SB9.

At least one council member seems to believe that the proposed ordinance is not a change to the SB9 ordinance at all but rather purports to amend Santa Monica’s ordinance to permit an urban Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1994 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 32 lot split of any lot, in any zone in the City, without owner occupancy. The proposed amendments on the Council’s agenda on May 13 concerning owner occupancy and vacant land are limited to lot splits in SB9. See Proposed Amendment to SMMC 9.31.125(A) and 9.31.125(D)(6). The Municipal Code and the Subdivision Map Act already describe when parcels can be split in any zone, see SMMC 9.54.010. And owner occupancy is not required. However, if a landowner wants the benefit of the SB9 procedures, the SB9 law itself undisputedly requires owner occupancy to be included in the local SB9 ordinance.

Aside from the lawfulness of the proposed amendment, there is good reason why the Legislature amended SB9 multiple times but did not eliminate the owner occupancy requirement. The owner occupancy requirement for lot splits is the main safeguard against developers, whether resident or out of state, buying up R-1 property and building high end apartments in R-1 zones. While SB9 might be useful “to facilitate the certification of the Housing Element,” as the Planning Commission observed in 2022, it was never intended to be a panacea that would allow large scale apartment construction to solve any housing element issues.

In fact, SB9 was a thoughtful, but limited approach to building mostly affordable housing. SB9’s was tailored to allow families to divide their R-1 lots so aging parents and grandparents, or adult children or friends, could live in SB9 apartments. Senator Atkins, the prime sponsor of SB9, said it this way:
“Senate Bill 9 promotes small-scale neighborhood residential development by streamlining the process for a homeowner to create a duplex or subdivide an existing lot… At a time when many Californians are experiencing economic insecurity caused by the pandemic, this bill will generate affordable rental units. It also provides flexibility for multigenerational housing by allowing homeowners to build a modest unit on their property so that their aging parent or adult child can have an affordable place to live. SB 9 expands opportunities for existing homeowners to build equity while also creating new homeownership opportunities for those locked out of the market.”
Fact Sheet on SB9 by Sen. Toni Atkins (emphasis added). Senator Atkins’ legislation focused on homeowners, affordable rental units and multigeneration wealth creation. The owner occupancy requirement ensured all three objectives.

When the Planning Commission considered the City’s proposed SB9 ordinance in 2022, Jing Yeo, the Planning Manager, told the Council that the owner occupancy requirement was designed to “quell speculation.” SB9 was not enacted to allow a streamlined process for speculators and developers.

The “owner occupancy” restriction is ensures that the applicant occupies one of the housing units as their principal residence.” D. Martin Memo to City Council at 5, December 29, 2021. The requirement helps to further housing equity for families. Under SB9, there is little incentive for developers to construct much needed moderate- or low-income housing. Without the owner occupancy requirement, there will be no incentive at all to build housing that moderate- and lowincome families can afford, and Santa Monca needs For this reason and others, the Planning Commission in 2022 wholeheartedly endorsed the owner occupancy requirement. Indeed, a majority of the Commission members voted to expand the Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1995 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 33 owner occupancy requirement to duplexes created under SB9. Council Member Raskin, who was on the Planning Commission in 2022, stated at the time he “absolutely” supported owner occupancy. This requirement in our local ordinance should not now be removed.

2. Owner occupancy prevents a corporate landowner from using SB9 to split an urban lot and the Santa Monica ordinance should be amended to expressly say so. It is obvious that a corporation cannot intend to occupy a housing unit on one of the split lots, as is required by SB9. Indeed, the state’s enforcement agency for SB9, the Department of Housing and Community Development, provided technical guidance that “LLCs [limited liability corporations] are not eligible applicants for SB 9 urban lot splits because they cannot satisfy the three-year occupancy requirement. While there are no provisions in SB 9 that expressly preclude LLC applicants, an LLC applicant cannot legitimately claim intentions of residing in one of the units as its principal residence since LLCs do not physically reside anywhere.” See Technical Assistance Letter to the City of Orinda, dated October 23, 2024.

3. The purported “clarification” that an SB9 lot split can occur on vacant land is also not supported by anything in SB450. Nor does it have to do with housing equity. In fact, as the City itself recognized after SB9 was adopted, “in no case could a vacant lot (i.e. no existing dwelling units on the lot) be subdivided under SB9 due to SB9’s requirement that the applicant occupy one of the units as their principal residence for three years from the approval of the lot split. If there are no units for the [owner] … to reside [in] at the time of the lot split’s approval, it appears this condition cannot be met. Approval of the lot split is not the same as approval of building permits for structures on the resulting lots, which will occur sometime after the lot split is approved.” D.

Martin Memo at 6.

According to the Planning Department, after Mr. Martin’s memo, planning staff contacted the state Housing and Community Development agency by telephone for oral technical guidance on the vacant lot issue. An unnamed staff member at HCD apparently said that a vacant parcel could be divided under SB9. But there is no record of this phone call by the Santa Monica participants and no writing by the HCD person on the vacant lot question. Nor was any written technical assistance requested from HCD. There is also nothing about SB9 being used on vacant lots in the SB9 Fact Sheet published by HCD.

The City of Orinda, however, seems to have requested guidance from HCD concerning SB9 and vacant land (although HCD has not yet responded to a Public Records Act request concerning vacant land guidance to Orinda, so I can't be sure). Orinda published its own guidance to SB9 applicants on using SB9 to develop vacant lots. Here is what Orinda includes on its SB9 website in the “frequency asked questions” section about SB9:
“I have a vacant lot where I want to split my lot and build new unit(s). Can I apply for a SB 9 Lot Split and SB 9 Unit application at the same time?
SB 9 requires the property owner[s] to declare they intend to occupy one of the onsite housing units as their principal residence for a minimum of three years from the date of the SB 9 lot split approval. Because vacant sites do not have any onsite housing units, Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1996 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 34 applicants would need to (1) apply for an SB 9 Unit Application first, or (2) apply concurrently for an SB 9 Unit and SB 9 Lot Split. For concurrent submittals, construction of the SB 9 Unit would need to be completed prior to final approval of the SB 9 lot split.” See https://www.cityoforinda.org/561/Senate-Bill-9-SB9#:~:text=Senate%20Bill%209%20(SB%209)%20aims%20to%20streamline%20the%20approval ,specific%20objective%20standards%20are%20met. In other words, a vacant lot owner would have to make the lot un-vacant first so the owner could declare an intent to live on the property for three years after lot split approval.

Just like a corporate owner’s use of SB9 is proscribed because of the owner occupancy requirement, a landowner of vacant land also cannot use SB9 to split a lot, which is exactly what David Martin declared in 2021. Such an owner cannot “occupy one of the units as their principal residence for three years from the approval of the lot split” if the lot has no housing unit on it.

Nor will “clarifying” that a vacant parcel can be split under SB9 have any impact on “diverse housing choices” in the R-1 zones. According to the City’s February 20, 2025, response to a Public Records Act request, “[t]here are no vacant lots in the R1 zone.” If that is true, then there is no possibility that “clarifying” that a vacant lot can be split under SB9, will increase any new housing, let alone increase diverse housing choices.

4. Several of the comments to the Planning Commission in support of these SB9 changes said that relaxing the SB9 requirements would increase housing stock, especially affordable housing.

But there is no evidence that any proposed SB9 projects was delayed or denied because the ministerial requirements in the current ordinance were time consuming or onerous. In fact, none of the SB9 projects so far submitted to the City have been rejected and SB450 now requires City action on a completed SB9 application in 60 days.

More importantly, there is no evidence that eliminating the owner occupancy requirement or allowing lot splits on vacant land, will increase the “diverse housing choices” or will facilitate much needed affordable housing units. Without these requirements, developers will be able to use SB9 to create only one kind of rental unit-- high end, very expensive market rate housing that will do nothing to increase housing affordability.

Thank you for the chance to submit these comments. I hope the Council will reject (a) any change to the owner occupancy requirement in SB9, except to make clear corporate landowners cannot use SB9, and (b) any “clarification” that an SB9 lot split is permitted on vacant land.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1997 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Josephine <[email protected]>
Sent: Monday, May 12, 2025 10:46 PM
To: councilmtgitems

EXTERNAL
Hi to all the city council people,
I want to express my strong opposition to several of the agenda to be discussed at your meeting on may 13, 2025, namely:

The item 4J for SB 9, the item 12A for SB 9, and the item 4K concerning the public input.

My hope is that the decisions made by the city council will be made in the interest of the residents.

Thank you for your attention
Josephine Bakis
2808 Washington Avenue
Santa Monic
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1998 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Kyle Rebar <[email protected]>
Sent: Monday, May 12, 2025 6:43 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Kyle Rebar
90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 1999 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2000 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Wendy Dembo <[email protected]>
Sent: Monday, May 12, 2025 7:38 PM
To: councilmtgitems; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Caroline Torosis; Barry Snell; Ellis Raskin; Lana Negrete
Subject: AGENDA ITEMS 4J/12A 5/13/25 - OPPOSE

EXTERNAL
Dear Council Members:

Please oppose items 4J and 12A. Santa Monica and its residents deserve to have local control of development.

Getting rid of owner occupancy will mean that developers will buy buildings kick out the tenants and build more unaffordable housing.

Developers are funded by wealthy foreigners, who are happy to park their money in the US We don’t need Wilshire, Santa Monica, Lincoln, 17th Street, 20th Street walled in 8 story empty buildings.

Please think about people who can’t afford to live in luxury rentals.

With great sadness,
Wendy Dembo
Santa Monica Resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2001 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Nancy HR <[email protected]>
Sent: Tuesday, May 13, 2025 2:40 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Oppose!

EXTERNAL
To the city of Santa Monica council:

I, Nancy Hochman Ross, who live at 616 20th St., Santa Monica 90402, oppose items 4J, 12A and 4K.

Thank you,
Nancy
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2002 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Michele Garber <[email protected]>
Sent: Tuesday, May 13, 2025 1:09 AM
To: councilmtgitems
Cc: [email protected]; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: SM Council Meeting 5/13/25, OPPOSE AGENDA ITEMS 4J, 12A, 4K

EXTERNAL
Dear Santa Monica City Council Members,
It has come to my attention that on Tuesday, May 13, you will be voting on several issues that if passed will adversely affect the members of our community. I therefore want to respectively submit my firm opposition to these harmful policies. If approved, they will only benefit outside interests at the severe detriment of Santa Monica residents and further damage our already fragile quality of life.

As a nearly 40 year resident of Santa Monica, I have witnessed first-hand the slow degradation of our once affordable, safe and peaceful bedroom community. Our bucolic neighborhoods are now rife with over-development, congestion, crime, and unaffordability. It’s heart-breaking.

Allowing these measures to pass will exacerbate our already complex issues. When each of you were elected to your seat, the members of this community instilled our trust in you to fairly and properly represent us. Our community needs you to do right by us. I implore you to listen to your constituents and please vote no on the measures listed below.

Agenda Item 4J – Support letter from SM for SB 79 – OPPOSE Agenda Item 12A – End Owner Occupancy Requirement in SB9 – OPPOSE Agenda Item 4K – Public Input Rules – OPPOSE
As a further comment on SB79 and the possibility that 7-story apartment buildings could ostensibly be built throughout Santa Monica, including in many neighborhoods once zoned for single family homes, may I remind you that we are neither Chicago nor Manhattan. Not only do we not have the infrastructure to handle this density, but we are located in a perilous and severe seismic activity zone. We are not meant to have high-rise apartments throughout our residential neighborhoods. There is absolutely no amount of profit worth destroying all that makes Santa Monica special…and I voice this passionate opposition whilst also being a diehard free-market capitalist. If approved, the measures you are considering will surely cause irreparable harm to our beloved city. Please do not approve these measures.

Sincerely,
Michele Garber
1128 Princeton St.

SM 90403
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2003 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Linda Karr O'Connor <[email protected]>
Sent: Monday, May 12, 2025 10:15 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: Items 12:A.2, 4-J, 4-K: Oppose

EXTERNAL
Dear Council Members:

It’s gotten difficult to find a quiet, safe place in Santa Monica. I moved here from San Francisco in 1983 after a 4 story building went up next door to me, blocking all my light and air. That was the year the pier blew down. When it was rebuilt, the pier was a lovely place to walk and listen to the ocean. The only loud section was the arcade near the rides.

Now, there isn’t a single spot on the pier where you can have a conversation, free of over-amplified music and proselytizing. Same with the Promenade. After years of construction, it became a wonderful place where I felt safe walking at night alone or with my daughter. I’d go to a movie and then to the Midnight Special bookstore. There were buskers, but they didn’t have amplifiers. Now not only is it over-amplified but desolate. Is turning it into Pinnocchio’s Pleasure Island for drinkers really the best we can imagine for our city?

What we are left with is our homes. After decades of apartment living, where I had to listen to the conversations and music of other people and keep my own music down, we bought our one and only home in Sunset Park. It was very important to us that it was zoned R-1. I prize the ability, even though I live on a busy street, to go in my backyard and not have neighbors looking down into my yard. I value the light in my home that is not blocked by tall buildings next door. Yes, I had to endure my neighbor turning his house into an AirBnB hotel, but at least he was there when things got out of hand.

I oppose: the elimination of the “Owner Occupancy Requirement” for lot splits I oppose: SB79
I oppose: changing the length of public input. People need sufficient time to express complex ideas including time donation.

Thank you.

Linda Karr O’Connor
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2004 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Jason Moore <[email protected]>
Sent: Monday, May 12, 2025 6:13 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: OPPOSE ITEMS 10A, 4J, 4K

EXTERNAL
Please oppose -
Item 10A - This is a horrible proposal and will do nothing but create more chaos on the promenade thanks to an already out of control homeless crisis.

Item 4J - Please oppose this giveaway to developers.

Item 4k - Please oppose the change in public input rules. We deserve the right to show up to meetings and provide our comments, this should not be shortened, and the City Council works for the residents of Santa Monica, and please respect that.

Thank you
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2005 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: girltunes <[email protected]>
Sent: Tuesday, May 13, 2025 1:19 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: OPPOSE Agenda Items: 4J, 12A, 10A, and 4K

EXTERNAL
Dear Santa Monica City Council,
I stand with Northeast Neighbors in OPPOSING Agenda Items 4J, 12A, 10A and 4K.

When are you going to actually represent the residents? We don't want a high rise, shadowy. overdeveloped urban jungle with no open space and scarce resources. And your gag rule in Item 4K exemplifies your hostility to Santa Monicans.

Sincerely,
Ferris Gluck
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2006 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Rose Nelson <[email protected]>
Sent: Monday, May 12, 2025 10:39 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: OPPOSE Agenda items 4J, 12A, 10A,4K meeting 5/13/25 I OPPOSE these items

EXTERNAL
I oppose the agenda items as noted in subject line.

Rose Nelson
35 year Santa Monica resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2007 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 9:24 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 4j - 12a - 10a - 4k

EXTERNAL
Hello
I’m writing you today to express my opposition of the following items - 4j - 12a - 10a - 4k.

I am a lifelong Santa Monica resident, born and raised attending Santa Monica schools. Roosevelt, Lincoln, samo high and crossroads.

My grandparents moved to Santa Monica in the 50s - you’d be hard pressed to find a resident with deeper roots here than myself.

I love this city very much.

With that I ask you to please oppose these actions items.

Public drinking all day long on the promenade does not help us restore what was once the envy of the country for family entertainment.

Nor does building 7 story apartments buildings in our beautiful residential neighborhoods.

Thank you
Jared Freedman
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2008 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Carol Dickinson <[email protected]>
Sent: Monday, May 12, 2025 9:09 PM
To: councilmtgitems
Subject: 0PP0SE Items 12A, 4J, 4K & 10A at City Council Meeting 5/13/25

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose Item 12A and its 5 development proposals that would ruin our city forever. Items 4J and 4K are included in12A along with the up-zoning of 1331 Wilshire and 2644 30th Street, the elimination of public input on commercial developments and the end to owner occupancy requirements for single-family lot splits.

SB 79 is a terrible bill that will ruin single-family and small multi-family neighborhoods. There are no requirements in the bill for affordable housing, public input or environmental impact studies. The developers will have a feeding frenzy! Residents are not in favor of SB 79 Developers are.

Item 10A is an absolute joke! Only alcoholics drink at 8:00 in the morning. The result will be public drunkenness, more criminal acts and chaos. At present, we do not have enough police officers in our neighborhoods. With public alcohol consumption going on between 8:00 A.M. and 2:00 A.M., we will have even less officers available.

I doubt that the atmosphere will be very inviting for families. In reality, more tourists will be attracted to the Promenade if it’s clean and safe and not overrun with homeless people instead of shoppers.

Lastly, what is the point of Item 4K besides stifling public comments? You would think that these new time limits were proposed by the MAGA crew and Trump. Please represent your constituents and vote NO on items 12A, 4J, 10A and 4K.

Sincerely,
Carol Dickinson
1030 25th Street
Santa Monica
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2009 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: S Ruth <[email protected]>
Sent: Tuesday, May 13, 2025 7:11 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: City Council Agenda Items 4J - OPPOSE, Item 12A - OPPOSE, Item 10A - OPPOSE, Item4K - OPPOSE

EXTERNAL
My family and I STRONGLY OPPOSE the following measures before the City Council on Tuesday, May 13, 2024:
 Agenda Item 4J – Support letter from SM for SB 79 - OPPOSE  Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE  Agenda Item 10A – Promenade Entertainment Zone – OPPOSE While I am not opposed to the idea in concept, the Council needs to consider limited locations, security and hours. This could be a nightmare if not properly monitored and controlled. It also needs to be an asset for the existing small businesses, not an additional liability.
 Agenda Item 4K – Public Input Rules - OPPOSE
Best Regards,
Steve Ruth
1501 Georgina Ave, Santa Monica
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2010 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Richard Robin <[email protected]>
Sent: Tuesday, May 13, 2025 7:11 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Oppose

EXTERNAL
Agenda Item 4J – Support letter from SM for SB 79 - OPPOSE Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE Agenda Item 10A – Promenade Entertainment Zone – OPPOSE Agenda Item 4K – Public Input Rules - OPPOSE
Richard Robin
818-621-3964
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2011 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Colleen O'Brien <[email protected]>
Sent: Tuesday, May 13, 2025 7:32 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Council members,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Colleen O’Brien
90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2012 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2013 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Adeena Karsseboom Fitterman <[email protected]> Sent: Tuesday, May 13, 2025 7:29 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/2025 Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE

EXTERNAL
I hereby oppose Agenda Item 12A - end Owner Occupancy Requirement iin SB9 This will ruin the neighborhoods, safety of children, and the congestion will be unliveable.

OPPOSE
To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.

Adeena K. Fitterman
Estates Director
310.991.8166
[email protected]
9440 Santa Monica Blvd, PH | Beverly Hills CA. 90210
carolwoodre.com
DRE 02012059
The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third party, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2014 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Noma Boardmember <[email protected]>
Sent: Tuesday, May 13, 2025 7:13 AM
To: Jesse Zwick; Lana Negrete; councilmtgitems; Dan Hall; Caroline Torosis; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: Bruce Leddy; Nancy Coleman
Subject: ITEM 12A, 5/13/25 - OPPOSE

EXTERNAL
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.

TO: Mayor Negrete and Council Members
RE: ITEM 12A – May 13, 2025: OPPOSE Amendment Removing OwnerOccupancy Requirement The Board of NOMA objects to Item 12A, specifically the proposed amendment to eliminate an owner-occupancy requirement in Section 9.31.125 of City code pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Current state law expressly requires owneroccupancy from the date of the approval of a lot split: “A local agency shall require an applicant for an urban lot split to sign an affidavit stating that the applicant intends to occupy one of the housing units as their principal residence for a minimum of three years from the date of the approval of the urban lot split,” and our city’s existing regulations reflect that owner-occupancy requirement. (Government Code Section 66411.7(g), emphasis added) The Planning Commission considered this item in its March 19, 2025 meeting, engaged in a robust discussion, and voted unanimously to recommend City Council retain the owner-occupancy requirement. Commissioner Landres stated “I do not agree that removing the owner-occupancy requirement will make housing more accessible.” He observed that by eliminating the owneroccupancy requirement “you’re functionally simply enabling speculation,” and “the subdivided units are not going to be accessible to the people for whom affirmatively furthering fair housing is intended.”
The author of SB 9, State Senator Toni Atkins (D, San Diego), proclaimed that SB 9 “ensures homeowners, not investors, would benefit by requiring the owner to live in one of the units for a minimum of three years after getting Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2015 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 approval for a lot split.” A recent effort to remove the owner-occupancy provision as part of SB 677 failed to pass in committee, indicating substantial opposition to the bill among CA Senate Democrats.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. This will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

We urge you to vote NO on item 12A, or modify it to retain an owneroccupancy requirement in Section 9.31.125 that is consistent with current state law and is crucial to our not ceding all control of our existing residential neighborhoods to developers.

The Board of NOMA
NOMA'S Next Meeting: THUR. JUNE 5th
at 7PM on ZOOM
https://us02web.zoom.us/j/81526517066
smnoma.org
[email protected]
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2016 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 6 David Yakobson
From: Gary Freedman <[email protected]>
Sent: Tuesday, May 13, 2025 5:57 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A-May 13 Meeting--OPPOSE

EXTERNAL
To Whom It May Concern:

As 50+ year residents of the City of Santa Monica, it is very difficult to understand why the City Council would want to make it easier for developers to change the very nature of what makes Santa Monica a desirable place to live and raise a family.

Please Vote NO
Sincerely,
Donna & Gary Freedman
533 9th Street
Santa Monica 90402
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2017 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 7 David Yakobson
From: Jesus <[email protected]>
Sent: Tuesday, May 13, 2025 1:54 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Jesus, 90405
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs. Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs
Sent with Proton Mail secure email.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2018 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 8 David Yakobson
From: Ellen Mark <[email protected]>
Sent: Tuesday, May 13, 2025 12:24 AM
To: councilmtgitems
Cc: Lana Negrete; Dan Hall; Ellis Raskin; Caroline Torosis; Barry Snell; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A - 5/13/25 - OPPOSE

EXTERNAL
Dear Councilmembers,
I oppose Agenda Item 12A, ending the owner occupancy requirement .

Sincerely,
Ellen Mark
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2019 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 9 David Yakobson
From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, May 13, 2025 12:08 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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.

This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Nikki Kolhoff
Santa Monica Resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2020 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 May 12, 2025
Via Email
To: Mayor Negrete and Councilmembers
From: Nikki and Dan Kolhoff
Re: May 13, 2025 City Council Meeting – Item 12A, Nos. 6 & 7 Upzoning of 2644 30th Street - OPPOSE
Dear Mayor Negrete and City Council –
We object to the change of land use and rezoning of 2644 30th Street. It is an illegal spot-zoning misrepresented in the staff report as a clerical error. It would upzone the parcel in a manner and result in a MASSIVE windfall for the owner, and negative impacts on the residential neighbors.

Nowhere else in the city is the Neighborhood Commercial designation applied to an interior parcel to bring commercial use into the residential neighborhood beyond the depth of the other Neighborhood Commercial parcels on the boulevards. This would be the ONLY one in the entire city, and is further evidence of spot zoning.

According to staff, this change was requested by owner’s counsel in September 2024. However, there has been no outreach to the neighborhood by the owner or city staff. Furthermore, city staff appear to have adopted the owner’s false statements without investigation, even though they are not supported by the public record or the law. The staff report contains numerous inaccurate and misleading statements, and the upzoning presents issues not addressed in the staff report.

A. INACCURATE AND MISLEADING STATEMENTS IN THE STAFF REPORT 2644 30th Street is a single tax parcel that has existed since 1956, almost 70 years, as a 2-story office building (the “Office Building”) on one portion and a surface parking lot (the “Parking Lot”) on the other portion. It has been owned by the same Beverly Hills family since 1987, almost 38 years. (See images of the parcel attached.)
Below are the inaccurate statements that form the basis of the staff report and staff’s recommendation for the upzoning.

1. The LUCE designation was an error. False. Staff repeats many times in the staff report and resolutions that both the 2010 LUCE designation and 2015 Zoning were “mapping errors” that were “inadvertent”. This is false. The Parking Lot has always been R1 and the Office Building was originally C2. When the LUCE was updated in 2010, it expressly stated that commercial activity should be on the boulevards, while preserving the residential neighborhoods. Because this parcel is not on a boulevard, it was designated Single Family Residential.

The LUCE described Sunset Park as follows: “Sunset Park maintains its semi-suburban character and continues to provide distinct single and multi-family housing opportunities. New or rehabilitated development, particularly on the adjacent boulevards is sensitive to the scale and mass of existing structures and with the surrounding neighborhood context. Character-defining features, like mature street trees, are preserved to perpetuate the quality of Sunset Park’s outdoor environment. Traffic congestion and parking issues— especially as they relate to Santa Monica College—are mitigated by a mixture of transportation and parking demand management programs to reduce the impact of cut-through traffic and parking shortages. The mixture of Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2021 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 neighborhood-serving amenities near residential areas along Pico and Ocean Park Boulevards features a range of retail, dining and entertainment options and is easily accessible by foot, bicycle or car.” (LUCE-Page 2.2-29)
The LUCE created NEW land use designations to conform to the stated intentions of the LUCE, and that is why Neighborhood Commercial is on the boulevards and Residential is interior. 2644 30th is NOT on the boulevard so it was entirely consistent with the goals of the LUCE and the existing R1 zoning, to assign it a LUCE designation of Single Family Residential. This wasn’t a mistake or a mismatch. No other parcel was assigned Neighborhood Commercial that extended beyond the strip of parcels along the boulevards in the entire city.

These additional LUCE provisions further confirm that commercial development is supposed to be on the boulevards and not in the residential neighborhood:
• “The highest priority of the community was the preservation of the existing character and scale of Santa Monica’s neighborhoods.” (LUCE-Page 3) • “The [2010] LUCE is different from the policy direction of the 1984 LUCE: It is a conservation plan that provides for an overall reduction in building height.” (LUCEPage 5) • Land Use 2.2 -- NEIGHBORHOOD CONSERVATION -- "Renters and homeowners alike advocate for neighborhood conservation so that future generations may enjoy the same benefits and experiences." (LUCE-Page 2.2-3)
Because Neighborhood Commercial was intended to be on the boulevards, the LUCE doesn’t even speak to interior parcels. A review of the City’s GIS maps shows that nowhere else in the city is the NC designation applied to an interior parcel to bring commercial use into the residential neighborhood beyond the depth of the other NC parcels on the boulevards. This would be the ONLY one in the entire city, and is further evidence of spot zoning.

2. The Zoning Designation was an Error. False. Counsel and staff contend that the LUCE designation was carried through to the zoning in error. As stated above, the LUCE designation of Single Family Residential was purposeful and the zoning of R1 was consistent with the LUCE. Furthermore, Friends of Sunset Park commented about this parcel on the record at both city council meetings, as well as a meeting with the City Manager, during the 2015 Zoning Ordinance Update to confirm the residential designation and zoning of this parcel.

The Parking Lot has always been R1 and the Office Building was formerly C2. After the purposeful designation of Residential in the LUCE, the zoning of R1 was consistent. As a result, there was no mismatch between the LUCE and the Zoning.

This is a completely different situation from the baskets of inconsistencies referenced in multiple staff reports in 2015, which included the A-Lot scandal where staff upzoned residential parcels adjacent to the boulevards to commercial in an effort to increase the size of lots for commercial development along the boulevards.

Ten years later, owner’s counsel and city staff are now mischaracterizing what was reviewed in 2014-15 by claiming that staff failed to catch a difference between the use and the “new” LUCE and zone. What was actually reviewed in 2014-15 were lots that had a prior zoning designation of residential, which staff changed to commercial in the LUCE, and then wanted to change the Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2022 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 zone to “conform” to the erroneous LUCE designation, otherwise known as the A-Lot Scandal.

Staff disingenuously characterized this as clerical at the time, but residents pushed back and demonstrated that the LUCE designation of commercial was inappropriate and must be reverted.

The resolution at the May 5, 2015 City Council meeting confirmed the residents were correct. It stated:
“WHEREAS, the Zoning Ordinance Update process has provided an opportunity to reassess the appropriateness of the land use designation changes that were approved as part of the LUCE; and
WHEREAS, staff has compared the LUCE Map with the existing Official Districting Map for all 23,500 parcels in the City, to generate a listing of inconsistent parcels; and WHEREAS, the City has a long history of creating and maintaining buffers between commercial and residential neighborhoods; and
WHEREAS, participants in the LUCE adoption process identified neighborhood preservation as the highest priority of the planning process; and
WHEREAS, a key goal of the LUCE includes maintaining an appropriate town-scale and balanced growth while encouraging certain types of development; and WHEREAS, this goal focuses on the retention of neighborhood character, development that is well-designed and consistent with the desired neighborhood scale, preservation of older buildings, and adaptive reuse of historic properties; and WHEREAS, it is appropriate that the vast majority of the parcels that were designated commercial be restored to a residential designation since such modification would be consistent with the overarching LUCE policy of preserving and protecting existing neighborhoods against the potential impacts related to development: traffic, noise, air quality, and encroachment of commercial activities; and WHEREAS, by retaining the residential zoning and land use designations, these parcels can redevelop, but the development potential for these parcels will be limited to what the residential districts permit;”
In other words, staff had unilaterally upzoned 115 parcels and almost all of them were reverted to residential. 2644 30th Street was correctly designated Residential and R1, consistent with the LUCE, so there was no inconsistency to correct.

Friends of Sunset Park included this property in its comments to City Council to confirm it was all Residential and R1 to avoid any confusion or reneging by staff in the future. FOSP’s comments included a chart with the information below for 2644 30th Street.

Address APN ArcGIS Draft LUCE
Land Use
Designations
Draft
Districting
Map
Action Required
2644 30th (the
original Google
building and large
parking lot,
behind the retail
center on OPB)
4270-
016-
084
R1 Single-Unit
Residential
R1 This lot appears to be all one APN.

However it is R1 with a
commercial building on part of it
and a parking lot on the rest.

Requested action: Please confirm
this is all single family LUCE
Designation and R1 Districting.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2023 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 They had to have a second City Council meeting in June 2015 to incorporate resident comments because staff revealed their maps to residents with inadequate review time for the May City Council meeting. That means there was another MONTH of engagement between residents, staff and City Council on these maps. FOSP’s comments were reiterated regarding inappropriate upzoning at the June 23, 2015 City Council meeting where the status of 2644 30th Street was also clarified. The comment said, “I raise again the LUCE map discrepancies that were brought to your attention by FOSP and remain unresolved by staff, Planning Commission or City Council.

These discrepancies fall into four categories. 1. MUBL in Sunset Park. … 2. Conversion of residential to commercial, similar to the A-lot issue … 3. Spot Zoning … 4. Maintaining commercial designations on lots that continue to be residential use … We would also appreciate clarification that 2644 30th (the original Google building and large parking lot, behind the retail center on OPB) is R1. This lot appears to be all one APN. However it is R1 with a commercial building on part of it and a parking lot on the rest. Please confirm this is all single family LUCE Designation and R1 Districting.” (See email dated May 12, 2015 and June 23, 2015 attached.)

3. The upzoning only applies to the Office Building. False. Owner’s counsel and staff claim that the upzoning only applies to the Office Building, but the resolutions apply to the entire parcel, which is very concerning and also calls into question the legality of the vote taken by the Planning Commission in support of the resolutions.

At the Planning Commission hearing in March 2025, both the staff report and the resolutions referred to upzoning the entire parcel to Neighborhood Commercial for both LUCE and Zoning purposes. However, in the Planning Commission meeting, both owner’s counsel and city staff made the false verbal assurance to the Commissioners that the upzoning applied only to the Office Building. However the resolutions were not amended and applied to the entire parcel.

Now, two months later at City Council, the staff report misleadingly states, “The subject portion of the parcel is currently designated as Single Family Housing and zoned R1 (Single-Unit Residential), but since 1956 has been developed as a commercial office building.” However, both resolutions again reference the entire parcel, which includes the Parking Lot as well as the Office Building. The staff report materially misrepresents what City Council is being asked to approve and calls into question the legality of the vote taken by the Planning Commission in support of the resolutions.

4. The nonconforming use is preventing the owner from re-tenanting. False. Staff claims in an email that the owner can’t lease to a new tenant. This is not true, so long as the use (office building) doesn’t change, because Santa Monica has a legal nonconforming use ordinance that protects the owner so it can continue existing uses.

The owner’s counsel claims that it is limited in its ability to re-tenant the property and that is false. The owner can lease it to any office tenant it wants. As long as the building has been there, tenants have come and gone and it is always occupied.

Chapter 9.27 of the Santa Monica Code is called “Nonconforming Uses and Structures” and its purpose is to “provide for the continuation of uses, continued occupancy and maintenance of structures, and development of parcels that were lawfully established but do not now comply with all of the standards and requirements of this Ordinance so long as the uses, continued occupancy, and maintenance meet the provisions of this Chapter.” Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2024 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 Section 9.27.020 of the Santa Monica Code states that a “lawful nonconforming use” as “an occupancy or activity that was established in compliance with the standards and requirements in effect at the time it is commenced and has not been abandoned withing the same structure or on the same parcel since that date but does not comply with all of the applicable provisions of this Ordinance including, but not limited to, permitted use, location, intensity, operational characteristics, performance standards or hours of operation.” The Office Building and Parking Lot are both legal nonconforming uses. They are under no threat because it remains in an R1 zone. It is no different from any other legal nonconforming use in the city.

It’s disturbing that staff is perpetuating a false limitation. In an email staff said, “This was brought to our attention by the property owner when they were exploring re-tenanting of office space that had become vacant for more than a year and discovered that no commercial uses would be allowed.” A plain reading of the code shows this is not the case. Staff should have read the code and advised the owner accordingly. Instead, the staff has embarked on unnecessarily changing the LUCE and the zoning at the behest of Harding Larmore to “fix” a problem that doesn’t exist. If staff’s position here is to be taken seriously, then every multi-tenant building would face abandonment when a single space isn’t filled and that can hardly be the legal result. I asked staff what specific use is being prevented, or what specific plans are being thwarted, by the current zoning of the parcel and staff did not respond.

The owner’s counsel claims it is limited in change of use, and while that is true, it is true for every owner of a nonconforming use in the city of Santa Monica. This property is no different and deserves no special treatment. Not only is this NOT the purview of staff to change zoning for an owner to do something they shouldn’t, but it is evidence of spot-zoning to benefit this owner or a developer. (See Code Section 9.27 attached.)

5. The nonconforming use is preventing the owner from renovating. False. The staff report claims, “This has created a nonconforming condition and impediments to future development … for the current structure.” This is not true because Santa Monica has a legal nonconforming use ordinance that protects the owner so it can remodel or renovate without “abandoning” existing uses.

As stated above, the Office Building and Parking lot are lawful nonconforming uses. Section

9.27.050.3 of the Santa Monica Code states, “Cessation of use due to remodeling shall not be considered abandonment so long as building permits are active in accordance with Chapter 8.08 of the Municipal Code. However, if the building permit expires before the use resumes, the oneyear period under subsection (B)(1) shall relate back and commence with the cessation of use.” So the owner is able to renovate this property as it currently exists as a legal nonconforming use and staff should know this. The owner just can’t redevelop the property into a massive commercial development that is inappropriate for the neighborhood. This is the same policy that applies to any other legal nonconforming use in the city. Clearly they want to go big and just aren't saying that. And it should go without saying that nobody is spending money to hire Harding Larmore to upzone their property unless they are trying to do something different/bigger with it or sell it with the new, extremely valuable entitlements. (See Code Section 9.27 attached.)

6. The nonconforming use is preventing the owner from getting financing. False. The staff report claims, “This has created a nonconforming condition and impediments to financing for the current structure.” This is not true because the owner most recently financed the property in 2019 under the current LUCE and zoning designations.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2025 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 6 In 2019, the owner granted two Deeds of Trust to First Republic, one for $6,227,000 and another for $2,000,000, for a total of $8,227,000 in financing. At the time of that financing, a commercial lender would have performed due diligence to confirm that the zoning and use supported the appraised value on which the loan was based. Those deeds of trust were assigned to JPMorgan Chase in 2024 and continue to encumber the property. So the owner clearly is able to finance this property as it currently exists as a legal nonconforming use. It should not be able to obtain financing for a massive commercial development that is inappropriate for the neighborhood and violations our zoning.

B. ADDITIONAL PROBLEMS WITH THIS SPOT UPZONING
In addition to the false statements in the staff report described above, this upzoning raises the following additional issues:

1. There are no development standards for interior Neighborhood Commercial parcels in the Santa Monica Code, so a new category would have to be created and that is not before you on the agenda.

Because the Neighborhood Commercial Zone was never intended to include interior parcels, there are no development standards for Neighborhood Commercial anywhere but the boulevards, and the standards that exist for each boulevard were created based on the character of such boulevard.

Here is what the Code says about Neighborhood Commercial. Clearly, it's supposed to be Ocean Park Blvd. and NOT the residential streets:

"NC Neighborhood Commercial. This Zoning District is intended to maintain and enhance small-scale neighborhood shopping districts that provide daily goods and services easily accessible from surrounding residential neighborhoods while also serving a sub-regional role.

This District provides for a scale and character of development that is pedestrian-oriented and which tends to attract and promote a walk-in clientele. Development within this District should maximize human-scaled elements while providing a sensitive transition between these uses and neighboring residential areas. Ground floor uses include active, local-serving retail and service commercial uses such as small restaurants, laundromats, dry cleaners, beauty/barber shops, and clothing and grocery stores. Uses above the ground floor include residential, commercial, and local-serving office uses. This District is comprised of 4 geographic areas:

Main Street. Main Street is a neighborhood commercial street that is home to many boutiques, restaurants, and neighborhood-serving businesses. Main Street has both local and regional appeal, providing an eclectic mix of activities that is unique to Southern California.

Ocean Park Boulevard. Ocean Park Boulevard is a local-serving boulevard with 2 vibrant, neighborhood-serving commercial areas. The boulevard is a complete street for pedestrians, bicycles, transit, and autos, with an enhanced streetscape and dining, retail, and service needs within walking distance of the Sunset Park and Pico neighborhoods.

Pico Boulevard. Pico Boulevard is a local-serving, commercial boulevard that provides an enhanced environment for pedestrians and includes a wider choice of local-serving retail, Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2026 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 7 expanded mobility, and shared parking.

Montana Avenue. Montana Avenue serves as a local, commercial, and entertainment street that also draws regional visitors who enjoy its many cafés and boutique stores.

(Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015; Amended by Ord. No. 2742CCS § 2, adopted April 11, 2023)"

In addition, this code section speaks to the purpose of commercial designations on the boulevards:

"Provide appropriate buffers and transition standards between commercial and residential uses to preserve both commercial and mixed-use feasibility and residential quality and provide a sensitive transition between the commercial uses and neighboring residences." As a reminder the height for Neighborhood Commercial on Ocean Park Boulevard was “mistakenly” increased by staff to 55 feet in connection with our Housing Element. This is taller than Pico’s Neighborhood Commercial zone and the same height as Lincoln’s General Commercial Zone. Residents are still waiting for the city to correct this error. It would be completely inappropriate to apply a boulevard height to an interior parcel, especially one that is erroneous to start with. In order to change the zoning of this parcel, city council would have to create an entirely new development standard for interior parcels and that is not on the agenda.

2. This is one parcel, and there is no legal opinion on whether it can be zoned in part.

In fact staff is taking the opposite position as their justification for recommendations 4 and 5 relating to 1331 Wilshire.

This is the legal description for 2644 30th Street:
“LOTS 77, 78, 83 AND 84 OF TRACT NO. 1980, IN THE CITY OF SANTA MONICA,

COUNTY OF LOS ANGELES, STATE OF CALIFORNIA, AS PER MAP RECORDED IN BOOK 21 PAGE 152 OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY. EXCEPT THE SOUTHEASTERLY 60 FEET OF LOTS 78 AND 83.

APN: 4270-016-084”
Ironically, staff is claiming that parcels cannot have two different zones in order to justify upzoning the Wilshire parcel, also on the agenda. Staff is trying to turn that parking lot from R2 to commercial by claiming, “Additionally, the subject split zoning presents a constraint on potential redevelopment of the parcel as two incongruous sets of land use regulations and development standards would be applied to the parcel.” So what is the city’s position on split zoning or does it depend on what the developer is asking for?

3. The LUCE update took 6 years and the Zoning Ordinance Update took almost 2 years. Residents participated while the owner did not, and is not entitled to special treatment for a do-over because it failed to participate.

This parcel has been owned by 2644 SM Partners since 1987. The partnership appears to be owned by Rita Sternberg and Scott Sternberg of Beverly Hills, and Scott Sternberg has signed Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2027 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 8 documents as the general partner of the partnership.

The Parking Lot was already a legal nonconforming use when they bought the property in 1987.

The 2010 LUCE update process spanned 6 years and there were many public meetings. The Sternbergs did not comment at the time the property was confirmed as Single Family Housing, with the Office Building becoming a legal nonconforming use.

The 2015 Zoning Ordinance Update process spanned several more years and over 33 public meetings. The Sternbergs also did not participate in or comment when the property was confirmed to be R1, with the Office Building a legal nonconforming use.

Residents spent hundreds of hours over the multi-year process, as evidenced by the many meetings, written comments, and oral comments at both Planning Commission and City Council meetings. Not once did the Beverly Hills owner or their counsel engage or comment. It is inappropriate for the owner and their counsel (or perhaps counsel for a developer looking to buy the property) to claim that they are entitled to be given a different zoning now because they failed to participate in the appropriate public processes at the time.

4. Upzoning would a windfall to the owner because they purchased the Office Building and Parking Lot when they were zoned R1 and C2, respectively, with a maximum height of thirty feet.

The Parking Lot has always been R1 so it was already a legal nonconforming use when the owner bought the property in 1987. The owner has held the property for passive income based on the current uses for 38 years. When the zoning was confirmed R1 in 2015, the height of Neighborhood Commercial on Ocean Park Blvd was also still 30 feet. It is only because of the erroneous upzoning of Neighborhood Commercial on Ocean Park Blvd. that the height on the boulevard is now 55 feet, or 85 feet with state bonuses. It is absurd to believe that the owner of 38 years reasonably expected, or is entitled to, develop this interior parcel beyond the 2-story office building and parking lot they purchased. It is entirely feasible that Harding Larmore also represents a developer looking to purchase this property for redevelopment. Converting it to Neighborhood Commercial confers a massive windfall to both the owner and a potential developer overnight, while harming the neighbors.

5. Residential owners and renters who purchased their homes or moved to the neighborhood in reliance on current zoning will be harmed.

It’s not ok to force residents to suffer commercial encroachment into their residential neighborhood just so a developer can make more money. If this is zoned Neighborhood Commercial and combined with the boulevard parcel, the resulting development could be 85 feet tall and extend one and a half football fields into the residential neighborhood. This is precisely what the LUCE is supposed to protect us against.

CONCLUSION
The upzoning of 2644 30th Street is an illegal spot-zoning based on inaccurate and misleading statements in the staff report that appear to have come from owner’s counsel. It would result in a MASSIVE windfall for the owner, and negative impacts on the residential neighbors. Nowhere Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2028 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 9 else in the city of Santa Monica is the Neighborhood Commercial designation applied to an interior parcel to bring commercial use into the residential neighborhood beyond the depth of the other Neighborhood Commercial parcels on the boulevards. This would be the ONLY one in the entire city, and is further evidence of spot zoning.

Furthermore, there has been no outreach to the neighborhood by the owner or city staff.

Furthermore, city staff appear to have adopted the owner’s false statements without investigation, even though they are not supported by the public record or the law. The staff report contains numerous inaccurate and misleading statements, and the upzoning presents issues not addressed in the staff report.

Please vote NO on Staff Recommendations 6 and 7.

Thank you for your consideration.

Regards,
Nikki and Dan Kolhoff
Sunset Park Residents and Santa Monica Voters
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2029 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 10 The parcel is dark red. Light red is existing NC. Green is residential.

View of Office Building from Parking Lot.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2030 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 11 29th Street home to the north.

Homes across the street on 29th Street.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2031 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 12 Homes across the street on 29th Street.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2032 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 13 View through Parkinig Lot facing south.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2033 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 14 29th Street facing north.
29th Street facing south.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2034 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 15 Homes across the streetHomes on 30th Street.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2035 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 16 Homes across the street on 30th Street.

Homes to the north of property on 30th Street.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2036 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 17 View of property from 30th Street.

View through Parking Lot to 30th Street.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2037 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 18 30th Street facing north.
30th Street facing south.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2038 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 19 Picnic bench in Parking Lot.

Patios for tenants of the Office Building.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2039 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) CHAPTER 9.27

NONCONFORMING USES AND STRUCTURES
§ 9.27.010. Purpose.

This Chapter's standards have been developed in recognition of the City's policies related to historic preservation, adaptive reuse, and sustainability and provide for the continuation of uses, continued occupancy and maintenance of structures, and development of parcels that were lawfully established but do not now comply with all of the standards and requirements of this Ordinance so long as the uses, continued occupancy, and maintenance meet the provisions of this Chapter.
(Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.020. Definitions.

Any lawfully established use or structure that is in existence on the effective date of this Ordinance but does not comply with all of the standards and requirements of this Ordinance or subsequent amendment including, but not limited to, the lack of an approved permit or other required authorization shall be considered nonconforming. Unless otherwise specified, the term "nonconforming" as used in this Ordinance shall mean "lawful nonconforming" as defined herein.

Lawful nonconforming use. An occupancy or activity that was established in compliance with the standards and requirements in effect at the time it commenced and has not been abandoned within the same structure or on the same parcel since that date but does not comply with all of the applicable provisions of this Ordinance including, but not limited to, permitted use, location, intensity, operational characteristics, performance standards or hours of operation.

Lawful nonconforming structure. A building or structure that was erected in compliance with the standards and requirements in effect when it was constructed but does not comply with all of the applicable provisions of this Ordinance including, but not limited to, density, floor area, height, setback, usable open space, and other development standards.

Nonconforming parking or loading. An existing use of land or structure shall not be determined to be nonconforming solely because of a lack of on-site parking and/or loading facilities required by this Chapter, provided that facilities used for on-site parking and/or loading as of the date of adoption of this Ordinance are not reduced in number to less than what this Ordinance requires.

The parking provided by City-Designated Historic Resources shall be considered conforming if it is the amount of parking provided as of July 6, 2010. See also Section 9.28.180(B). (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.030. Legal Nonconforming Structures.

A nonconforming structure may be maintained as follows:

A. Repairs, Alterations, and Improvements. Subject to Chapter 9.25 and subsection (B) of this Section, repairs, alterations, or improvements may be made to nonconforming buildings.

B. Additions and Enlargements. An addition to or enlargement of a nonconforming building shall be permitted if the addition or enlargement is made to conform to all the development standards and use regulations of the District in which it is located.

City of Santa Monica, CA
§ 9.27.010 § 9.27.030
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2040 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) C. Replacing Nonconforming Features or Portions of Buildings. Nonconforming features or portions of buildings that are removed shall not be replaced unless they conform to the provisions of this Chapter. Notwithstanding this requirement, nonconforming architectural features which have been removed from any existing building which is designated as a Historic Resource or listed on the Historic Resources Inventory may be replaced if the Landmarks Commission determines that such feature contributes to the building's historic architectural integrity and that the reconstruction conforms to the Secretary of Interior's Standards for the Treatment of Historic Properties. Landmarks Commission review of such reconstruction shall be processed generally in accordance with the procedures for processing applications for Certificates of Appropriateness contained in Chapter 9.56. Any project subject to Landmarks Commission review under this Section shall not require additional review by the Architectural Review Board. The determination of the Landmarks Commission under this Section shall be appealable to the City Council.

D. Moving. No nonconforming building shall be moved in whole or in part to any other location on the parcel unless every portion of the building is made to conform to all of the regulations of the District in which it is located. A relocated building shall be considered a new structure.

However, if the building is a City-Designated Historic Resource, the Landmarks Commission may approve nonconforming setbacks through the issuance of a Certificate of Appropriateness.

E. Damaged or Destroyed. A nonconforming building which is damaged or destroyed may be restored or replaced in accordance with Section 9.27.040.

F. Demolition. An existing nonconforming building that is demolished shall lose any legal nonconforming status and may only be replaced or rebuilt if the entire structure is made to comply with all currently applicable zoning ordinance requirements unless:

1. The existing building is a Historic Resource or is listed on the City's Historic Resources Inventory, provided the alteration or addition conforms with the Secretary of the Interior's Standards for Rehabilitation and Illustrated Guidelines for Rehabilitating Historic Buildings.

2. The existing building is commercial or industrial and is altered in accordance with all of the following criteria:
a. The alterations only involve the replacement of the footings, cripple walls, stem walls, or similar structural components between the structure's footings and the finished floor of the first story as defined in Chapter 8.12 of the Santa Monica Municipal Code;
b. The alterations are only undertaken to the minimum extent necessary to maintain a safe structure;
c. The existing exterior wall elements or principal support structure remain in place at all times and provide necessary structural support to the building upon completion of the alterations; and
d. No new floor area is added.

City of Santa Monica, CA
§ 9.27.030 § 9.27.030
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2041 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.040. Restoration of a Damaged Nonconforming Structure.

An existing nonconforming structure that is damaged or destroyed by a nonvoluntary fire or explosion, earthquake, or other natural disaster may be restored or replaced to its density (including square footage and number of rooms or dwelling units, as applicable), parking, building footprint and envelope, and height that existed prior to the destruction subject to the following:

3. The existing building is residential and is altered or added to in accordance with all of the following criteria:
a. The alterations or additions to the existing residential building include the replacement of the footings, cripple walls, stem walls, or similar structural components between the structure's footings and the finished floor of the first story as defined in Chapter 8.12 of the Santa Monica Municipal Code; and b. The existing first story exterior wall elements remain in place at all times and provide necessary structural support to the building upon completion of the alteration or addition.

4. The building was demolished as a result of a nonvoluntary fire or explosion, earthquake, or other natural disaster and it is restored or replaced in accordance with Section

9.27.040.

G. Termination. A nonconforming building need not be discontinued and removed or altered so long as the nonconforming building is maintained in accordance with this Section.

A. Damaged Structure Restoration Application.

1. Application. To request a permit to restore a damaged structure, the applicant must submit a complete application on a form provided by the Director in addition to any other material, reports, dimensioned plans, or other information required to take action on the application. Each application shall also include:
a. Two estimates of the cost of repair or reconstruction from properly licensed contractors. The estimates must contain sufficient detail to ascertain the scope of the proposed work and include the contractor's profit, overhead and insurance cost. b. For structures that have been posted with either a no entry notice (Red-tagged) or limited entry notice (Yellow-tagged), a written structural analysis of the structure prepared by a licensed engineer in accordance with the standards provided by the Building and Safety Division.
c. Two sources of documentation of the pre-destruction condition of the property or structure sufficient to enable the City to determine whether the project involves inkind repair or reconstruction. Documentation may include:
i. Approved building permits;
ii. Approved construction drawings;
City of Santa Monica, CA
§ 9.27.030 § 9.27.040
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2042 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) iii. Surveys from licensed surveyors;
iv. County assessor information;
v. Certified property appraisals;
vi. Sanborn maps;
vii. Reports or drawings prepared by an insurance company to support damage claims;
viii. Photographs;
ix. City planning records; or
x. Any other verifiable information.

2. Review Process. Each application to restore a damaged structure shall require plan check approval as the final review prior to issuance of the applicable permit. In addition, the following procedures shall apply:
a. Where the cost of repair is less than 50 percent of the replacement value of the structure, or where less than 50 percent of the exterior walls are removed to the foundation (regardless of cost of repair), the following review or reviews will be required:
i. If there is not a significant design change from the original design, Administrative Approval and plan check is required.
ii. If there is a significant design change, Architectural Review Board review is required. Single-Unit homes are not subject to Architectural Review Board pursuant to this subsection.
b. Where the cost of repair equals or exceeds 50 percent of the replacement value of the structure, and 50 percent or more of the exterior walls are removed to the foundation, but the development on the parcel is below the development review threshold for the district in which it is located, Administrative Approval and Architectural Review Board approval shall be required.
c. Where the cost of repair equals or exceeds 50 percent of the replacement value of the structure, and 50 percent or more of the exterior walls are removed to the foundation, and the development on the parcel is above the development review threshold for the District in which it is located, a Development Review Permit is required prior to plan check. Architectural Review Board approval shall also be required.
d. Notwithstanding the above, any restoration of a damaged structure that is a CityDesignated Historic Resource shall be subject to the review of the Landmarks Commission.

3. Standards for Review. The following standards shall govern the review of an application for damaged structure restoration:

City of Santa Monica, CA
§ 9.27.040 § 9.27.040
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2043 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) a. Administrative Review. Administrative approval shall be granted if the project plans reflect in-kind repair or reconstruction.
b. ARB/Landmarks Review. The Architectural Review Board, or for City-Designated Historic Resources the Landmarks Commission, or Planning Commission/City Council on appeal, shall grant approval if both of the following findings can be made:
i. The structure's architectural design is substantially similar to the pre-damage design; or, if a significant design change is involved, the structure's architectural design is compatible with the general area in which it is located. ii. If the structure is a City-Designated Historic Resource and being repaired, the repair will meet the Secretary of the Interior's Standards and will not compromise the architectural or historical integrity of the structure or potential district; or, if being reconstructed, the reconstruction is required, based upon an estimate from a professional experienced in rehabilitation of historic structures, demonstrating it is not economically feasible to repair the structure. The Landmarks Commission may request 2 alternative evaluations and detailed estimates to support the determination of economic infeasibility. c. Development Review Permit. The Planning Commission, or City Council on appeal, shall grant approval if all of the following findings can be made:
i. The structure's architectural design is substantially similar to the pre-damage design; or, if a significant design change is involved, the structure's architectural design is compatible with the general area in which it is located; ii. The plan for the proposed building or structure is expressive of good design and in general contributes to the image of Santa Monica as a place of beauty, creativity and individuality;
iii. The proposed building or structure is not of inferior quality such as to cause the nature of the local neighborhood or environment to materially depreciate in appearance and value; and
iv. If the structure is a Historic Resource, the repair will meet the Secretary of the Interior's Standards and will not compromise the architectural or historical integrity of the structure or potential district; or, if reconstruction is involved, based upon an estimate from a professional experienced in rehabilitation of historic structures, it is not economically feasible to repair the structure. d. Any reconstruction, repair, or restoration undertaken pursuant to this Section shall conform to all applicable Technical Code requirements, and a building permit must be obtained within 2 years, or 3 years if a Development Review Permit is required, after the date of the damage or destruction. The Director may approve an extension if the owner has applied for and diligently pursued approval of the building permit.

City of Santa Monica, CA
§ 9.27.040 § 9.27.050
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2044 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) § 9.27.050. Legal Nonconforming Uses.

A legal, nonconforming use may be maintained subject to the following provisions:

A. Change of Ownership. A change of ownership, tenancy, or management of a nonconforming use shall not affect its status as a legal, nonconforming use.

B. Abandonment. If a nonconforming use of a building, structure, or parcel ceases for a continuous period of one year or more, the use shall be considered abandoned, and the building, structure, or parcel shall thereafter be used only in accordance with the regulations for the District in which it is located except as provided below. It is the responsibility of the applicant to provide evidence demonstrating to the satisfaction of the Director that the use was legally established and has not been abandoned. Notwithstanding the above, no nonconforming residential use shall be considered abandoned regardless of the length of time of non-use unless the Director determines the building is dangerous, unsafe, a health and safety hazard, and/or uninhabitable, and these conditions cannot be remedied.

1. The one-year period to determine that a nonconforming use has been abandoned shall commence when the use ceases and any one of the following occurs:
a. The business license lapses;
b. The site is vacated;
c. The lease is terminated;
d. Utilities are terminated; or
e. A conforming use that meets the applicable requirements of this Ordinance is lawfully established in the space previously occupied by the nonconforming use.

2. Once the one-year period has commenced under subsection (B)(1) that period shall only be terminated if the nonconforming use is fully licensed, permitted, and operational for 60 continuous days. Operational shall mean that the nonconforming use is open for business to the public and provides services typically associated with the nonconforming use during the hours and days that are customary for that nonconforming use.

3. Cessation of use due to remodeling shall not be considered abandonment so long as building permits are active in accordance with Chapter 8.08 of the Municipal Code.

However, if the building permit expires before the use resumes, the one-year period under subsection (B)(1) shall relate back and commence with the cessation of use.

4. Except as provided in subsection (B)(5), no nonconforming use may be resumed, reestablished, or reopened once it has been determined to have been abandoned for one year.

5. If the nonconforming use of a building, structure, or parcel occurred in a Citydesignated Historic Resource, the nonconforming use may be resumed, reestablished, or reopened even if that nonconforming use has been abandoned for more than one year and other uses have occurred since that abandonment if a Conditional Use Permit is City of Santa Monica, CA
§ 9.27.050 § 9.27.050
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2045 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) obtained based on the following findings:
a. The City-designated Historic Resource was not in residential use as of December 16, 2014;
b. The proposed use is compatible with existing and permissible land uses within the District and the general area in which the proposed use is to be located; c. The proposed use is compatible with any of the land uses presently on the subject parcel if the land uses are to remain;
d. The physical location or placement of the use on the site is compatible with and relates harmoniously to the surrounding neighborhood;
e. The subject parcel is physically suitable for the type of land use being proposed; and
f. The proposed use would not be detrimental to the public interest, health, safety, convenience, or general welfare.

6. Notwithstanding the foregoing, or anything to the contrary in this Ordinance, the following legal, nonconforming uses may be resumed, reestablished, or reopened, even if that nonconforming use has been abandoned for more than one year, unless a conforming use that meets the applicable requirements of the Zoning Ordinance has been lawfully established in the space previously occupied by the nonconforming use:
a. In areas excluding the Third Street Promenade Area:
i. Restaurant, full service,
ii. Restaurant, limited service and take-out,
iii. Food hall,
iv. General retail sales, small scale, and
v. General retail sales, medium scale;
b. In the Third Street Promenade Area:
i. Bar/nightclub/lounge,
ii. Restaurant, full service,
iii. Restaurant, limited service and take-out,
iv. Food hall,
v. General retail sales, small scale, and
vi. General retail sales, medium scale.

C. Conversion to Conforming Use. If a nonconforming use is converted to a conforming use, the nonconforming use may not be resumed except as authorized by subsection (B)(5).

City of Santa Monica, CA
§ 9.27.050 § 9.27.050
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2046 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015; amended by Ord. No. 2520CCS § 22, adopted June 14, 2016; Ord. No. 2726CCS § 10, adopted October 25, 2022; Ord. No. 2741CCS § 4, adopted April 11, 2023)
§ 9.27.060. Public Utility Exception.

Nothing contained in this Chapter shall be construed or implied so as to require the removal of governmental or public utility buildings, structures, equipment, or facilities provided that there is not a change of use nor enlargement of the land area devoted to the use. (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.070. Building Permits or Certificates of Occupancy Prohibited.

When any nonconforming building or use is required to be eliminated pursuant to the provisions of this Chapter, no building permit or Certificate of Occupancy shall thereafter be issued for further continuance, alteration, or expansion of the nonconforming building or use. The issuance of the permit or Certificate in error shall not be construed to allow the continuation of the nonconforming building or use.
(Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) D. Expansion of Nonconforming Use. A nonconforming use of a building or portion of a building that conforms to the development standards of this Chapter shall neither be expanded into any other portion of the building nor changed except to a conforming use. The nonconforming use of land shall not be expanded or extended in area, except that outdoor dining areas and other outdoor spaces permitted pursuant to Sections 9.31.199, Outdoor Commercial Uses on Private Property, and 9.31.200, Outdoor Dining and Seating on Sidewalks, shall not be considered an expansion in area for the purposes of this subsection.

E. Intensification of Uses. A nonconforming use shall not be permitted to substantially change in mode or character of operation. A substantial change in mode or character of operation shall include, but is not limited to, addition of uses, a change in operational hours that extends past 11:00 p.m. any night Sunday through Thursday and/or midnight on Friday and/or Saturday or begins before 7:00 a.m., a 5% increase in the floor area of the premises, or a 5% increase in the number of seats in any restaurant, but in no case shall the increase exceed any established seating limitation in the underlying zoning district.

F. Continuation/Reinstatement. The uses existing in a structure that have been restored pursuant to Section 9.27.040 may be continued/reinstated in the reconstructed/replacement structure so long as no continued/reinstated nonconforming uses are expanded, changed or substituted.

G. Legal, Nonconforming Rent-Controlled Multiple-Unit Properties. Notwithstanding subsection (D), existing multi-unit residential units in the R1 Single-Unit Residential District that are presently controlled by Article XVIII of the City Charter may be expanded in area provided such expansion complies with all other applicable Code provisions, including those governing height, number of stories, setbacks, stepbacks, parcel coverage and off-street parking (unless the City's Parking and Traffic Engineer determines that the provision of parking is not feasible), and the number of housing units on the multi-unit residential property does not increase.

City of Santa Monica, CA
§ 9.27.050 § 9.27.080
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2047 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) § 9.27.080. Removal of Illegal Nonconforming Buildings and Uses.

Nothing contained in this Chapter shall be construed or implied so as to allow for the continuation of illegal nonconforming buildings and uses. These uses shall be removed immediately upon notification by the Director.
(Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.090. Rent Control Bootleg Units.
(Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.100. Continuation of Nonconforming Uses.

No person shall occupy any nonconforming building and no person shall continue any nonconforming use except as provided for in this Chapter. (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015) § 9.27.110. Parking Lots in Residential Districts.

A. A rental unit registered with the Santa Monica Rent Control Board, which was built or created without City planning or building permits shall not be required to meet the setback and density requirements of this Ordinance if the unit is or can be made habitable as determined by the Director.

B. A rental unit exempt from setback and density requirements pursuant to subsection (A) of this Section shall be required to provide parking for the unit pursuant to Chapter 9.28, Parking, Loading, and Circulation, unless the Director determines that the provision of parking is not feasible. Parking which would result in a significant reduction in setback space is not feasible. The location of any feasible parking shall comply with the Chapter 9.28, Parking, Loading, and Circulation, except the Director may authorize a reduction in parking space dimensions so long as the space remains accessible and safe.

C. A rental unit that meets the requirements of this Section shall be considered a legal, nonconforming unit.

A. Except as provided in Section 9.31.070(D), parking lots on parcels in Residential Districts shall be permitted to remain provided:

1. The commercial parcel supported by the residential parking lot is not redeveloped for another use;

2. The lot remains as a surface level parking lot;

3. The use or uses existing on the commercial parcel supported by the residential parking lot do not change. For purposes of this requirement, a change of use shall be defined as any new use which requires more intense parking standards than exists on the effective date of the ordinance codified in this Chapter;

4. The square footage of the existing commercial building on the commercial parcel is not added to or enlarged beyond 50% of the floor area existing on the effective date of this Chapter; and
City of Santa Monica, CA
§ 9.27.080 § 9.27.110
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2048 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) (Added by Ord. No. 2486CCS §§ 1, 2, adopted June 23, 2015)

5. The required parking for any new addition or expansion under 50% is not located on the residentially zoned parking lot. A parking lot on a residentially zoned parcel shall revert to residential use when one or more of the above conditions are not met.

B. Parking lots in Residential Districts with A Off-Street Parking Overlays are regulated by Chapter 9.16, A Off-Street Parking Overlay District.

City of Santa Monica, CA
§ 9.27.110 § 9.27.110
Downloaded from https://ecode360.com/SA5008 on 2025-04-14 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2049 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Council 5/12/15 agenda item 5-A - LUCE Map Discrepancies (FOSP & PNA) From: [email protected]
To: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Cc: [email protected]; [email protected]; [email protected]; [email protected] Date: Tuesday, May 12, 2015 at 03:42 PM PDT
May 12, 2015
To:       City Council
From:  Zina Josephs, Nikki Kolhoff, Maria Loya, and Oscar de la Torre RE:       May 12, 2015 agenda item 5-A
Attached please find a spreadsheet with LUCE Map Discrepancies in the Sunset Park and Pico Neighborhoods.

The addresses in question are 2337 Centinela, 2249 - 30th St., 2410 Pico, 1925 Pico, 2024 - 19th St., 2019 - 18th St., 1930 - 11th St., 1922-1924 - 11th St., 2683 - 34th St., 3401 Ocean Park Blvd., and 2644 - 30th St.

For example:
1) 2410 Pico – This parcel (Rite Aid, Next Door by Josie, and Josie restaurant) is a single parcel zoned MUBL in the middle of many blocks of NC (19th to 31st) on the south side of Pico.

In addition, as the parking lots behind have been correctly returned to R1, it is the only MUBL bordering R1 in the entire city. This is spot zoning and should not be allowed.
2) 1925 Pico – This single parcel (Burger King) is zoned MUBL in the middle of several blocks (17th to 21st) of NC and across the street from NC. This is spot zoning and should not be allowed.

Some of our other requests have to do with
-- preserving rent-controlled apartments,
-- preserving family day care, and
5/4/25, 10:25 AM Yahoo Mail - Council 5/12/15 agenda item 5-A - LUCE Map Discrepancies (FOSP & PNA) about:blank 1/2
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2050 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) ZOU_Kolhoff__Z_SunsetPark_LUCEMapDiscrepancies2.doc
46kB
-- preserving potential landmarks or structures of merit Please review the attached spreadsheet and our requested actions.

Thank you for your consideration.
5/4/25, 10:25 AM Yahoo Mail - Council 5/12/15 agenda item 5-A - LUCE Map Discrepancies (FOSP & PNA) about:blank 2/2
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2051 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Sunset Park and Pico Neighborhood LUCE Map Discrepancies Address APN ArcGIS Draft LUCE
Land Use
Designations
Draft
Districting
Map
Action Required
2337 Centinela
(next to 3402 Pico
– the GRAMMY
site)
4270-010-090 R2 MUBL MUBL This is an R2 lot, but the Zoning Administrator states it was changed to MUBL in 2013. We are
not aware of any publicly agendized item
relating to the change. Requested actions:

Change Designation to Low Density Residential.

Change Districting to R2. Alternatively, change
to NC, along with all lots on Pico east of 31st
because MUBL is inappropriate in Sunset Park.
2249 30th St.
(behind 3010 Pico
– south side – Der
Wienerschnitzel)
4270-006-002 C4 NC NC This is a little row of 1-story bungalows adjacent to the Der Wienerschitzel parking lot.

Requested action: Change to R2 to preserve
rent-controlled units.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2052 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Address APN ArcGIS Draft LUCE
Land Use
Designations
Draft
Districting
Map
Action Required
2410 Pico Blvd.
(Rite Aid, Next
Door by Josie, and
Josie restaurant) -
(south side)
4273-008-023 C4 MUBL MUBL This is a single lot zoned MUBL in the middle of many blocks NC (19th to 31st). Now that the
parking lot has been correctly returned to R1,
this is spot zoning. The Zoning Administrator
states this isn’t spot zoning because MUBL is
across the street. This isn’t persuasive because
(1) there must be a border established at some
point or the entire city would be MUBL, and (2)
PNA and FOSP have told the City Council that
MUBL is inappropriate for our neighborhoods,
and we have requested NC instead.

Furthermore, this is the only MUBL
bordering R1 in the entire city, so the issues
we raised relating to insufficient buffers
between R1 and commercial, as compared to
R1 and multi-family residential, come into play
here because there are minimal set backs and
height limitations for MUBL directly adjacent to
R1. Requested actions: We request a
Resolution of Intention to change the LUCE
Designation to NC and the Districting Map to
NC.
1925 Pico (Burger
King) (north side)
4274-019-024 C2 MUBL MUBL This is a single lot zoned MUBL in the middle of NC (17th to 21st). This is spot zoning.

Requested actions: A Resolution of Intention
to change the LUCE Designation to NC, and
change the Districting Map to NC.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2053 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Address APN ArcGIS Draft LUCE
Land Use
Designations
Draft
Districting
Map
Action Required
2024 19th Street
(behind 1819 Pico
– The Manor –
north side)
4274-017-017 R2 NC R2 This is currently an apartment building. Rentcontrolled units should be preserved.

Requested actions: We request a Resolution of
Intention to change the LUCE Designation from
NC to R2, and the Districting Map to remain R2.
2019 18th Street
(behind 1801 Pico
Subway sandwich
shop – north side)
4274-017-016 R2 NC R2 This is currently 1-story residential. Rentcontrolled units should be preserved.

Requested action: A Resolution of Intention to
change the LUCE Designation from NC to R2,
and the Districting Map to remain R2.
1930 11th (behind
1021 and 1023
Pico – north side)
4283-024-003 C4 GC GC This is a very old 1-story house, possibly a potential landmark or structure of merit. It
should be preserved. Requested action: A
Resolution of Intention to change the LUCE
Designation from GC to residential, and change
the Districting Map to residential.
1922-1924 11th
(behind 1021 and
1023 Pico – north
4283-024-004 R2 Low Density
Residential
GC This is a cute little 1-story tile-roof duplex
being used for family day care. Family day care
is a priority in the city and should be preserved.

The LUCE Designation is correct at Low Density
Residential. Requested action: Maintain the
LUCE Designation, but change the Districting
Map back to R2.
2683 34th (behind
3401 Ocean Park
Blvd.)
4270-017-019 C2 NC NC This is currently an apartment building. Rentcontrolled units should be preserved.

Requested action: A Resolution of Intention to
change the LUCE Designation from NC to R2,
and change to Districting Map to R2 as well.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2054 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Address APN ArcGIS Draft LUCE
Land Use
Designations
Draft
Districting
Map
Action Required
3401 Ocean Park
Blvd.
4270-017-020 C2 NC NC This is currently an apartment building. Rentcontrolled units should be preserved.

Requested action: A Resolution of Intention to
change the LUCE Designation from NC to R2,
and change to Districting Map to R2 as well.
2644 30th (the
original Google
building and large
parking lot, behind
the retail center on
OPB)
4270-016-084 R1 Single-Unit
Residential
R1 This lot appears to be all one APN. However it
is R1 with a commercial building on part of it
and a parking lot on the rest. Requested
action: Please confirm this is all single family
LUCE Designation and R1 Districting.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2055 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) City Council 6-23-15 Agenda Item 7A (LUCE Map)
From: Nikki Kolhoff ([email protected])
To: [email protected]
Date: Tuesday, June 23, 2015 at 11:24 AM PDT
To: Mayor McKeown and City Council
RE: 6/23/15 City Council agenda item 7-C: Approve LUCE Amendments and LUCE Land Use Designation Map Amendments
I strongly support the amendment to eliminate the Lincoln/Ocean Park Activity Center low overlay from the LUCE Land Use Designation Map.

I also raise again the LUCE map discrepancies that were brought to your attention by FOSP and remain unresolved by Staff, Planning Commission or City Council. These discrepancies fall into four categories.

1. MUBL in Sunset Park. The MUBL designation is inappropriate for Sunset Park and all such designations should be changed to NC.

Requested actions: A Resolution of Intention to change the LUCE Designation to NC and the Districting Map to NC.

2. Conversion of residential to commercial, similar to the A-lot issue. These are lots that are currently zoned residential and then became commercial on the LUCE Land Use Designation. Like the A-lots, these changes were covertly made by staff to increase the size of commercial lots for development along the boulevards. Just as it was wrong to convert the A-lots to commercial, it is wrong to convert purely residential lots to commercial. The staff has told you that the change on the districting map is merely “clerical” to match the land use designation, but the land use designation was improperly changed from residential to commercial in 2010.

Requested actions: A Resolution of Intention to change the LUCE Designation to Low Density Residential and the Districting Map to R2.
a. 2337 Centinela – This is currently zoned R2 and was changed to MUBL on both the land use designation and districting map. It should be returned to R2. b. 2024 19th Street (behind 1819 Pico – The Manor – north side). This is currently an apartment building zoned R2 but was changed to NC in the LUCE designation and R2 on districting. Rent-controlled units should be preserved so it should be changed to Low Density Residential land use designation.
c. 2019 18th Street (behind 1801 Pico Subway sandwich shop – north side). This is currently 1-story residential zoned R2 but was changed to NC in the LUCE designation and R2 on districting. Rent-controlled units should be preserved so it should be changed to Low Density Residential land use designation.
d. 1922-1924 11th (behind 1021 and 1023 Pico – north). This is a cute little 1-story tileroof duplex being used for family day care and currently zoned R2. The LUCE Designation is correct at Low Density Residential. However, the districting was made GC. Family day care is a priority in the city and should be preserved, and the lot should be changed to R2 on the districting map.

3. Spot Zoning. These are egregious examples of illegal spot zoning.

Requested actions: A Resolution of Intention to change the LUCE Designation to NC and the Districting Map to NC.
5/4/25, 10:42 AM Yahoo Mail - City Council 6-23-15 Agenda Item 7A (LUCE Map) about:blank 1/2
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2056 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) a. 2410 Pico – This parcel (Rite Aid, Next Door by Josie, and Josie restaurant) is a single parcel zoned MUBL in the middle of many blocks of NC (19th to 31st) on the south side of Pico Blvd. Amanda Schachter says this is not spot zoning because there is MUBL “across the street.” First, allowing the designation across the street to justify spot zoning is a slippery slope that will result in increased commercialization in residential districts. There must be a border established at some point or the entire city would be MUBL. Second, now the parking lots behind have been correctly returned to R1, it is the only MUBL bordering R1 in the entire city. If this is not spot zoning, I don’t know what is. b. 1925 Pico – This single parcel (Burger King) is zoned MUBL in the middle of several blocks (17th to 21st) of NC and across the street from NC. This is spot zoning and should not be allowed.

4. Maintaining commercial designations on lots that continue to be residential use. There are significant residential uses on lots that are currently zoned commercial. However, in order to preserve affordable housing and landmark structures, these lots should be designated residential, consistent with their use. In some cases the districting was changed to R2, but land use designation remains commercial in all cases.

Requested actions: A Resolution of Intention to change the LUCE Designation from NC to Low Density Residential, and the Districting Map to become or remain R2. a. 2249 30th St. (behind 3010 Pico – south side – Der Wienerschnitzel) - This is a little row of 1-story bungalows adjacent to the Der Wienerschitzel parking lot. It is currently zoned C4 and was changed to NC under the LUCE. It should be changed to R2 to preserve rentcontrolled units. b. 1930 11th (behind 1021 and 1023 Pico – north side). This is a very old 1-story house, possibly a potential landmark or structure of merit. It is currently zoned C4 and was made GC on the LUCE designation and districting maps. However, it should be preserved and changed to residential.
c. 2683 34th (behind 3401 Ocean Park Blvd.). This is currently an apartment building and currently zoned C2. It was made NC on both the designation and districting maps.

However, rent-controlled units should be preserved so this should be changed to residential. d. 3401 Ocean Park Blvd. This is currently an apartment building. Rent-controlled units should be preserved.

We would also appreciate clarification that 2644 30th (the original Google building and large parking lot, behind the retail center on OPB) is R1. This lot appears to be all one APN. However it is R1 with a commercial building on part of it and a parking lot on the rest. Please confirm this is all single family LUCE Designation and R1 Districting.

Thank you for your thoughtful consideration.

Regards,
Nikki Kolhoff
2628 29th Street
[email protected]
5/4/25, 10:42 AM Yahoo Mail - City Council 6-23-15 Agenda Item 7A (LUCE Map) about:blank 2/2
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2057 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2058 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2059 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2060 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2061 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2062 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2063 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2064 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2065 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2066 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2067 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2068 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2069 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2070 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2071 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2072 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2073 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2074 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2075 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2076 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2077 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2078 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2079 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2080 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2081 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2082 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2083 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2084 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2085 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2086 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2087 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2088 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2089 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2090 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2091 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2092 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2093 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2094 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2095 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2096 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2097 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2098 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2099 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2100 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2101 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2102 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2103 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2104 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2105 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2106 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2107 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2108 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2109 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2110 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2111 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2112 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2113 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2114 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2115 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2116 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2117 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2118 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2119 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2120 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2121 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2122 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 10 David Yakobson
From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, May 13, 2025 12:05 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects.

Who is City Council serving if it gives our city away to this request? I urge you to retain an owneroccupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Nikki Kolhoff
Santa Monica Resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2123 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 11 David Yakobson
From: John Lin <[email protected]>
Sent: Tuesday, May 13, 2025 12:03 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
John Lin
90401
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2124 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 12 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

John Lin
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2125 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 13 David Yakobson
From: [email protected]
Sent: Tuesday, May 13, 2025 12:02 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A on 5/13/25 -- OPPOSE

EXTERNAL
Dear City Council Members,
Please do NOT support Agenda Item 12A on 5/13/25. Let’s not damage or ruin this city with this ill-conceived proposal.

Thank you,
Kirk & Nan Borcherding
residents
924 25th Street
Santa Monica
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2126 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 14 David Yakobson
From: Adam Gross <[email protected]>
Sent: Monday, May 12, 2025 11:02 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold OPPOSE

EXTERNAL
Dear City Council Members,
I object to eliminating public input on 1+ acre parcels. One acre is a huge amount of land in our city. If a project is designed well, and is fair to the community, it should get through the process easily. This change will only protect bad decisions and lead to mistrust.

Sincerely,
Adam Gross
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2127 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 15 David Yakobson
From: Adam Gross <[email protected]>
Sent: Monday, May 12, 2025 10:57 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE

EXTERNAL
Dear City Council Members,
As a resident and voter, I oppose eliminating the owner-occupancy requirement for splitting R1 zoned lots. This will make homes more unaffordable when families and buyers are forced to compete with developers. If this passes, the resulting luxury apartments will be too small and too expensive for families. By retaining the owner occupancy requirement, we allow parents to create housing for family members or community members.

I urge you to keep the owner-occupancy requirement that matches state law and will keep our neighborhoods from becoming luxury apartment blocks.

Thank you,
Adam Gross
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2128 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 16 David Yakobson
From: George Ferrell <[email protected]>
Sent: Monday, May 12, 2025 10:47 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members:

I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning.

Thank you,
Peggy Ferrell
338 15th ST
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2129 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 17 David Yakobson
From: George Ferrell <[email protected]>
Sent: Monday, May 12, 2025 10:46 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members:

I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning.

Thank you,
George Ferrell
338 15th St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2130 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 18 David Yakobson
From: George Ferrell <[email protected]>
Sent: Monday, May 12, 2025 10:44 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members: We object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Peggy Ferrell
George Ferrell
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2131 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 19 David Yakobson
From: George Ferrell <[email protected]>
Sent: Monday, May 12, 2025 10:41 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Barry Snell; [email protected] Subject: Eliminating Owner-occupancy Requirement

EXTERNAL
George Ferrell
From:[email protected]
To:[email protected]
Cc:[email protected],[email protected],[email protected],barry.snell @santamonica.gov,[email protected] 3 more...

Mon, May 12 at 10:30 PM
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members:

I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all singlefamily residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Peggy Ferrell
338 15th St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2132 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 20 David Yakobson
From: George Ferrell <[email protected]>
Sent: Monday, May 12, 2025 10:31 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members:

I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
George Ferrell
338 15th St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2133 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 21 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 10:23 PM
To: councilmtgitems; Barry Snell; Caroline Torosis; Dan Hall; Ellis Raskin; Jesse Zwick; Lana Negrete; Natalya Zernitskaya
Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: FOSP: 5/13 Council agenda item 12-A -- 3 concerns: 1-acre threshold - SB9 - 2644-30th Street

EXTERNAL
May 12, 2025
To: Mayor Negrete and Councilmembers

From: Board of Directors, Friends of Sunset Park

RE: 5/13/25 agenda item 12-A

The FOSP Board opposes the following 3 staff recommendations and urges the Council to remove them from the action item:

1) "Elimination of 1-acre Administrative Approval threshold for projects."

After the Gelson's project (551 apartments in 12 5- and 6-story buildings) was approved ministerially (Administrative Approval), the City Council passed an ordinance requiring Council approval for projects on parcels larger than 1 acre. (The Gelson's parcel is 4 acres.)

This ordinance, as written, undoes that earlier 0ordinance and would allow Administrative Approval of projects of any size, for example, in the 40-acre Santa Monica Business Park.

There are no public hearings with the Administrative Approval process, only at the Architectural Review Board.

Among the 500 residents participated in the Gelson's 2022 community Zoom call, very few people supported the project.

Imagine the uproar among residents if an even larger housing project went forward in the Business Park, with no public hearings and only Administrative Approval.

We urge you to maintain the 1-acre Administrative Approval threshold for housing projects.

********************************************************************

2) "Removing the owner-occupancy requirement for lots splits and duplexes." -- This would be an invitation to out-of-town and out-of-state developers to buy up single family homes and make huge profits by building multiple housing units on R-1 parcels. As was noted in a recent opinion piece in the Santa Monica Mirror:

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2134 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 22 "SB9, a statewide law, was designed to expand opportunities for families to create moderateincome housing for relatives and friends, and to build wealth from their R-1 parcels. The author of the state law said at the time the law was passed that SB9 was focused on homeowners, affordable housing units, and multigeneration wealth creation by building equity from splitting R-1 lots into two parcels. Real estate developers and speculators were never part of the SB9 law.
"The primary legislative tool to insure SB9 encouraged family development, not real estate speculation, is the owner occupancy requirement built into the SB9 law. That provision requires a homeowner to live in one of the newly built SB9 housing units as the homeowner’s principal residence for three years after approval of an SB9 lot split. According to the state Housing and Community Development (“HCD”) agency, owner occupancy also means that only a person who owns the lot, not a corporation, can use SB9’s streamlined city approval process. A corporate SB9 owner “cannot legitimately claim intentions of residing in one of the units as its principal residence since [corporations] do not physically reside anywhere.

Now, three City Councilmembers (Zwick, Zernitskaya, and Hall) propose to fundamentally change Santa Monica’s SB9 Ordinance, by “removing the owner-occupancy requirement for lot splits … and clarifying that vacant or demolished parcels… are eligible for lot splits…” Their resolution is currently on the City Council Agenda for the May 13, 2025, Council meeting. According to a Public Records Act request to the City, these two changes were recommended by Stephen Anderson, who is the corporate representative of the two SB9 developments in Santa Monica, proposed by Delaware corporations.

The Council should reject the suggested SB9 amendments. They are not good housing policy for the City and its residents. The amendments will instead allow out-of-state developers to build expensive multi-family units in R-1 zones. They will also boost the prospects of Mr.

Anderson’s corporate SB9 projects in Santa Monica...."
The FOSP Board urges you to maintain the owner-occupancy requirement for lots splits and duplexes.
***************************************************************************** 3) Amending the Zoning Ordinance to upzone 2644 30th Street to "Neighborhood Commercial."

2644 30th Street is not located right on Ocean Park Blvd. -- it's a 2-story office building and parking lot right behind the retail center with The Counter, Il Forno, Hurry Curry, and Crimson.

It's adjacent to and right across 29th and 30th Streets from single family homes.

Thanks to the 6th Cycle Housing Element, "Neighborhood Commercial" on Ocean Park Blvd. is allowed 55 feet in height. With the state density bonus, this could possibly increase a building on 2644 30th Street to 85 feet in height, adjacent to and right across the street from single family homes.

The property owner's attorney told the Planning Commission that this zoning change was necessary so her client could re-rent office space in the building after it was vacated for remodeling. If the property owner is indeed just trying to remodel the building, they can Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2135 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 23 already do so under the City's legal nonconforming use ordinance. The only thing they can't do is go bigger.

The FOSP Board urges you NOT to amend the Zoning Ordinance to upzone 2644 30th Street to "Neighborhood Commercial."

Thank you for your consideration.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2136 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 24 David Yakobson
From: Ralph Barton <[email protected]>
Sent: Monday, May 12, 2025 10:01 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A – 5/13/2025 - "End Owner Occupancy Requirement in SB9" - OPPOSE

EXTERNAL
Great land speculation opportunity for developers – are there EVER any good measures that are balanced or make any sense at all except to line the pockets of developers ? OPPOSE
Ralph Barton
908 26th St.

SM, CA
_______________________________
Ralph G. Barton, Jr. (Mobile) 310-633-4963 (Fax) 310-564-7577 Bring the Joy®
Nothing Bundt Cakes
Manhattan Beach,CA – Torrance,CA - Costa Mesa,CA – Mission Viejo,CA Roseville,CA – Folsom,CA - Newton,MA
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2137 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 25 David Yakobson
From: Robyn Rosenbach <[email protected]>
Sent: Monday, May 12, 2025 9:43 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I am a resident and business owner in the City. I currently live on 30th Street, about 100 feet from the property at 2644 30th Street which is the subject of this Item.

I strongly object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. As you all should know, there is not a single building in the neighborhood which approaches 85 feet in height, and that includes the Santa Monica Business Park which is across the street.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85-foot building.
2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Robyn Rosenbach

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2138 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 26 David Yakobson
From: barbanell <[email protected]>
Sent: Monday, May 12, 2025 9:37 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5-13-25 SM City Council Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE

EXTERNAL
Council Members:

Oppose the removal of the owner occupancy requirement in SB 9. Protects our neighborhoods from land speculators—keep the owner occupancy requirement ASIS!
2) Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE Staff is recommending that the City Council vote to remove the SB9 owner occupancy requirement that was added to SB9 in order to help it pass in the State legislature. Now our own City Council is being encouraged by City staff to remove the owner-occupancy requirement. The owner occupancy requirement in SB9 was meant to encourage multi-generational housing. Removing it will open up neighborhoods to land speculators.

Below is the proposed revision that appears on page 256 of the attached Staff Report.

Thank you.

Sincerely,
Stephanie Barbanell— 40 year resident of Santa Monica
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2139 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 27 David Yakobson
From: Jim Lipschultz <[email protected]>
Sent: Monday, May 12, 2025 9:37 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I am a resident and business owner in the City. I currently live on 30th Street, about 100 feet from the property at 2644 30th Street which is the subject of this Item.

I strongly object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. As you all should know, there is not a single building in the neighborhood which approaches 85 feet in height, and that includes the Santa Monica Business Park which is across the street.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85-foot building.

This is way too tall for the interior of a residential street! A limitation of 2 stories would be consistent with the neighborhood.
2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Jim Lipschultz
Law Ofϐice of James D. Lipschultz,
a Professional Corporation
tel: 310.820.3311 x203
[email protected]
This e-mail message is conϐidential, intended only for the named recipient(s) above and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you have received this message in error, or are not the named recipient(s), please immediately notify the sender at 310-820-3311 and delete this e-mail message from your computer. Thank you.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2140 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 28 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2141 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 29 David Yakobson
From: Ed Cheung <[email protected]>
Sent: Monday, May 12, 2025 9:25 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: Please Vote NO on Agenda Item 12A Protect Our Neighborhood and Public Voice

EXTERNAL
Dear Mayor and City Councilmembers,
I am writing as a concerned Santa Monica resident to respectfully urge you to vote NO on all five proposals included in Agenda Item 12A 5/13/2025. These proposals would have a lasting and detrimental impact on the character, safety, and livability of our community.

Here’s why I strongly oppose Agenda Item 12A:

1. SB 79 – Overdevelopment Without Oversight
Allowing apartment and condo towers up to 15 stories tall within a 1⁄2 mile of any transit stop, including an ever-growing number of bus stops, would invite unchecked overdevelopment, congestion and safety issues. This bill prioritizes developers over residents and undermines local control.

2. Eliminating the Owner-Occupancy Requirement for Lot Splits This change would accelerate speculative real estate activity in single-family neighborhoods, eroding community stability and transforming residential areas into zones apartment zones.

3. Removing Public Input on Commercial Development
Removing the requirement for council votes and public comment on commercial projects would silence the voices of residents and remove critical transparency from the development process.

Decisions that impact the future of our city should never be made behind closed doors.

4. Upzoning 1331 Wilshire and 2644 30th Street
These proposals set a dangerous precedent for out-of-scale development in sensitive areas.

Upzoning without community input disregards the values and concerns of surrounding residents.

5. Reducing Public Speaking Time at Council Meetings
Limiting residents’ ability to speak and removing time donations further diminishes public participation in our democracy. Santa Monica deserves more transparency and engagement, not less.

6. It is deeply troubling that every member of this City Council has accepted campaign contributions from developers and aƯiliated political action committees. This represents a serious conflict of interest and may constitute a violation of the Fair Political Practices Commission’s (FPPC) Pay-to-Play restrictions. Furthermore, the lack of transparency in how these proposals are being advanced raises legitimate concerns about potential Brown Act violations. Santa Monica residents will not stand by! We will demand full accountability and ensure these matters are thoroughly investigated by the appropriate oversight authorities.

Each of these proposals benefits large developers, not the everyday residents who live, work, and raise families in Santa Monica. We are facing serious challenges in public safety, infrastructure, and aƯordability handing over our city to speculative interests will only worsen these problems.

Please stand with the residents of Santa Monica, not special interests. Vote NO on Agenda Item 12A.

Sincerely,
Ed Cheung
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2142 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 30 David Yakobson
From: Dannie Charney <[email protected]>
Sent: Monday, May 12, 2025 9:24 PM
To: councilmtgitems
Subject: Fwd: AGENDA ITEM 12A. OPPOSE -OWNER OCCUPANCY MUST STAY

EXTERNAL
---------- Forwarded message ---------
From: Dannie Charney <[email protected]>
Date: Mon, May 12, 2025 at 9:18 PM
Subject: Re: AGENDA ITEM 12A. OPPOSE -OWNER OCCUPANCY MUST STAY To: Council Mailbox <[email protected]>, <[email protected]> Cc: <[email protected]>, lana.negrete <[email protected]>, Ellis Raskin <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, Jesse Zwick <[email protected]>
On Mon, May 12, 2025 at 9:09 PM Dannie Charney <[email protected]> wrote:

OWNERS MUST STAY TO ALLOW SB9
WHAT ARE YOU THINKING TO ALLOW THIS?
Stop land speculation here - my god you have
done everything wrong so far.. do not allow this
Every thing Weiner comes up with must be defeated..
do not removed this requirement
'
Stop destroying every last bit of protection left..

A vote for this means you should not be on the Council
Danielle Charney
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2143 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 31 David Yakobson
From: Dannie Charney <[email protected]>
Sent: Monday, May 12, 2025 9:19 PM
To: Council Mailbox; councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Re: AGENDA ITEM 12A. OPPOSE -OWNER OCCUPANCY MUST STAY

EXTERNAL
On Mon, May 12, 2025 at 9:09 PM Dannie Charney <[email protected]> wrote:

OWNERS MUST STAY TO ALLOW SB9
WHAT ARE YOU THINKING TO ALLOW THIS?
Stop land speculation here - my god you have
done everything wrong so far.. do not allow this
Every thing Weiner comes up with must be defeated..
do not removed this requirement
'
Stop destroying every last bit of protection left..

A vote for this means you should not be on the Council
Danielle Charney
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2144 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 32 David Yakobson
From: Bea Nemlaha <[email protected]>
Sent: Monday, May 12, 2025 9:13 PM
To: councilmtgitems
Subject: 5/13/25 Agenda 12A - End Owner Occupancy Requirement in SB9 - OPPOSE

EXTERNAL
Council,
This proposal has the possibility of turning virtually every Santa Monica land owner into a land speculator whose only interest is his/her bottom line. Can’t we as a community do better than that?
NO ON SB9 elimination of owner occupancy requirement.

Bea Nemlaha
Ocean Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2145 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 33 David Yakobson
From: Nikki Kolhoff <[email protected]>
Sent: Monday, May 12, 2025 8:28 PM
To: councilmtgitems; Lana Negrete; Caroline Torosis; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Dan Hall; Jesse Zwick
Cc: Friendsofsunsetpark Info; Dan Kolhoff
Subject: May 13, 2025 City Council Meeting – Item 12A, Nos. 6 & 7 Upzoning of 2644 30th Street - OPPOSE
Attachments: 2025-05-12 Comment Opposing Upzoning of 2644 30th St.pdf

EXTERNAL
Dear Mayor Negrete and City Council –
Please see the attached comment in opposition of the illegal spot upzoning of 2644 30th Street. Please vote NO on both the Resolution to Amend the LUCE Map and the Resolution to Amend the Zoning Map.

Regards,
Nikki and Dan Kolhoff
Sunset Park Residents and Santa Monica Voters
Attachment
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2146 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 34 David Yakobson
From: William Schoene <[email protected]>
Sent: Monday, May 12, 2025 8:08 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, We object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
William and Mary Lou Schoene
1519 Oak Street
Santa Monica 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2147 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 35 David Yakobson
From: Karen Freedman <[email protected]>
Sent: Monday, May 12, 2025 8:08 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda item 12A, 5/13/25- OPPOSE

EXTERNAL
Please accept this email as an official declaration of my opposition to Agenda Item 12A. I want my opposition included in the official record.

Thank you,
Karen Freedman
Santa Monica 90402
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2148 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 36 David Yakobson
From: Stacey Ravel Abarbanel <[email protected]>
Sent: Monday, May 12, 2025 8:07 PM
To: councilmtgitems
Subject: OPPOSE Agenda Item 4J and Agenda Item 12A

EXTERNAL
Dear City Council:

I write to urgently request you oppose Agenda Item 4J and Agenda Item 12A.

As you know, Agenda Item 4J would direct the City Manager to draft a letter expressing the City’s support for SB 79 (Wiener). As a longtime resident of Santa Monica I DO NOT support such action.

Please allow Santa Monica to meet housing needs in ways that are appropriate to our city. A state-wide, one-size-fits all approach will devastate Santa Monica, where the city's population density is already significantly higher than the national average. As you know, a substantial proportion of our city's land is occupied by high-density housing, including apartments, condos, and other multi-family dwellings. And we're building more, which I support, as well as permitting ADU's in formerly single-family areas! But when people, often families, have invested their life savings to live in a lower-density area, we should not put their choice and investment at risk of having an apartment building next door where once only a similar lower-density home was allowed. Note that in Santa Monica, SB 79 will only spare a few areas, including North of Montana. It’s another “rich get richer” scenario where elites benefit and everyone else suffers.

Agenda Item 12A would end the owner occupancy requirement in SB9. What a bait-and-switch that would be to folks who supported SB9 to improve opportunities for multi-generational families to live together! It’s nothing more than a gift to developers, who already flout so many of our well-intentioned and well thought out building codes (including front fence heights not to code and attached “ADU’s" built with false walls ready to break down to add square footage to the main house), negatively altering our community in the process. Please DO NOT remove the residency requirement that was designed to prevent more speculation by developers and the destruction of older homes that are often the affordable choice that young families seek.

We can and are meeting housing needs without destroying our residential choices in the process. Thank you.

Stacey Ravel Abarbanel
1039 Harvard Street
Santa Monica CA 90403
[email protected]
310/736-5300
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2149 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 37 David Yakobson
From: William Schoene <[email protected]>
Sent: Monday, May 12, 2025 8:06 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, We object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
William and Mary Lou Schoene
1519 Oak Street
Santa Monica 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2150 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 38 David Yakobson
From: Vivien Flitton <[email protected]>
Sent: Monday, May 12, 2025 8:03 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A – End Owner Occupancy Requirement in SB9 - OPPOSE

EXTERNAL
Sincerely,
Vivien Flitton
Santa Monica Resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2151 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 39 David Yakobson
From: Rachel Harms <[email protected]>
Sent: Monday, May 12, 2025 8:02 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: Agenda Item 12A 5/13/25 – End Owner Occupancy Requirement in SB9 – OPPOSE

EXTERNAL
Dear Santa Monica City Council Members
I am a 30 year resident of Santa Monica, having lived here continuously first as a renter and then an owner. The owner occupancy requirement in SB9 was meant to encourage multi-generational housing. Removing it will open up neighborhoods to land speculators.

I oppose ending the owner occupancy requirement in SB9 and I urge you to do the same.

Sincerely,
Rachel Harms
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2152 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) From: Paula Larmore
To: councilmtgitems; Lana Negrete; Jesse Zwick; Caroline Torosis; Ellis Raskin; Natalya Zernitskaya; Dan Hall; Barry Snell
Cc: Ross Fehrman; Rachel Kwok; Jing Yeo; Armine Chaparyan Subject: Agenda Item 12.A: Support the LUCE and Zoning Change for 2644 30th Street Commercial Office Building Date: Monday, May 12, 2025 7:44:54 PM
Attachments: 2644 30th Street Zone and LUCE Change.pdf
Exhibit 1 - 2644 30th Street Comparison of Prior vs New Zoning.pdf Exhibit 2 - Excerpts from CC SR 2014.04.14.pdf
Exhibit 3 - Resolution No. 15-007 (PCS) w.highlight.pdf Exhibit 4 - Excerpt CC Resolution 10874 (Amend LUCE).pdf

EXTERNAL
"ôÍŘϙ
ĺŪIJèĖīıôıæôŘŜϠ
IϙÍıϙſŘĖťĖIJČϙĺIJϙæôēÍīċϙĺċϙťēôϙĺſIJôŘϙĺċϙ͕͓͓͑ϙ͒͏ťēϙ‹ťŘôôťϙťĺϙŘôŗŪôŜťϙƅĺŪŘϙÍŕŕŘĺŽÍīϙĺċϙťēôϙ[˜ (
ÍIJîϙ¾ĺIJĖIJČϙîôŜĖČIJÍťĖĺIJϙèēÍIJČôŜϙċĺŘϙťēôϙŕĺŘťĖĺIJϙĺċϙťēĖŜϙŕŘĺŕôŘťƅϙĖıŕŘĺŽôîϙſĖťēϙÍϙèĺııôŘèĖÍī æŪĖīîĖIJČϙϼÍŕŕŘĺƄϟϙ͐͗Ϡ͏͏͏ϙŜċϽϙťĺϙbôĖČēæĺŘēĺĺîϙ
ĺııôŘèĖÍīϙÍŜϙŘôèĺııôIJîôîϙæƅϙ
Ėťƅϙ‹ťÍċċϙÍIJî
ťēôϙ„īÍIJIJĖIJČϙ
ĺııĖŜŜĖĺIJϟϙ“ēĖŜϙèēÍIJČôϙĖŜϙèĺIJŜĖŜťôIJťϙſĖťēϙťēôϙŕŘĺŕôŘťƅЍŜϙīĺIJČϱŜťÍIJîĖIJČϙŪŜôϙÍŜϙÍ èĺııôŘèĖÍīϙæŪĖīîĖIJČϙÍIJîϙŕŘĖĺŘϙèĺııôŘèĖÍīϙƏĺIJĖIJČϟϙ‹ôôϙÍťťÍèēôîϙ„">ϙèīÍŘĖċƅĖIJČϙťēÍťϡ “ēôϙŕŘĺŕĺŜôîϙèēÍIJČôϙĖŜϙĺIJīƅϙċĺŘϙťēôϙīĺťŜϙèŪŘŘôIJťīƅϙĖıŕŘĺŽôîϙſĖťēϙťēôϙèĺııôŘèĖÍīϙæŪĖīîĖIJČ ϼťĺťÍīĖIJČϙÍŕŕŘĺƄϟϟϙ͐͗Ϡ͏͏͏ϙŜċϽϟ
bĺϙèēÍIJČôϙĖŜϙŕŘĺŕĺŜôîϙċĺŘϙťēôϙīĺťŜϙſĖťēϙťēôϙŜŪŘċÍèôϙŕÍŘħĖIJČϟϙ“ēôŜôϙīĺťŜϙťĺťÍīĖIJČϙ͕͒Ϡ͏͏͏ϙŜċ ſĖīīϙŘôıÍĖIJϙ‡͐ϙϼŜĖIJČīôϱċÍıĖīƅϙŘôŜĖîôIJťĖÍīϽϟ
“ēôϙĺſIJôŘϙŕŪŘèēÍŜôîϙťēôϙŕŘĺŕôŘťƅϙĖIJϙťēôϙ͐͗͘͏ŜϠϙſēôIJϙťēôϙèĺııôŘèĖÍīϙæŪĖīîĖIJČϙſÍŜϙƏĺIJôî èĺııôŘèĖÍīϙϼ
͑ϽϙÍIJîϙÍϙŽÍŘĖôťƅϙĺċϙèĺııôŘèĖÍīϙŪŜôŜϙſôŘôϙŕôŘıĖťťôîϙſĖťēĖIJϙťēôϙæŪĖīîĖIJČϟϙ“ēô ĺſIJôŘЍŜϙČĺÍīϙÍIJîϙċĺèŪŜϙſÍŜϙÍIJîϙèĺIJťĖIJŪôŜϙťĺϙæôϙĺIJϙīĺIJČϱťôŘıϙŽĖÍæĖīĖťƅϙĺċϙťēôϙèĺııôŘèĖÍī æŪĖīîĖIJČϟϙIIJϙīĖČēťϙĺċϙŜēĖċťŜϙĖIJϙèĺııôŘèĖÍīϙĺċċĖèôϙŜŕÍèôϙIJôôîŜϠϙċīôƄĖæĖīĖťƅϙÍIJîϙťēôϙÍæĖīĖťƅϙťĺϙīôÍŜôϙťēô æŪĖīîĖIJČϙťĺϙÍϙŽÍŘĖôťƅϙĺċϙĺċċĖèôϙŪŜôŜϙĖŜϙèŘĖťĖèÍīϟ
“ēôϙĺſIJôŘϙĺIJīƅϙīôÍŘIJôîϙťēÍťϙťēôϙôƄĖŜťĖIJČϙæŪĖīîĖIJČϙēÍîϙæôôIJϙŘôƏĺIJôîϙċŘĺıϙèĺııôŘèĖÍīϙťĺϙ‡͐ ŘôèôIJťīƅϠϙÍċťôŘϙÍŕŕŘĺÍèēĖIJČϙťēôϙ
ĖťƅϙťĺϙċĖČŪŘôϙĺŪťϙÍīīĺſôîϙŪŜôŜϙċĺŘϙťēôϙæŪĖīîĖIJČϙŪŕĺIJϙÍIJϙŪŕèĺıĖIJČ ťôIJÍIJťϙŽÍèÍIJèƅϟϙ˜IJîôŘϙťēôϙ‡͐ϙŜĖIJČīôϱċÍıĖīƅϙƏĺIJĖIJČϙîĖŜťŘĖèťϙīÍIJîϙŪŜôϙŘôČŪīÍťĖĺIJŜϠϙťēôŘôϙÍŘôϙIJĺ ŕôŘıĖťťôîϙèĺııôŘèĖÍīϙŪŜôŜϟϙ“ēŪŜϠϙťēôϙôƄĖŜťĖIJČϙèĺııôŘèĖÍīϙŪŜôŜϙſĖťēĖIJϙťēôϙæŪĖīîĖIJČϙÍŘôϙIJĺſ èĺIJŜĖîôŘôîϙīôČÍīϠϙIJĺIJèĺIJċĺŘıĖIJČϙÍIJîϙŘôϱťôIJÍIJťĖIJČϙÍIJîϙèēÍIJČôŜϙĺċϙŪŜôϙÍŘôϙôƄťŘôıôīƅϙīĖıĖťôîϟ aĺŘôĺŽôŘϠϙťēôϙÍæÍIJîĺIJıôIJťϙŕŘĺŽĖŜĖĺIJŜϙċĺŘϙīôČÍīϠϙIJĺIJèĺIJċĺŘıĖIJČϙŪŜôŜϙèŘôÍťôϙŜĖČIJĖċĖèÍIJťϙŘĖŜħŜϙċĺŘ ťēôϙŕŘĺŕôŘťƅϙĺſIJôŘϟϙŜϙîôťÍĖīôîϙæôīĺſϠϙťēôϙŕŘĖĺŘϙƏĺIJôϙèēÍIJČôϙϼċŘĺıϙ ͑ϙťĺϙ‡͐ϽϙÍŕŕôÍŘŜϙťĺϙēÍŽô
æôôIJϙĖIJÍîŽôŘťôIJťϙÍIJîϙIJôĖťēôŘϙťēôϙ„īÍIJIJĖIJČϙ
ĺııĖŜŜĖĺIJϙIJĺŘϙťēôϙ
ĺŪIJèĖīϙſôŘôϙIJĺťĖċĖôîϙĺċϙťēĖŜ
èēÍIJČôϙæôċĺŘôϙŽĺťĖIJČϙĺIJϙťēôϙèŪŘŘôIJťϙ[˜
(ϙÍIJîϙ¾ĺIJĖIJČϙıÍŕŜϙϼÍīťēĺŪČēϙťēôƅϙſôŘôϙŕŘôŜôIJťôîϙſĖťēϙÍ
īĖŜťϙĺċϙĺťēôŘϙŕŘĺŕôŘťĖôŜϙĖIJϙÍϙŜĖıĖīÍŘϙŜĖťŪÍťĖĺIJϽϟϙ“ēôϙĺſIJôŘϙĖŜϙŘôŜŕôèťċŪīīƅϙŘôŗŪôŜťĖIJČϙťēÍťϙťēôϙŕĺŘťĖĺIJ ĺċϙťēôϙŕŘĺŕôŘťƅϙĺèèŪŕĖôîϙæƅϙťēôϙèĺııôŘèĖÍīϙæŪĖīîĖIJČϙæôϙŘôϱƏĺIJôîϙæÍèħϙťĺϙèĺııôŘèĖÍīϙϼb Ͻ
èĺIJŜĖŜťôIJťϙſĖťēϙťēôϙIJôĖČēæĺŘĖIJČϙèĺııôŘèĖÍīϙŕŘĺŕôŘťƅϙťĺϙťēôϙŜĺŪťēϟ FôŘôϙĖŜϙÍϙċŪŘťēôŘϙĺŪťīĖIJôϙĺċϙťēôϙĖŜŜŪôϡ
͐ϟ (ƄĖŜťĖIJČϙ
ĺIJîĖťĖĺIJŜϙϱϙ“ēôϙ„ŘĺŕôŘťƅϙèĺIJŜĖŜťŜϙĺċϡϙϟ
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2153 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) a. Approximately 18,000 square feet of land that is improved with a commercial office building (“Building Lots”).
b. Approximately 36,000 square feet of land that is improved with surface parking (“Parking Lots”).
c. The entire Property (both Building Lots and Parking Lots) is currently zoned R1 with LUCE designation of “Single Family Housing”.

2. Existing Land Use Regulation – Single-Family (R1) vs. Neighborhood Commercial a. R1 zone – There are no permitted commercial uses. Therefore, the existing uses are designated as “legal, nonconforming uses”.

Legal, nonconforming uses may be maintained but they cannot be changed to any other use other than a conforming use (and there are no permitted commercial uses). Thus, when the current tenants move out, their suites can only be reoccupied with the same type of commercial use (postproduction) and not for other office or similar uses. This is very limiting/restrictive.

Moreover, the abandonment provisions for legal, nonconforming uses create significant risks for the property owner. If the tenant “goes dark” or leaves early unexpectedly, the property owner will be at risk of losing the grandparented rights for the commercial use.
b. NC zone – There are a variety of permitted commercial uses within existing buildings including Business & Professional Office and Creative Office.

3. The Property’s Zoning / LUCE History
a. The Property has a long history of commercial zoning and use – in 1984 LUCE and 1988 Zoning the Property was designated C2.
b. In 2010, the Property’s LUCE designation was changed from C2 to “Single Family Housing”.
· There is no evidence this change was intentional.
c. Until 2015, the Property was zoned C2.
d. In 2015, the City updated its zoning Citywide to be consistent with 2010 LUCE. · As explained below, during the 2015 Zoning Map update process City Staff attempted to identify all parcels that had inconsistent 2010 LUCE designations relative to their then-existing/pre-2015 zoning designations and provided the list of these parcels to the Planning Commission and City Council. The Property was missed during this identification process and not included on the lists presented to the Planning Commission or the City Council. As such, neither the Planning Commission nor the City Council were notified of the inconsistency for this Property before voting on the map with the R1 zoning for this property.
· The Property owner was also not notified before either the LUCE or Zoning maps were changed.
· Given that the line between commercially-zoned and residentially-zoned property along Ocean Park Boulevard varies (as it does along all boulevards), it is understandable that the inconsistency was inadvertently missed. See Exhibit 1 attached.

4. LUCE/Zoning Ordinance Map Changes Background
a. During Zoning Ordinance update process in 2014/2015, inconsistencies between the then-existing/pre-2010 LUCE zoning and the new LUCE zoning were identified.

Initially the focus was on properties that had been changed from residential to commercial but, after community feedback, City Staff attempted to conduct a Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2154 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Please feel free to reach out to me if you have any questions. Thank you for your consideration.

Paula
Paula J. Larmore | Attorney at Law
1250 Sixth Street, Suite 200 | Santa Monica, CA 90401
O: (310) 656-4311 | [email protected]
NOTICE OF DISTRIBUTION: This e-mail message contains information that may be confidential and privileged. Unless you are the addressee (or authorized to receive messages for the addressee), you may not use, copy or disclose this message (or any information contained in it) to anyone. If you have received this message in error, please advise the sender by reply e-mail and delete this message. Nothing in this message should be interpreted as a digital or electronic signature that can be used to authenticate a contract or other legal document. a comprehensive list of inconsistent parcels. An April 14, 2014, City Council Staff Report to the City Council (attached as Exhibit 2) states in relevant part:
“During the public review process and in the course of analyzing the boundaries of the newly created zoning districts, inconsistencies between the adopted LUCE Land Use Designation Map and the existing Official Districting Map were identified. As a result, staff compared the LUCE Map with the existing Official Districting Map for all 23,500 parcels in the City, to generate a listing of inconsistent parcels.” (emphasis added.) b. As a result of the effort above, a list of 115 parcels with inconsistent was prepared and reviewed by the Planning Commission and City Council. 19 of the parcels on the list were zoned commercial/industrial and used with commercial/industrial uses but had been given a residential LUCE designation. [See Resolution No. 15-007 (PCS) attached as Exhibit 3.] • 2644 30th Street was missed/not included on the list of parcels with inconsistent zoning and LUCE designations. At that time, it was zoned C2 but the 2010 LUCE designation was Single Family Housing. See Exhibit 1.
c. On May 5, 2015 Council adopted Resolution No. 10874 (CCS) (attached as Exhibit 4) amending the LUCE including the LUCE map. The amendments to the LUCE map included changing the LUCE designation from residential to commercial for then-identified parcels that had commercial zoning and were in commercial use. At the time of voting on the Resolution, Council had been informed that staff had provided a comprehensive list of all of the parcels with inconsistent zoning and 2010 LUCE designations. One of the recitals to Resolution No. 10874 (CCS) states:
“WHEREAS, staff has compared the LUCE Map with the existing Official Districting Map for all 23,500 parcels in the City, to generate a listing of inconsistent parcels;” (City Council Resolution No. 10874 (CCS), page 12.)
• 2644 30th Street was again missed/not included on the list of parcels with inconsistent zoning and LUCE designations.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2155 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Proposed Change
18,000 sf lots with commercial building →
Neighborhood Commercial (NC)
designation
36,000 sf lots with surface parking →retain
R1 (Single Family Zoning) designation (no
change)
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2156 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1984 LUCE 1988 Zoning
(pre-2015 Zoning)
2010/Current LUCE 2015/Current Zoning
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2157 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) City Council Meeting: April 14, 2015
Agenda Item: 4-A
To: Mayor and City Council
From: David Martin, Director, Planning and Community Development Subject: Study Session on the Draft Zoning Ordinance, Proposed Land Use and Circulation Element Amendments, Draft Official Districting Map, and Draft LUCE Land Use Designation Map Amendments
Recommended Action
Staff recommends that the City Council review, comment, and provide direction on the following:
1) Draft Zoning Ordinance;
2) Proposed Land Use and Circulation Element (“LUCE”) Amendments; 3) Draft LUCE Land Use Designation Map Amendments;
4) Appeals of Planning Commission Denials of Specified LUCE and Designation Map Amendments;
5) Draft Official Districting Map; and
6) Negative Declaration.

Staff further recommends that Council direct staff to return on May 5, 2015 with a Zoning Ordinance for 1st reading, LUCE amendments, LUCE Land Use Map amendments, and the Official Districting Map.

Executive Summary
Since December 2013, the City has been engaged in an extensive public review process to update the City’s current Zoning Ordinance and related land use chapters of Article 9 of the Santa Monica Municipal Code. This process has involved 33 Planning Commission public hearings, including a Town Hall meeting, to review and discuss the Draft Zoning Ordinance, potential LUCE amendments, potential LUCE Land Use Designation Map amendments, the proposed Official Districting Map, and the environmental analysis for this project.

This report provides background on this sixteen month process and then focuses principally on those issues which generated significant community discourse throughout these proceedings and which, in many instances, continue to elicit strongly-held, diverging opinions. These issues are being presented to Council for further discussion and to facilitate consensus on the Ordinance recommendations.

These issues include:
8/27/24, 10:31 AM City of Santa Monica - Study Session on the Draft Zoning Ordinance, Proposed Land Use and Circulation Element Amendments, … https://www.smgov.net/departments/council/agendas/2015/20150414/s2015041404-A.htm 1/42 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2158 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) exception to authorize Tier 3 height for City-Designated Landmarks and Structures of Merit.

The Planning Commission recommended these LUCE amendments on March 18, 2015.

Other Potential Amendments
One of the potential amendments that the Planning Commission also included in the Resolution of Intention adopted on November 5, 2014 would have authorized market rate housing through a discretionary review process in the Industrial Conservation and Office Campus Districts. Currently the LUCE does not allow residential development in the Industrial Conservation District except for one hundred percent affordable housing in limited areas. It is unclear whether the LUCE authorizes any housing in the Office Campus District. This limited allowance for housing in the IC land use designation raised legal issues. More specifically, concerns were raised that only authorizing the provision of affordable housing may run afoul of Costa Hawkins, Civil Code Section 1954.50 et. seq., and to address this concern, market rate housing should also be permitted in these districts. However, upon further analysis, it was determined that allowing market rate housing in these employment districts could trigger the need for additional environmental analysis, which could not be undertaken in a timely fashion. Consequently, to address the potential Costa Hawkins issue the Planning Commission did not move forward with this potential LUCE amendment.

Instead, the issue will revisited at a later time after further analysis and review.

Consequently, the Draft Zoning Ordinance does not authorize one hundred percent affordable housing or market rate housing in these two districts.

Draft LUCE Land Use Designation Map (Attachment I)
A City-wide Land Use Designation Map was adopted as part of the adoption of the LUCE on July 6, 2010. During the public review process and in the course of analyzing the boundaries of the newly created zoning districts, inconsistencies between the adopted LUCE Land Use Designation Map and the existing Official Districting Map were identified. As a result, staff compared the LUCE Map with the existing Official Districting Map for all 23,500 parcels in the City, to generate a listing of inconsistent parcels. The Planning Commission reviewed these inconsistent parcels in detail on June 18, 2014 and October 1, 2014.

Exhibit A of Attachment K 3 is a table that lists the parcels in the City whose LUCE land use designations have been identified as being inconsistent with their existing 8/27/24, 10:31 AM City of Santa Monica - Study Session on the Draft Zoning Ordinance, Proposed Land Use and Circulation Element Amendments, … https://www.smgov.net/departments/council/agendas/2015/20150414/s2015041404-A.htm 33/42 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2159 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) zoning and uses as well as with adjacent parcels. The parcels are listed in the table with their address, existing zoning, existing LUCE designation, and the Planning Commission’s recommendation as to what the appropriate LUCE designation should be for the parcels. This list contains 115 parcels.

The majority of these inconsistent parcels, #1-84 on Exhibit A of Attachment K 3, are parcels in the City whose land use designations were changed to a commercial designation with the adoption of the LUCE Land Use Designation Map and are now inconsistent with their predominantly residential zoning or partial residential zoning.

As shown in Exhibit A of Attachment K 3, the recommendation is for these LUCE commercial land use designations to be changed back to LUCE residential land use designations to make them consistent with the existing residential zoning of these parcels. The remainder of these inconsistent parcels, #85-115 on Exhibit A of Attachment K 3, includes parcels in the City whose LUCE land use designations are inconsistent with their existing commercial and industrial zoning and uses as well as with adjacent parcels.

Of the 115 parcels, the Planning Commission recommended retaining the existing commercial land use designation of three parcels:
1127 2nd St (#5 on Exhibit A of Attachment K 3)
1129 2nd St (#6 on Exhibit A of Attachment K 3)
1137 2nd St (#7 on Exhibit A of Attachment K 3)
These parcels are currently zoned R3 (Medium Density Multiple Family Residential), with the southern end of 1137 2nd Street also zoned C3 (Downtown Commercial). The residential portions of these parcels also contain “A” overlay designations and are currently used for surface parking and a small office building. All three parcels, however, are currently designated Downtown Core under the existing LUCE land use designation map, are commercially used, and are within the boundaries of the pending Downtown Specific Plan area. As the LUCE provides that the specific uses, height, FAR, and development standards for buildings and uses within the Downtown Core will be addressed by a Specific Plan, the Planning Commission voted not to 8/27/24, 10:31 AM City of Santa Monica - Study Session on the Draft Zoning Ordinance, Proposed Land Use and Circulation Element Amendments, … https://www.smgov.net/departments/council/agendas/2015/20150414/s2015041404-A.htm 34/42 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2160 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) recommend that these parcels be changed and would retain their LUCE commercial land use designation. Commissioner Kennedy appealed this action.

A significant amount of public correspondence has been received regarding 1801 Wilshire Boulevard (#90 on Exhibit A of Attachment K 3). Although the entire parcel is currently zoned C6 (Boulevard Commercial) and is currently occupied by multi-story commercial and office buildings with multi-level parking, the existing LUCE Land Use Designation Map identified the rear of the parcel as Low Density Housing. The Commission’s recommendation is to change the rear portion of the parcel to a MixedUse Boulevard (MUB) LUCE land use designation to provide consistency with the existing MUB designation of the majority of the parcel, the existing zoning of the entire parcel, and the existing commercial, office, and parking uses on the parcel. No existing residential uses would be included in this LUCE land use designation correction at 1801 Wilshire Boulevard.

A draft Official Districting Map (Attachment H) is attached that corresponds to the Draft LUCE Land Use Designation Map.

Additional Issues
In addition to the issues discussed above that were the subject of robust discussion and debate, several other issues were identified and resulted in revisions that resolved the concerns that were raised.

Residential Uses on Commercial Parcels Adjacent to Residential Districts or Active Commercial- Section 9.21.200
This revision addresses situations where residential uses are located within commercial districts. Specifically, if a commercial parcel immediately adjacent to a residential district has only been residentially used since July 10, 2010, any redevelopment of a commercial parcel adjacent to this parcel, shall be designed in accordance with the development standards (minimum setbacks and daylight plane) as if the development were occurring next to a residential zoned parcel. Essentially, this provision protects residentially used parcels from having a zero setback when an adjacent commercially zoned parcel redevelops. It also extends to the adjoining parcel deeper into the commercial zoning if it is also residentially used. 8/27/24, 10:31 AM City of Santa Monica - Study Session on the Draft Zoning Ordinance, Proposed Land Use and Circulation Element Amendments, … https://www.smgov.net/departments/council/agendas/2015/20150414/s2015041404-A.htm 35/42 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2161 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2162
Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2163
Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2164
Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2165
Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2166
Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2167
Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2168 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2169 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) :..UCE Map Changes
I Page Address Street APN Existing Zoning Approved LUCE Designation , LUJ:;E Designation Change I Number , 79 1421 23RD ST 4275005010 R3 I MUBL Change back to Medium Density Hsg ' 80 12311 SCHAOE.R DR 427S005068 R3 MUBL Change back to Medium Density Hsg 81 12428 SANTA MONICA BLVD 4275003016 C4/R2 I MUBL Change back to Low Density Hsg 8� !2505 SANTA MONICA BLVD 4276021054 R2A I MUBL Change back to Low Density Hsg 83 850 PALISADES BEACH RD 4292031018 R2S OF Change back to Low Density Hsg

3.1. ,8S0 PALISADES BEACH RD 4292031905 R2B OF Change back to Low Density Hsg ' 85 11337 12TH ST 4282014016 C4 jMedium Density Housing Change to General Commercial I 86 2001 BROADWAY 4275008808 CP3-C4 jHealthcare Mixed Use/MUBL Change to MUBL for entire parcel I 37 1418 19TH ST 4275010004 C4 Low Density Housing Change. to General Commercial 38 1560 12TH ST 4282031030 Ml jMUBL/Medium Density Housing Change·to MUBL for entire parcel 89 1519 COLORADO-AVE 4282035010 Ml Low Density Housing/MUBL Change to MUBL for entire parcel 90 1801 WILSHIRE BLVD 4276009036 C6 Low Density Housing/MUB Change to MUB for entire parcel �- \2602. MAINS1 4288002902 CM2-0P2 1Low Density Housing Change to lnsitutional/Public lands :,_ 32 1::.s.6.: 15TH ST 4282035014 M: Low Density Housing Change to MUBL I -- ,:.547 15 IH SI 4282035013 iv11 . Lo•..v Density Housing Change to MUBL :IL 11548 18TH ST 4275012011 M'.:. 1 Low Density Housing Change to MUBL :i-�:l J1547 16TH ST 4282036015 M: I Low Denslty Houslng Change to MUBL I 96 715 CALIFORNIA AVE. 4292003028 R2 1
·nstitutional/?ublic lands .Change to Low Density Housing 97 1030 LINCOLN BLVD 4292003027 R2 Institutional/Public Lands Change to Low Density Housing 98 701 PICO BLVD 4290004013 C4 Medium Density Housing • Change to MUBL 95 12019 14TH ST 4284034014 Rl I Low Density Housing Change to Single Family Housing lCO )1550 jEUCLID ST 4282032010 Ml I Medium Density Housing Change to MUBL 10: !1534 \20TH ST 4275014003 LMSD Low Density Housing Change to MUBL - ,, _
_ .J.! 1544 20TH ST 4275014005 . I Lfv15J 'Low Densitv Housing Change to MUBL :03 11538 20TH ST 4275014004 -1 LMSC LJv✓ Densi:y Housing Change to MUBL ,_ 1C4 11528 20TH ST 4275014002 I LMSD Lc-w Der,sity Housing Change to MUBL 105 12515 EUCLID ST 4284025002 I R1-,i3 Medi1.Jm Density Housing Change to Single Family Housing I 106 J1547 18TH ST 4275013014 I Ml Low Density Housing Change to MUBLl 107 J1547 19TH ST 4275014009 Ml Low Density Housing ·
Change to MUBL
j 108 1212 BAY ST 4289018002 CM2 Low Density Housing Change to NC I 109 12101 OCEAN PARK BLVD 4273016900 I R3 Medium Density Housing Change to lnsitutional/Puolic Lands ! 110 1704 MONTANA AVE 42.77008900 i'l.2 Low Density Housing Change to lnsitutional/P.ublic Lands· l .. .. ,1 1847 114TH ST 4283031907 I R2 1 Parks and Open Space Change to lnsitutional/Public Lands ! 112 1847 i14TH ST 4283033917 I R.2 ?ar!<s and Open Space Change to lnsitutional/Public Lands �13 1847 /14TH ST 4283033918 I �2 I Parks 3nd Open Space Change to lnsitutional/Public Lands 'lL 11847 !14TH ST I 4283033916 I °'2 \Perks and Open 5paca Change to lnsitutional/Public Lands ·15 !18d7 14TH ST I 4283031900 I C4-R2 ?:;rl:s and Open Soaca Change to lnsitutional/Public Lands Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2170 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) WHEREAS, as detailed in the June 18,2014 Planning Commission staff report and Apri114, 2015 City Council staff report, approximately 89 parcels on the LUCE Land Use Designation Map were changed from their previous residential designation to a commercial designation; and
WHEREAS, parcels with these designation changes were generally located adjacent to the following commercial boulevards: Montana Avenue, Wilshire Boulevard, Santa Monica Boulevard, Colorado Avenue, Ocean Park Boulevard, Pico Boulevard, Lincoln Boulevard, and Main Street; and
WHEREAS, these designation changes were made for a variety of reasons including making the land use designation consistent with an existing commercial use, accommodating the LUCE activity centers, or creating commercial parcels that could more easily accommodate mixed use projects envisioned in the LUCE for the boulevards; and WHEREAS, the Zoning Ordinance Update process has provided an opportunity to reassess the appropriateness of the land use designation changes that were approved as part of the LUCE; and
WHEREAS, staff has compared the LUCE Map with the existing Official Districting Map for all 23,500 parcels in the City, to generate a listing of inconsistent parcels; and WHEREAS, the City has a long history of creating and maintaining buffers between commercial and residential neighborhoods; and
WHEREAS, participants in the LUCE adoption process identified neighborhood preservation as the highest priority of the planning process; and WHEREAS, a key goal of the LUCE includes maintaining an appropriate town-scale and balanced growth while encouraging certain types of development; and 12 Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2171 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 51 David Yakobson
From: William Schoene <[email protected]>
Sent: Monday, May 12, 2025 7:35 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, We object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. If the owner of a lot to be split is not required to keep living on the lot for 3 years, as required by current state law, then most houses on the market will get snapped up by real estate developers for converting them into maximally-profitable multi-unit housing. And since market rate units are more profitable, none of this new housing would be affordable. There are already over 5000 vacant market rate units in Santa Monica; where is the demand for more market rate units from lot splits? Why allow the deliberate densification of single-unit neighborhoods for a nonexistent housing demand?
We live in a single-unit neighborhood and certainly would not wish to live next to a maximally-developed split lot.

And you would be hard pressed to find any other Santa Monican (or Southern Californian, for that matter) living in a single-unit neighborhood who feels differently.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers, who would easily outbid buyers who wished to live in the existing house.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is the City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
WIlliam and Mary Lou Schoene
1519 Oak Street
Santa Monica 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2172 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 52 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 7:20 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: AGENDA ITEM 12A-End Owner Accompany Requirement in SB9- 5/13/25 - OPPOSE

EXTERNAL
We need more Police and a SubStation in the Promenade, not an Entertainment Zone.

AGENDA ITEM 4J-Support Letter from SM for SB 70 5/13/25 - OPPOSE AGENDA ITEM 12A-End Owner Accompany Requirement in SB9- 5/13/25 - OPPOSE AGENDA ITEM 10A-Promenade Entertainment Zone - 5/13/25 - OPPOSE AGENDA ITEM 4K Public Input Rules 5/13/25 - OPPOSE
30 Year SM Resident and Homeowner
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2173 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 53 David Yakobson
From: Heather Thomason <[email protected]>
Sent: Monday, May 12, 2025 6:49 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- Oppose

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I respectfully object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Thank you for your service, I know that this job is not easy, and you have many competing demands to balance.

But please oppose this upzoning.

Thank you,
Heather Thomason
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2174 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 54 David Yakobson
From: Tracey Hom <[email protected]>
Sent: Monday, May 12, 2025 6:45 PM
To: Council Mailbox; Santa Monica City Manager's Office; councilmtgitems; Dan Hall; Natalya Zernitskaya; Caroline Torosis; Ellis Raskin; [email protected]; Lana Negrete; Barry Snell
Subject: agenda items 12 a. 6 & 7

EXTERNAL
RE: MAY 13, 2025 CITY COUNCIL MEETING – ITEM 12A, 6 & 7 UPZONING OF 2644 30TH STREET – THE RESIDENTS OF 2638 29TH STREET OPPOSE
Dear City Council –
We object to the change of land use and rezoning of 2644 30th Street. We object to you voting on something where you have based your opinion on false information. It is shocking to me that smart people would listen to Harding Larmore without checking the statements included in their documentation .For once, do the right thing for your constituents, not an unknown developer. Approval will greatly negatively impact all of the residents on 29th and 30th streets.

Either the staff did not want to spend the time researching this issue and blindly took Harding Larmore at their word or they blatantly misrepresented the facts for reasons only they know. If the staff lied to council, action must be taken to prevent this from happening again. I was willing to give staff the benefit of the doubt, but the more I have dug into this the more culpable they are. They have misrepresented the facts, the recorded documents, previous minutes, deeds of trust and actions taken at council meetings. Residential owners and renters who purchased their homes or moved to the neighborhood in reliance on current zoning will be harmed. It’s not ok to force residents to suffer commercial encroachment into their residential neighborhood just so a developer can make more money and the City can get additional tax dollars. This is precisely what the LUCE is supposed to protect us against.

NUMBER 1 THIS IS ILLEGAL SPOT UPZONING AN AREA NOT ON THE BOULEVARD.

1. Neighborhood Commercial was intended to be on the boulevards. This is an interior lot. It is approximately 200 feet north of the boulevard.

2. LUCE doesn’t even speak to or address interior parcels. A review of the City’s GIS maps shows that nowhere else in the city is the NC designation applied to an interior parcel to bring commercial use into the residential neighborhood beyond the depth of the other NC parcels on the boulevards. This would be the ONLY one in the entire city, and is further evidence of spot zoning.It is an illegal spot-zoning misrepresented in the staff report as a clerical error. It would upzone the parcel in a manner that results in a MASSIVE windfall for the owner, and negative impacts on the residential neighbors. There are 30 R1 homes on 29th and 34 R1 homes on 30th street. Staff claims that this change was requested by owner’s counsel in September 2024. However, there has been no outreach to the neighborhood by the owner or city staff and city staff have adopted the owner’s position even though THIS POSITION IS NOT supported by the public record. ALL STAFF WOULD HAVE Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2175 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 55 HAD TO DO IS ACTUALLY REVIEW THE PUBLIC RECORD. The staff report contains numerous inaccurate and misleading statements, and the upzoning presents issues not addressed in the staff report. We did not get notice until March 2025.

NUMBER 2. INACCURATE AND MISLEADING STATEMENTS IN THE STAFF REPORT 2644 30th Street is a single tax parcel that has existed since 1956, almost 70 years, as a 2- story office building (the “Office Building”) on one portion and a surface parking lot (the “Parking Lot”) on the other portion. This is the last standing building of Douglas Aircraft. It has been owned by the same Beverly Hills family since 1987, almost 38 years. No one hires Harding Larmore at $1000 per hour if they do not either intend to sell or develop the property.

1. THE LUCE DESIGNATION WAS NOT AN ERROR. Staff repeats many times in the staff report and resolutions that both the 2010 LUCE designation and 2015 Zoning were “mapping errors” that were inadvertent. THIS IS FALSE. The Parking Lot has always been R1 and the Office Building was originally C2. When the LUCE was updated in 2010, it expressly stated that commercial activity should be on the boulevards, while preserving the residential neighborhoods. Because this parcel is not on a boulevard, it was designated Single Family Residential.

The LUCE described Sunset Park as follows: “Sunset Park maintains its semi-suburban character and continues to provide distinct single and multi-family housing opportunities. New or rehabilitated development, particularly on the adjacent boulevards is sensitive to the scale and mass of existing structures and with the surrounding neighborhood context. Character-defining features, like mature street trees, are preserved to perpetuate the quality of Sunset Park’s outdoor environment. Traffic congestion and parking issues— especially as they relate to Santa Monica College—are mitigated by a mixture of transportation and parking demand management programs to reduce the impact of cutthrough traffic and parking shortages. The mixture of neighborhood-serving amenities near residential areas along Pico and Ocean Park Boulevards features a range of retail, dining and entertainment options and is easily accessible by foot, bicycle or car.” (LUCE-Page 2.2-29) The LUCE created NEW land use designations to conform to the stated intentions of the LUCE, and that is why Neighborhood Commercial is on the boulevards and Residential is interior. 2644 30th is NOT on the boulevard so it was entirely consistent with the goals of the LUCE and the existing R1 zoning, to assign it a LUCE designation of Single Family Residential. This wasn’t a mistake or a mismatch. No other parcel was assigned Neighborhood Commercial that extended beyond the strip of parcels along the boulevards.

These additional LUCE provisions further confirm that commercial development is supposed to be on the boulevards and not in the residential neighborhood:
• “The highest priority of the community was the preservation of the existing character and scale of Santa Monica’s neighborhoods.” (LUCE-Page 3) • “The [2010] LUCE is different from the policy direction of the 1984 LUCE: It is a conservation plan that provides for an overall reduction in building height.” (LUCE-Page 5)
• Land Use 2.2 -- NEIGHBORHOOD CONSERVATION -- "Renters and homeowners alike advocate for neighborhood conservation so that future generations may enjoy the same benefits and experiences." (LUCE-Page 2.2-3)
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2176 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 56 Upzoning this parcel does not preserve the existing character or scale of the neighborhood. When combined with the lot adjacent on the Ocean park blvd (the Starbucks, counter and Crimson lot). You might as well just allow it to be a shopping mall because that is what is going to happen. When we bought our home in 1992, our lot and the surrounding area was R1. I would not have purchased a home across from a lot that could quadruple in size. When the owner purchased the property they were charged with knowing what they were buying. We will have more traffic, more noise, no place to park, more dirt from car fumes and a more dangerous street.

2. The Zoning Designation was an NOT AN Error. Counsel and staff contend that the Luce designation was carried through to the zoning in error. As stated above, the LUCE designation of Single Family Residential was purposeful and the zoning of R1 was consistent with the LUCE. Furthermore, Friends of Sunset Park commented about this parcel on the record at both city council meetings, as well as a meeting with the City Manager, during the 2015 Zoning Ordinance Update to confirm the residential designation and zoning of this parcel.

The Parking Lot has always been R1 and the Office Building was formerly C2. After the SPECIFIC designation of Residential in the LUCE, the zoning of R1 was consistent. As a result, there was no mismatch between the LUCE and the Zoning.

This is a completely different situation from the baskets of inconsistencies referenced in multiple staff reports in 2015, which included the A-Lot scandal where staff upzoned residential parcels adjacent to the boulevards to commercial in an effort to increase the size of lots for commercial development along the boulevards.

Ten years later, owner’s counsel and city staff are now mischaracterizing what was reviewed in 2014- 15 by claiming staff failed to catch a difference between the use and the “new” LUCE and zone. What was actually reviewed in 2014-15 were lots that had a prior zoning designation of residential, which staff changed to commercial in the LUCE, and then wanted to change the zone to “conform” to the erroneous LUCE designation. Staff disingenuously characterized this as clerical at the time, but residents pushed back and demonstrated that the LUCE designation of commercial was inappropriate and must be reverted.

The resolution at the May 5, 2015 City Council meeting stated:
“WHEREAS, the Zoning Ordinance Update process has provided an opportunity to reassess the appropriateness of the land use designation changes that were approved as part of the LUCE; and
WHEREAS, staff has compared the LUCE Map with the existing Official Districting Map for all 23,500 parcels in the City, to generate a listing of inconsistent parcels; and WHEREAS, the City has a long history of creating and maintaining buffers between commercial and residential neighborhoods; and
WHEREAS, participants in the LUCE adoption process identified neighborhood preservation as the highest priority of the planning process; and
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2177 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 57 WHEREAS, a key goal of the LUCE includes maintaining an appropriate town-scale and balanced growth while encouraging certain types of development; and WHEREAS, this goal focuses on the retention of neighborhood character, development that is welldesigned and consistent with the desired neighborhood scale, preservation of older buildings, and adaptive reuse of historic properties; and
WHEREAS, it is appropriate that the vast majority of the parcels that were designated commercial be restored to a residential designation since such modification would be consistent with the overarching LUCE policy of preserving and protecting existing
neighborhoods against the potential impacts related to development: traffic, noise, air quality, and encroachment of commercial activities; and WHEREAS, by retaining the residential zoning and land use designations, these parcels can redevelop, but the development potential for these parcels will be limited to what the residential districts permit;”

In other words, staff had unilaterally upzoned 115 parcels and almost all of them were reverted to residential. 2644 30th Street was correctly designated Residential and R1, consistent with the LUCE, so there was no inconsistency to correct.

3. THE STAFF REPORT STATING THAT THE UPZONING ONLY APPLIES TO THE OFFICE BUILDING IS A BLATANT LIE. Owner’s counsel and staff claim that the upzoning only applies to the Office Building, but the RESOLUTIONS APPLY TO THE ENTIRE PARCEL, which is very concerning and also calls into question the legality of the vote taken by the Planning Commission in support of the resolutions.

At the Planning Commission hearing in March 2025, both the staff report and the resolutions referred to upzoning the entire parcel to Neighborhood Commercial for both LUCE and Zoning purposes.

However, in the Planning Commission meeting, both owner’s counsel and city staff made the false verbal assurance to the Commissioners that the upzoning applied only to the Office Building. STAFF DID NOT AMEND THE RESOLUTIONS. Now, two months later at City Council, the staff report FALSELY states, “The subject portion of the parcel is currently designated as Single Family Housing and zoned R1 (Single-Unit Residential), but since 1956 has been developed as a commercial office building.” However, both resolutions again reference the entire parcel, which includes the Parking Lot as well as the Office Building. The staff report materially misrepresents what City Council is being asked to approve. These staff members should be able to harm homeowners by either their false statements or their lack of taking the steps necessary to make sure their reports are correct.

4. STAFF AND HARDING LARMORE STATE THE NONCONFORMING USE IS PREVENTING THE OWNER FROM OBTAINING NEW TENANT. THIS IS COMPLETELY FALSE. Staff claims in email that the owner can’t lease to a new tenant. This is not true, so long as the use (office Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2178 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 58 building) doesn’t change, because Santa Monica has a legal nonconforming use ordinance that protects the owner so it can continue existing uses.

We can state under oath that since we have lived at 2638 29th Street, The owner’s have leased the property at least 20 different tenants beginning with google and now the newest tenant Done and Dusted. The statements by Harding Laramore are false and should lead the council to ask themselves if they lied about this what else are they lying about. The owner can lease it to any office tenant it wants. As long as the building has been there, tenants have come and gone and it is always occupied.

Chapter 9.27 of the Santa Monica Code is called “Nonconforming Uses and Structures” and its purpose is to “provide for the continuation of uses, continued occupancy and maintenance of structures, and development of parcels that were lawfully established but do not now comply with all of the standards and requirements of this Ordinance so long as the uses, continued occupancy, and maintenance meet the provisions of this Chapter.” Section 9.27.020 of the Santa Monica Code states that a “lawful nonconforming use” as “an occupancy or activity that was established in compliance with the standards and requirements in effect at the time it is commenced and has not been abandoned withing the same structure or on the same parcel since that date but does not comply with all of the applicable provisions of this Ordinance including, but not limited to, permitted use, location, intensity, operational characteristics, performance standards or hours of operation.” The Office Building is a legal nonconforming use. It is under no threat because it remains in an R1 zone. It is no different from any other legal nonconforming use in the city.

One should also ask themselves why is the staff perpetuating the false limitation and information. In an email staff said, “This was brought to our attention by the property owner when they were exploring re-tenanting of office space that had become vacant for more than a year and discovered that no commercial uses would be allowed.” Staff knows this is not the case and should have advised the owner. Instead, the staff has embarked on unnecessarily changing the LUCE and the zoning at the behest of Harding Larmore. If staff’s position here is to be taken seriously, then every multi-tenant building would face abandonment when a single space isn’t filled and that can hardly be the legal result. I asked staff what specific use is being prevented, or what specific plans are being thwarted, by the current zoning of the parcel and staff did not respond.

The owner’s counsel claims it is limited in change of use, and while that is true, it is true for every owner of a nonconforming use in the city of Santa Monica. This property is no different and deserves no special treatment. Not only is this NOT the purview of staff to change zoning for an owner to do something they shouldn’t, but it is evidence of spot-zoning to benefit this owner or a developer. (See Code Section 9.27 attached.)

5. THE NONCONFORMING USE IS PREVENTING THE OWNER FROM RENOVATING. THIS IS A FALSE STATEMENT. The staff report claims, “This has created a nonconforming condition and impediments to future development … for the current structure.” This is not true because Santa Monica has a legal nonconforming use ordinance that protects the owner so it can remodel or renovate without “abandoning” existing uses.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2179 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 59 As stated above, the Office Building and Parking lot are lawful nonconforming uses. Section

9.27.050.3 of the Santa Monica Code states, “Cessation of use due to remodeling shall not be considered abandonment so long as building permits are active in accordance with Chapter 8.08 of the Municipal Code. However, if the building permit expires before the use resumes, the one-year period under subsection (B)(1) shall relate back and commence with the cessation of use.”

THE OWNER HAS RENOVATED THE BUILDING SEVERAL TIMES IN THE LAST THIRTY YEARS. We have seen it all.

6. THE MOST EGREGIOUS FALSE STATEMENT IS THAT THE NONCONFORMING USE IS PREVENTING THE OWNER FROM GETTING FINANCING. The staff report claims, “This has created a nonconforming condition and impediments to financing for the current structure.” This is not true because the owner most recently financed the property in 2019 under the current LUCE and zoning designations.

In 2019, the owner granted two Deeds of Trust to First Republic, one for $6,227,000 and another for $2,000,000, for a total of $8,227,000 in financing. At the time of that financing, a commercial lender would have performed due diligence to confirm that the zoning and use supported the appraised value on which the loan was based. Those deeds of trust were assigned to JPMorgan Chase in 2024 and continue to encumber the property. This is further evidence that either the staff was lazy or is making false statements.

Tracey Hom and Lenny Hom
2638 29th Street
Santa Monica, CA 90405
Tracey P. Hom Esq.
10850 Wilshire Blvd. Suite 825
Los Angeles, California 90024
310 749 5343
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2180 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 60 David Yakobson
From: Heather Thomason <[email protected]>
Sent: Monday, May 12, 2025 6:37 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- Oppose

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I am concerned about and must respectfully object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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.

This could mean the entire Business Park area, or even the Santa Monica Airport could be developed without any public input.

The amendment as currently written entails a far-reaching change to our zoning, which leaves too much of the development of our city purely to staff discretion. Please allow the public to be able to weigh in on massive projects before they are approved -- it's the democratic way to do things! Thank you so much,
Heather Thomason
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2181 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 61 David Yakobson
From: Frank J Gruber <[email protected]>
Sent: Monday, May 12, 2025 6:37 PM
To: councilmtgitems
Subject: Item 12 on the May 13 agenda - changes to housing laws

EXTERNAL
Dear City Council,
I’m writing to support the staff report to bring the City’s zoning into compliance with state laws to reduce unnecessary delays in approvals of new housing, including with respect to ADUs and lot splits. In commercial zones I agree with eliminating the cap on administrative approvals currently at one acre. (Of course, approvals have be consistent with the allowed building standards under both local zoning and state law.) I’m pleased to see that staff is recommending return to standards in the LUCE that were reduced by zoning after the adoption of the LUCE.

I’m not going to opine on the various policy questions in the staff report — I assume you’ll make the best decisions.

However, I would like to make one suggestion that goes beyond staff’s recommendations, which means that you probably can’t vote on it at this meeting. But perhaps you can ask for analysis. My suggestion is to increase allowed heights to three stories in R1 and R2 zones (and in the equivalent OP zones). This would be not only for apartments, but also for townhomes. As one who passed his formative years in Philadelphia, a city of rowhouses, a three-story townhome can provide much more “home” to a family or other household. Three stories can also allow for more larger setbacks and landscaping while providing enough square feet of housing.

Thanks, and keep up the good work,
Frank Gruber
Ocean Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2182 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 62 David Yakobson
From: Leslie Neale <[email protected]>
Sent: Monday, May 12, 2025 6:30 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Leslie Neale
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2183 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 63 David Yakobson
From: Leslie Neale <[email protected]>
Sent: Monday, May 12, 2025 6:29 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects!
This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! Sant Monica is too small a community for the public not to have a say! The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you,
Leslie Neale
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2184 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 64 David Yakobson
From: Heather Thomason <[email protected]>
Sent: Monday, May 12, 2025 6:22 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I respectfully object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to an inevitable land rush by market-rate developers who will have to maximize their investments by building the maximum number of luxury units possible on the land.

Market-rate units are not the answer to the housing affordability problem our city faces.

Adopting this ordinance will lead to the destruction of our beloved Santa Monica neighborhoods, especially those with older homes in them, which happen to be some of our currently most affordable and diverse neighborhoods. Removing the owner occupancy requirement will raise the cost of land and will put home ownership in our city even farther out of reach for so many.

This ordinance is not serving our residents. It's not making Santa Monica more affordable.

The Planning Commission who reviewed this recommended against adopting it because, among other reasons, they said that they did not believe that this would move the needle on affordability in our city.

Moreover, current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Proceeding with this ordinance will open Santa Monica up to lawsuits, because the state requirement is not an optional provision. It is a requirement. It seems that Santa Monica will be in defiance of the requirement if it goes ahead with this ordinance.

And lastly, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you for your service, and for listening to your constituents.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2185 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 65 Sincerely,
Heather Thomason
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2186 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 66 David Yakobson
From: Michael Etzel <[email protected]>
Sent: Monday, May 12, 2025 6:18 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Michael Etzel
90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2187 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 67 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2188 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Ann Hoover <[email protected]>
Sent: Monday, May 12, 2025 4:37 PM
To: councilmtgitems; Lana Negrete; Caroline Torosis; [email protected]; Ellis Raskin; Dan Hall; Barry Snell; Natalya Zernitskaya
Cc: Elaine Polachek; Susan Cline; Douglas Sloan; Susan Cola; Jing Yeo; Heather Averick; Armine Chaparyan; Heidi von Tongeln; Nikima Newsome
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members - I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard.

Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE.

Please oppose this upzoning.

Thank you,
Ann Bowman
Resident, 28+ years
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2189 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Ann Hoover <[email protected]>
Sent: Monday, May 12, 2025 4:31 PM
To: councilmtgitems; Lana Negrete; Caroline Torosis; Jesse Zwick; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Dan Hall
Cc: Elaine Polachek; Susan Cline; Douglas Sloan; Susan Cola; Nikima Newsome; Armine Chaparyan; Heather Averick; Heidi von Tongeln; Jing Yeo Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor Pro-Tem Torosis, and City Council Members - I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers, which will have the effect of RAISING prices, not incentivizing the creation of more housing that is affordable.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects.

Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Ann Bowman
Resident, 28+ years
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2190 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Ann Hoover <[email protected]>
Sent: Monday, May 12, 2025 4:34 PM
To: councilmtgitems; Lana Negrete; Caroline Torosis; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Ellis Raskin; Barry Snell
Cc: Elaine Polachek; Susan Cline; Douglas Sloan; Susan Cola; Heidi von Tongeln; Jing Yeo; Armine Chaparyan; Nikima Newsome; Heather Averick
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor Pro-Tem Torosis, and City Council Members - I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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.

This could mean parcels as big as the entire Business Park area! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Ann Bowman
Resident, 28+ years
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2191 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Gail Gordon <[email protected]>
Sent: Monday, May 12, 2025 4:28 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Gail Gordon
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2192 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 David Yakobson
From: Barbara Fuchs <[email protected]>
Sent: Monday, May 12, 2025 4:07 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Barbara Fuchs
90403
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval.

Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2193 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 6 Adjustment to Section 9.55.120 on the Architectural Review Board:

Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing.

Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.
--
Barbara Fuchs
Distinguished Professor of Spanish and English
Director, Diversifying the Classics
https://urldefense.com/v3/__http://diversifyingtheclassics.humanities.ucla.edu/__;!!OfuUnHCITYtmmjM!upEyV2d 2kUR1mngrZIZW2prMA8kKvxgQ4K_Ijvxyvr5eTc6RxMfs0Vhu8VJmSJGcIRm8adnLXw7q_N12vMy4M7w5nFQ0DoKeGs$ Articles Editor, Renaissance Quarterly
5320 Rolfe Hall
University of California
Los Angeles, CA 90095-1530
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2194 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 7 David Yakobson
From: Ann Murphy <[email protected]>
Sent: Monday, May 12, 2025 3:56 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate public commentary on commercial development.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Ann Murphy
Homeowner
2419 31st St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2195 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 8 David Yakobson
From: Yollanda Ziff <[email protected]>
Sent: Monday, May 12, 2025 3:49 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: Items 12.A.6&7

EXTERNAL
Hello,
I have been living in Santa Monica, residing at 2625 30th street since April of 1987. My late husband and I have built our family home here, and raised our two children at this address.

The reason we chose the neighborhood, and this particular location was that it was a quiet and pleasant street, where we could walk to the various local small businesses and restaurants, walk our kids to their elementary school, and feel that our family was safe in our enjoyment of the small town atmosphere.

We were not unique in assessing our neighborhood vibe: all of our friends and acquaintances who live on our street appreciated the same things about our homes' location.

We have fought hard in past years to prevent any changes that might disrupt our quiet enjoyment and our lifestyle, by creating additional traffic and noise.

These were relatively small changes that were proposed, such as opening a driveway into the shopping center at the corner of 30th and Ocean Park, that would allow supply trucks to drive onto our street. Therefore, the proposed project at 2644 30th street is UNIMAGINABLE!
The creation of such a structure would bring traffic, noise, street closures, crime, and a number of residents and consumers that our small street just CANNOT handle! The construction alone, that in this day and age would take several years, would be incredibly disruptive: imagine the cranes, dump and mixer trucks, the workers' vehicles, etc., on a street where just our garbage pick-up trucks block the smooth flow of traffic when they come by once a week! In addition, please consider what this project would do to our property values, both during and after the completion of the project. I am sure that I speak for all my neighbors when I say that our homes are our biggest asset and nest egg.

Personally, being a retiree who is watching the erosion of my savings, and the threat to my Social Security benefit, I cannot even describe the harm to my wellbeing and my livelihood caused by the possible decrease in value of my home.

Please DO NOT APPROVE THIS PROJECT!!! Thank you.

Sincerely,
Yollanda Inghel Ziff
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2196 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Elizabeth Van Denburgh <[email protected]>
Sent: Monday, May 12, 2025 3:57 PM
To: Barry Snell; Caroline Torosis; Jesse Zwick; Dan Hall; Natalya Zernitskaya; Lana Negrete; Ellis Raskin; councilmtgitems
Subject: City Council Meeting - 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is the City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Respectfully,
Elizabeth Van Denburgh
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2197 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Yollanda Ziff <[email protected]>
Sent: Monday, May 12, 2025 3:49 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: Items 12.A.6&7

EXTERNAL
Hello,
I have been living in Santa Monica, residing at 2625 30th street since April of 1987. My late husband and I have built our family home here, and raised our two children at this address.

The reason we chose the neighborhood, and this particular location was that it was a quiet and pleasant street, where we could walk to the various local small businesses and restaurants, walk our kids to their elementary school, and feel that our family was safe in our enjoyment of the small town atmosphere.

We were not unique in assessing our neighborhood vibe: all of our friends and acquaintances who live on our street appreciated the same things about our homes' location.

We have fought hard in past years to prevent any changes that might disrupt our quiet enjoyment and our lifestyle, by creating additional traffic and noise.

These were relatively small changes that were proposed, such as opening a driveway into the shopping center at the corner of 30th and Ocean Park, that would allow supply trucks to drive onto our street. Therefore, the proposed project at 2644 30th street is UNIMAGINABLE!
The creation of such a structure would bring traffic, noise, street closures, crime, and a number of residents and consumers that our small street just CANNOT handle! The construction alone, that in this day and age would take several years, would be incredibly disruptive: imagine the cranes, dump and mixer trucks, the workers' vehicles, etc., on a street where just our garbage pick-up trucks block the smooth flow of traffic when they come by once a week! In addition, please consider what this project would do to our property values, both during and after the completion of the project. I am sure that I speak for all my neighbors when I say that our homes are our biggest asset and nest egg.

Personally, being a retiree who is watching the erosion of my savings, and the threat to my Social Security benefit, I cannot even describe the harm to my wellbeing and my livelihood caused by the possible decrease in value of my home.

Please DO NOT APPROVE THIS PROJECT!!! Thank you.

Sincerely,
Yollanda Inghel Ziff
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2198 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Ann Murphy <[email protected]>
Sent: Monday, May 12, 2025 3:56 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate public commentary on commercial development.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Ann Murphy
Homeowner
2419 31st St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2199 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Elizabeth Van Denburgh <[email protected]>
Sent: Monday, May 12, 2025 3:30 PM
To: Lana Negrete; Barry Snell; Ellis Raskin; Caroline Torosis; Jesse Zwick; Natalya Zernitskaya; Dan Hall; councilmtgitems
Subject: City Council Meeting 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's more transparent and the way good government should be handled..

Respectfully,
Elizabeth Van Denburgh
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2200 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Tatiana Khmilinina <[email protected]>
Sent: Monday, May 12, 2025 3:21 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: Please Vote NO on Agenda Item 12A Protect Our Neighborhood and Public Voice

EXTERNAL
Dear Mayor and City Councilmembers,
I am writing as a concerned Santa Monica resident to respectfully urge you to vote NO on all five proposals included in Agenda Item 12A 5/13/2025. These proposals would have a lasting and detrimental impact on the character, safety, and livability of our community.

Here’s why I strongly oppose Agenda Item 12A:

1. SB 79 – Overdevelopment Without Oversight
Allowing apartment and condo towers up to 15 stories tall within a 1⁄2 mile of any transit stop, including an ever-growing number of bus stops, would invite unchecked overdevelopment, congestion and safety issues. This bill prioritizes developers over residents and undermines local control.

2. Eliminating the Owner-Occupancy Requirement for Lot Splits This change would accelerate speculative real estate activity in single-family neighborhoods, eroding community stability and transforming residential areas into zones apartment zones.

3. Removing Public Input on Commercial Development
Removing the requirement for council votes and public comment on commercial projects would silence the voices of residents and remove critical transparency from the development process. Decisions that impact the future of our city should never be made behind closed doors.

4. Upzoning 1331 Wilshire and 2644 30th Street
These proposals set a dangerous precedent for out-of-scale development in sensitive areas. Upzoning without community input disregards the values and concerns of surrounding residents.

5. Reducing Public Speaking Time at Council Meetings
Limiting residents’ ability to speak and removing time donations further diminishes public participation in our democracy. Santa Monica deserves more transparency and engagement, not less.

6. It is deeply troubling that every member of this City Council has accepted campaign contributions from developers and affiliated political action committees. This represents a serious conflict of interest and may constitute a violation of the Fair Political Practices Commission’s (FPPC) Pay-to-Play restrictions. Furthermore, the lack of transparency in how these proposals are being advanced raises legitimate concerns about potential Brown Act violations. Santa Monica residents will not stand by! We will demand full accountability and ensure these matters are thoroughly investigated by the appropriate Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2201 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 oversight authorities.

Each of these proposals benefits large developers, not the everyday residents who live, work, and raise families in Santa Monica. We are facing serious challenges in public safety, infrastructure, and affordability handing over our city to speculative interests will only worsen these problems.

Please stand with the residents of Santa Monica, not special interests. Vote NO on Agenda Item 12A.

Sincerely,
Tatiana Khmilinina
1325 Arizona Ave #202
Santa Monica CA 90404
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2202 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Nick Taranto <[email protected]>
Sent: Monday, May 12, 2025 3:18 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Support for Item 12A and Consent Calendar Item J – Housing and Transit-Oriented Development

EXTERNAL
Dear Mayor Negrete and Santa Monica City Council members, As a member of Abundant Santa Monica, I am writing to express strong support for Item 12A on the May 13th agenda, as well as Consent Calendar Item J.

Item 12A includes important updates to Santa Monica’s housing ordinances that will promote muchneeded housing production while aligning with state law. I urge you to approve these updates, including:

Legalizing duplexes and lot splits in single-family neighborhoods under SB9, and removing unnecessary owner occupancy requirements that limit the law’s effectiveness Supporting the creation of ADUs across residential zones Expanding streamlined approvals to larger housing projects Replacing parcel coverage rules with Floor Area Ratio (FAR) for residential zoning Clarifying what constitutes a meeting of the Architectural Review Board These reforms will help reduce barriers to housing, modernize our zoning code, and support a more inclusive Santa Monica.

I also support Consent Calendar Item J, which directs city staff to send a letter of support for SB 79. This important state legislation would promote transit-oriented development statewide—helping communities like ours meet housing goals, reduce vehicle dependence, and make better use of our transit infrastructure.

Please vote in favor of both Item 12A and Consent Calendar Item J to keep Santa Monica moving toward a more abundant, equitable, and sustainable future.

Sincerely,
Nick Taranto
Abundant Santa Monica Member
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2203 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 David Yakobson
From: Matias Fuchs-Lynch <[email protected]>
Sent: Monday, May 12, 2025 3:17 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Additionally, I would ask that the council push for more relaxed zoning laws around transit stations, and in particular the expo line. Easily built housing and retail space around our transit systems is what will bring people to Santa Monica, to live, work, and spend money. More building will lower rents for housing, but also on commercial spaces, allowing local small businesses to get in business and stay in business. Too many of Santa Monica’s small businesses have been forced out of operation by high rents. The Santa Monica City Council must take action to make it easy to invest in and thrive in Santa Monica.

Thank you,
Matias Fuchs Lynch
90403
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2204 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 6 LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2205 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 7 David Yakobson
From: Carter Rubin <[email protected]>
Sent: Monday, May 12, 2025 3:00 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
As a 15-year resident, and someone whose lived in Santa Monica as a renter and homeowner, I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Carter Rubin
Pico Neighborhood Resident
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2206 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 8 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Best,
Carter
310-200-1088
(Sent while mobile)
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2207 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 9 David Yakobson
From: Gail Gordon <[email protected]>
Sent: Monday, May 12, 2025 2:54 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Gail Gordon
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2208 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 10 David Yakobson
From: Gail Gordon <[email protected]>
Sent: Monday, May 12, 2025 2:53 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Gail Gordon
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2209 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 11 David Yakobson
From: Gail Gordon <[email protected]>
Sent: Monday, May 12, 2025 2:53 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Gail Gordon
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2210 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 12 David Yakobson
From: Jerry <[email protected]>
Sent: Monday, May 12, 2025 2:46 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
[Jerry Nodiff]
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2211 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 13 David Yakobson
From: Michael Kadish <[email protected]>
Sent: Monday, May 12, 2025 2:29 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: VOTE NO Agenda Item 12A

EXTERNAL
As a home and business owner in Santa Monica, I urge you to vote NO on all 5 proposals in Agenda Item 12A.

Michael B. Kadish, Esq.

The Kadish Law Group, P.C.
3122 Santa Monica Blvd., Suite 200
Santa Monica, California 90404
Tel: 424-239-6210|Fax: 424-239-6220
[email protected]
Privileged/Confidential Information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person), you may not copy or deliver this message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise immediately if you or your employer does not consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.

IRS Circular 230 Disclosure: To ensure compliance with Treasury Department Regulations, we advise you that, unless otherwise expressly indicated, any federal tax advice contained in this communication was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or applicable state or local tax law provisions or (ii) promoting, marketing or recommending to another party any tax-related matter addressed herein.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2212 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 14 David Yakobson
From: Naveen Hovemann <[email protected]>
Sent: Monday, May 12, 2025 2:04 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Naveen HOVEMANN
90401
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2213 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 15 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2214 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 16 David Yakobson
From: Leslie Lambert <[email protected]>
Sent: Monday, May 12, 2025 2:01 PM
To: councilmtgitems
Subject: Re: Item 12A

EXTERNAL
The comments I just submitted refer to item 12A on the May 13 agenda.

Leslie Lambert
On Mon, May 12, 2025, 10:56 PM Leslie Lambert <[email protected]> wrote:

I strongly urge you to adopt the recommendations contained in 12A, particularly the provision for allowing Administrative review for all housing projects on sites that are larger than one acre. The reasons for my recommendation are as follows.

1. Requiring further exactions for projects in order to be eligible for Administrative review would require amendment of the Zoning Ordinance and, perhaps, the LUCE. to specify what these additional requirements would be. My understanding is that those proposing these exactions are considering those required by the Bergamot Area Plan. There is no indication that these requirements are suitable for citywide application.

2. Proponents of additional exactions in order to qualify for Administrative approval consider this approach legitimate because it means developers will be giving something back to the City. In my opinion, this is a ludicrous assertion given the current market conditions that are negatively affecting the development of new housing. I would maintain that the provision of new housing, given the negative market environment, the funds generated by Measure GS, and paying all the other fees required by the City are more than an ample basis for expediting the review of projects on larger sites.

3. Any actions that add time to the production of housing are not in the interest of the City and are particularly harmful to families who need this housing. And certainly contrary to State priorities. Let's not get lost in process.

I am writing this from.Barcelona so will not be attending tomorrow night's meeting.

Thank you for your consideration of my points by supporting the most expeditious process for producing housing as possible.

Leslie Lambert
Planning Commissioner (for ID only)
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2215 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 17 David Yakobson
From: George Guttman <[email protected]>
Sent: Monday, May 12, 2025 1:59 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: Please Vote NO on Agenda Item 12A Protect Our Neighborhood and Public Voice

EXTERNAL
Dear Mayor and City Councilmembers,
I am writing as a concerned Santa Monica resident to respectfully urge you to vote NO on all five proposals included in Agenda Item 12A 5/13/2025. These proposals would have a lasting and detrimental impact on the character, safety, and livability of our community.

Here’s why I strongly oppose Agenda Item 12A:

1. SB 79 – Overdevelopment Without Oversight
Allowing apartment and condo towers up to 15 stories tall within a 1Ú2 mile of any transit stop, including an ever-growing number of bus stops, would invite unchecked overdevelopment, congestion and safety issues. This bill prioritizes developers over residents and undermines local control.

2. Eliminating the Owner-Occupancy Requirement for Lot Splits This change would accelerate speculative real estate activity in single-family neighborhoods, eroding community stability and transforming residential areas into zones apartment zones.

3. Removing Public Input on Commercial Development
Removing the requirement for council votes and public comment on commercial projects would silence the voices of residents and remove critical transparency from the development process.

Decisions that impact the future of our city should never be made behind closed doors.

4. Upzoning 1331 Wilshire and 2644 30th Street
These proposals set a dangerous precedent for out-of-scale development in sensitive areas.

Upzoning without community input disregards the values and concerns of surrounding residents.

5. Reducing Public Speaking Time at Council Meetings
Limiting residents’ ability to speak and removing time donations further diminishes public participation in our democracy. Santa Monica deserves more transparency and engagement, not less.

6. It is deeply troubling that every member of this City Council has accepted campaign contributions from developers and affiliated political action committees. This represents a serious conflict of interest and may constitute a violation of the Fair Political Practices Commission’s (FPPC) Pay-to-Play restrictions. Furthermore, the lack of transparency in how these proposals are being advanced raises legitimate concerns about potential Brown Act violations. Santa Monica residents will not stand by! We will demand full accountability and ensure these matters are thoroughly investigated by the appropriate oversight authorities.

Each of these proposals benefits large developers, not the everyday residents who live, work, and raise families in Santa Monica. We are facing serious challenges in public safety, infrastructure, and affordability handing over our city to speculative interests will only worsen these problems.

Please stand with the residents of Santa Monica, not special interests. Vote NO on Agenda Item 12A.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2216 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 18 Sincerely,
George Guttman
Long time resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2217 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 19 David Yakobson
From: Leslie Lambert <[email protected]>
Sent: Monday, May 12, 2025 1:57 PM
To: councilmtgitems
Cc: Lana Negrete; [email protected]; [email protected]; Natalya Zernitskaya; [email protected]; Dan Hall; Ellis Raskin
Subject: Item 12A

EXTERNAL
I strongly urge you to adopt the recommendations contained in 12A, particularly the provision for allowing Administrative review for all housing projects on sites that are larger than one acre. The reasons for my recommendation are as follows.

1. Requiring further exactions for projects in order to be eligible for Administrative review would require amendment of the Zoning Ordinance and, perhaps, the LUCE. to specify what these additional requirements would be. My understanding is that those proposing these exactions are considering those required by the Bergamot Area Plan. There is no indication that these requirements are suitable for citywide application.

2. Proponents of additional exactions in order to qualify for Administrative approval consider this approach legitimate because it means developers will be giving something back to the City. In my opinion, this is a ludicrous assertion given the current market conditions that are negatively affecting the development of new housing. I would maintain that the provision of new housing, given the negative market environment, the funds generated by Measure GS, and paying all the other fees required by the City are more than an ample basis for expediting the review of projects on larger sites.

3. Any actions that add time to the production of housing are not in the interest of the City and are particularly harmful to families who need this housing. And certainly contrary to State priorities. Let's not get lost in process.

I am writing this from.Barcelona so will not be attending tomorrow night's meeting.

Thank you for your consideration of my points by supporting the most expeditious process for producing housing as possible.

Leslie Lambert
Planning Commissioner (for ID only)
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2218 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 20 David Yakobson
From: Judy Abdo <[email protected]>
Sent: Monday, May 12, 2025 1:53 PM
To: councilmtgitems
Subject: item 12

EXTERNAL
Councilmembers,
I support concrete changes to Santa Monica's housing policies that will facilitate the building of muchneeded housing in our city. As a former Councilmember and Mayor of Santa Monica, I appreciate the role housing plays in creating an equitable and sustainable community. I ask that you follow Staff's recommendations on these proposed changes: (1) finding ways to streamline and reduce the time to permit Administrative Approvals for housing, (2) supporting a change in the current ordinance to allow housing on parcels over one acre in size to use AAs, and (3) supporting changes to ADU minimum and maximum size limits, and increasing the number of ADUs & JADUs permitted on existing multifamily parcels.

Thank you for your commitment to the progressive values that make changes like these possible.

Judy Abdo
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2219 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Alex Novakovich <[email protected]>
Sent: Monday, May 12, 2025 11:39 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.2 - Elimination of owner-occupancy requirement - OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor Pro-Tem Torosis, and City Council Members, I oppose the proposed amendment that eliminates an owner-occupancy requirement for lot splits.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

The Planning Commission reviewed the item and recommended against adopting it.

According to Public Record the elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to make millions from his projects.

I urge you to retain an owner-occupancy requirement that is consistent with current state law and preserves the integrity of our neighborhoods.

Thank you,
Alex Novakovich
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2220 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Caro Vilain <[email protected]>
Sent: Monday, May 12, 2025 11:48 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Caro Vilain
90404
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2221 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2222 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Maria Loya <[email protected]>
Sent: Monday, May 12, 2025 1:28 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Maria Loya
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2223 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Maria Loya <[email protected]>
Sent: Monday, May 12, 2025 1:28 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Maria Loya
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2224 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Maria Loya <[email protected]>
Sent: Monday, May 12, 2025 1:28 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Maria Loya
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2225 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Aram Kadish <[email protected]>
Sent: Monday, May 12, 2025 1:28 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning. Thank you, Aram Kadish
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2226 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 David Yakobson
From: Aram Kadish <[email protected]>
Sent: Monday, May 12, 2025 1:28 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you, Aram Kadish
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2227 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 6 David Yakobson
From: Aram Kadish <[email protected]>
Sent: Monday, May 12, 2025 1:27 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owneroccupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods. Thank you,
Aram Kadish
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2228 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 7 David Yakobson
From: Tracey Alexander <[email protected]>
Sent: Monday, May 12, 2025 1:19 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support of Item 12.A

EXTERNAL
Hello Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank-you,
Tracey Alexander
90272
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owneroccupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle- and lower-income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2229 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 8 and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2230 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 9 David Yakobson
From: Ralph Mechur <[email protected]>
Sent: Monday, May 12, 2025 1:04 PM
To: councilmtgitems
Subject: Agenda item 12A

EXTERNAL
Mayor and Council
For item 12A I would ask you to consider for ADU's that the size limit be modified for detached ADU's as follows:
studios and 1BR units = 850 SF
2 bedroom units = 1200 SF
3 bedroom+ units = 1350 SF
The proposed limit is 1200 SF for all units 2 bedroom and greater. One of Santa Monica's largest deficits is a lack of middle income large units and I would add for upper middle income units as well. R-1 lots north of Wilshire Blvd and in Sunset Park can accommodate larger ADU's with 3, 4 and 5 bedrooms for larger middle and upper middle income families. The additional area will allow for added bedrooms while maintaining adequate common areas. This will be particularly for 2 story ADU's.

Please review with staff if there are any restrictions to making this change and if it can be provided at this time.

Sincerely,
--
Ralph Mechur
Ralph Mechur Architects
2800 Airport Avenue, #1A
Santa Monica, CA 90405
o: 310-398-2940
m: 310-721-1254
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2231 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 10 David Yakobson
From: Will von Bernuth <[email protected]>
Sent: Monday, May 12, 2025 12:46 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard.

Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE.

Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Will von Bernuth
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2232 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 11 David Yakobson
From: Will von Bernuth <[email protected]>
Sent: Monday, May 12, 2025 12:44 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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.

This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Will von Bernuth
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2233 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 12 David Yakobson
From: Will von Bernuth <[email protected]>
Sent: Monday, May 12, 2025 12:43 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects.

Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Wil von Bernuth
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2234 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 13 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 11:38 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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.

This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Elizabeth Grossman
To help protect your privacy,
Micro so ft Office prevented
auto matic downlo ad o f this
picture from the Internet. Virus-free.www.avast.com
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2235 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 14 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 11:38 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Elizabeth Grossman
To help protect your privacy,
Micro so ft Office prevented
auto matic downlo ad o f this
picture from the Internet. Virus-free.www.avast.com
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2236 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 15 David Yakobson
From: Cindy Fraser <[email protected]>
Sent: Monday, May 12, 2025 11:19 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Cynthia Fraser
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2237 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 16 David Yakobson
From: Cindy Fraser <[email protected]>
Sent: Monday, May 12, 2025 11:19 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Cynthia Fraser
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2238 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 17 David Yakobson
From: Cindy Fraser <[email protected]>
Sent: Monday, May 12, 2025 11:18 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Cynthia Fraser
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2239 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 18 David Yakobson
From: Ryan Olson <[email protected]>
Sent: Monday, May 12, 2025 10:53 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you, Ryan Olson, 90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2240 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 19 number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2241 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 20 David Yakobson
From: nancykless <[email protected]>
Sent: Monday, May 12, 2025 10:49 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Nancy Kless
310-890-4266
Sent via the Samsung Galaxy S21 5G, an AT&T 5G smartphone Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2242 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 21 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 10:46 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial.

In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Kelly
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2243 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 22 David Yakobson
From: nancykless <[email protected]>
Sent: Monday, May 12, 2025 10:48 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you!
Nancy Kless
310-890-4266
Sent via the Samsung Galaxy S21 5G, an AT&T 5G smartphone Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2244 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 23 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 10:46 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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.

This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you,
Kelly
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2245 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 24 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 10:45 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects.

Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Kelly
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2246 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 25 David Yakobson
From: Michael Stoppelman <[email protected]>
Sent: Monday, May 12, 2025 10:36 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Support for Item 12A and Consent Calendar Item J – Housing and Transit-Oriented Development

EXTERNAL
Dear Mayor Negrete and Santa Monica City Council Members, As a member of Abundant Santa Monica, I am writing to strongly support Item 12A on the May 13th agenda, as well as Consent Calendar Item J.

Item 12A includes crucial updates to Santa Monica’s housing ordinances that will encourage muchneeded housing development while complying with state law. I urge you to approve these updates, which include:
* Legalizing duplexes and lot splits in single-family neighborhoods in accordance with SB9, and removing unnecessary owner occupancy requirements that currently limit the law's impact. * Supporting the creation of Accessory Dwelling Units (ADUs) in all residential zones. * Expanding streamlined approvals for larger housing projects. * Replacing parcel coverage rules with Floor Area Ratio (FAR) for residential zoning. * Providing clarity on what constitutes a meeting of the Architectural Review Board.

These important reforms will help lower barriers to housing, modernize our zoning code, and foster a more inclusive Santa Monica.

I also support Consent Calendar Item J, which directs city staff to send a letter of support for SB 79. This vital state legislation will promote transit-oriented development throughout California, assisting communities like ours in meeting housing goals, reducing reliance on vehicles, and better utilizing our transit infrastructure.

I respectfully request your vote in favor of both Item 12A and Consent Calendar Item J to help Santa Monica progress towards a more abundant, equitable, and sustainable future.

Sincerely,
Michael Stoppelman
Abundant Santa Monica Member
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2247 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 26 David Yakobson
From: Susan Jain <[email protected]>
Sent: Monday, May 12, 2025 10:11 AM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Susan Jain
Sunset Park Resident
Vice Chair, SM Arts Commission
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2248 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 27 David Yakobson
From: Susan Jain <[email protected]>
Sent: Monday, May 12, 2025 10:11 AM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Susan Jain
Sunset Park Resident
Vice Chair, SM Arts Commission
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2249 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 28 David Yakobson
From: nancykless <[email protected]>
Sent: Monday, May 12, 2025 10:39 AM
To: councilmtgitems
Cc: Dan Hall; [email protected]; Barry Snell; Ellis Raskin; [email protected]; [email protected]; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Nancy Kless
310-890-4266
Sent via the Samsung Galaxy S21 5G, an AT&T 5G smartphone Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2250 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 29 David Yakobson
From: Susan Jain <[email protected]>
Sent: Monday, May 12, 2025 10:09 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,

Susan Jain
Sunset Park Resident
Vice Chair, SM Arts Commission
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2251 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 30 David Yakobson
From: Bronwyn Barkan <[email protected]>
Sent: Monday, May 12, 2025 10:00 AM
To: councilmtgitems
Cc: Dan Hall; [email protected]; Ellis Raskin; Barry Snell; Caroline Torosis; [email protected]; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Bronwyn Barkan
Resident Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2252 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 31 David Yakobson
From: Eli Gill <[email protected]>
Sent: Monday, May 12, 2025 9:59 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Support for Item 12A and Consent Calendar Item J – Housing and Transit-Oriented Development

EXTERNAL
Dear Mayor Negrete and Santa Monica City Council members, As a member of Abundant Santa Monica, I am writing to express strong support for Item 12A on the May 13th agenda, as well as Consent Calendar Item J.

Item 12A includes important updates to Santa Monica’s housing ordinances that will promote muchneeded housing production while aligning with state law. I urge you to approve these updates, including:

Legalizing duplexes and lot splits in single-family neighborhoods under SB9, and removing unnecessary owner occupancy requirements that limit the law’s effectiveness Supporting the creation of ADUs across residential zones Expanding streamlined approvals to larger housing projects Replacing parcel coverage rules with Floor Area Ratio (FAR) for residential zoning Clarifying what constitutes a meeting of the Architectural Review Board These reforms will help reduce barriers to housing, modernize our zoning code, and support a more inclusive Santa Monica.

I also support Consent Calendar Item J, which directs city staff to send a letter of support for SB 79. This important state legislation would promote transit-oriented development statewide—helping communities like ours meet housing goals, reduce vehicle dependence, and make better use of our transit infrastructure.

Please vote in favor of both Item 12A and Consent Calendar Item J to keep Santa Monica moving toward a more abundant, equitable, and sustainable future.

Sincerely,
Eli Gill
Abundant Santa Monica Member
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2253 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 32 David Yakobson
From: Bronwyn Barkan <[email protected]>
Sent: Monday, May 12, 2025 9:56 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Bronwyn Barkan
Resident Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2254 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 33 David Yakobson
From: Amy <[email protected]>
Sent: Monday, May 12, 2025 9:37 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Amy Bisson
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2255 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 34 David Yakobson
From: Amy <[email protected]>
Sent: Monday, May 12, 2025 9:37 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Amy Bisson
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2256 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 35 David Yakobson
From: Chasen Daniels <[email protected]>
Sent: Monday, May 12, 2025 9:19 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Chasen Daniels
90401
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2257 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 36 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2258 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 37 David Yakobson
From: Danny Guggenheim <[email protected]>
Sent: Monday, May 12, 2025 9:00 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008 to (respectively) change the LUCE and Districting Map for 2644 30th Street, which is less than one-quarter of a mile from our home of nearly 20 years.

If this change is made, this lot which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street. 2644 30th Street is currently a 2-story office building and parking lot that fronts both 29th and 30th Streets, and which is usually quiet and calm outside of business hours and on weekends, when countless residents walk their children and pets past this lot. It is an interior parcel and is not located on a boulevard.

Staff should not be supporting an upzone of this parcel to Neighborhood Commercial, and in any case has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. I am also concerned to hear about questionable statements made by staff in order to justify what appears to be illegal spot zoning.

I urge you to oppose this inappropriate, misguided and potentially illegal upzoning.

Thank you,
Danny Guggenheim
Sunset Park homeowner since 2006
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2259 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 38 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 8:59 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25- 007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning. Thank you,
Vincent Esparza
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2260 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 39 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 8:57 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you,
Vincent Esparza
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2261 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 40 David Yakobson
From: [email protected]
Sent: Monday, May 12, 2025 8:57 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods. Thank you, Vincent Esparza - Sunset Park Resident
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2262 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 41 David Yakobson
From: Danny Guggenheim <[email protected]>
Sent: Monday, May 12, 2025 8:48 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I strongly object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This is a far-reaching and materially adverse change to our zoning laws from the perspective of the city’s residents, who are not electing staff, and in any case should not be granting staff the discretion to control so much of the development of our city without feedback. The public must be able to weigh in on huge projects before they are approved.

I urge you to reject this proposal and retain the requirement for public feedback on large projects.

Thank you,
Danny Guggenheim
Sunset Park homeowner since 2006
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2263 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 42 David Yakobson
From: John Tapia <[email protected]>
Sent: Monday, May 12, 2025 8:46 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Do not support Item 12.A

EXTERNAL
Councilmembers,
I am writing in disapproval of item 12.A updating zoning ordinance and city code. There is no housing crisis. Rent control has created the loss of cheaper rentals. Economists agree. Report after report agrees.

Until rent control is reduced or removed, none of this solutions will produce more of the desired inexpensive housing.

Thank you,
John Tapia
90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2264 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 43 their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2265 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 44 David Yakobson
From: JORDAN ELLIS <[email protected]>
Sent: Monday, May 12, 2025 8:44 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Jordan Ellis
Resident of Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2266 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 45 David Yakobson
From: JORDAN ELLIS <[email protected]>
Sent: Monday, May 12, 2025 8:44 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Jordan Ellis
Resident of Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2267 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 46 David Yakobson
From: Danny Guggenheim <[email protected]>
Sent: Monday, May 12, 2025 8:40 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I strongly object to the proposed amendment that eliminates an owner-occupancy requirement for ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

This ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it, and current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

In addition, removing the owner-occupancy provision – as well as all limitations to demolition – will open all singlefamily residential properties to speculative purchase by developers. To that end, it is shocking to hear that the Council's consideration of this proposal may have been the result of a request by a corporate representative who is associated with two different SB9 developments in Santa Monica, and would profit greatly from its passage. Our Council was elected by the residents, to serve the residents - not corporate interests.

I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Danny Guggenheim
Sunset Park homeowner since 2006
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2268 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 47 David Yakobson
From: JORDAN ELLIS <[email protected]>
Sent: Monday, May 12, 2025 8:39 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Barry Snell; Caroline Torosis; Ellis Raskin; Natalya Zernitskaya; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Jordan Ellis
Resident of Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2269 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 48 David Yakobson
From: Diana Bianchini <[email protected]>
Sent: Monday, May 12, 2025 8:21 AM
To: councilmtgitems
Cc: Diana Bianchini
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Diana Bianchini
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2270 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 49 David Yakobson
From: Diana Bianchini <[email protected]>
Sent: Monday, May 12, 2025 8:20 AM
To: councilmtgitems
Cc: Diana Bianchini
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Diana Bianchini
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2271 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 50 David Yakobson
From: janet rt <[email protected]>
Sent: Monday, May 12, 2025 8:13 AM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Janet Tunick
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2272 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 51 David Yakobson
From: Lauren Marie <[email protected]>
Sent: Monday, May 12, 2025 8:08 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Lauren Wyka
821 Bay St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2273 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 52 David Yakobson
From: Lauren Marie <[email protected]>
Sent: Monday, May 12, 2025 8:07 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Lauren Wyka
821 Bay St
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2274 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 53 David Yakobson
From: Lauren Marie <[email protected]>
Sent: Monday, May 12, 2025 8:07 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Friends of Sunset Park
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Lauren Wyka
821 Bay
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2275 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Kelli <[email protected]>
Sent: Wednesday, May 7, 2025 7:48 AM
To: Lana Negrete; Dan Hall; councilmtgitems; Ellis Raskin; Barry Snell; Jesse Zwick; Caroline Torosis; Natalya Zernitskaya
Subject: Stop 7 story zoning Sunset Park

EXTERNAL
I am writing to request that you DO NOT approve the resolutions changing the Luce Designs to neighborhood commercial and changing zoning to NC.

Thank You
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2276 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Dorothy Le Suchkova <[email protected]> Sent: Sunday, May 11, 2025 5:30 PM
To: councilmtgitems; Dan Hall; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Lana Negrete
Subject: In support of pro-housing amendments to the Santa Monica zoning code

EXTERNAL
Dear Honorable City Council Members,
I am writing to support the changes to city ordinances that are proposed for city council approval on May 13, 2025 and encourage the council council members to vote in favor.

As a homeowner and resident in Sunset Park, I recently built an Accessory Dwelling Unit.

I strongly support proposals to facilitate and streamline duplex creation, encourage ADUs, simplification of residential zoning to form-based zoning, and reduce timelines to progress through ARB review. These proposals will increase housing, diversity housing type and grow the city's tax base.

In addition, as a Sunset Park resident, I received a flyer from Friends for Sunset Park opposing items 12 A.6 and 7. I strongly disagree and support the City restoring the zoning of 2644 30th Street to neighborhood commercial.

Thank you,
Dorothy
Dorothy Le Suchkova
c: 424.212.9327
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2277 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Boris Suchkov <[email protected]>
Sent: Sunday, May 11, 2025 4:55 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: In support of pro-housing amendments to the Santa Monica zoning code

EXTERNAL
Hi,
I'm writing to support the changes to city ordinances that are proposed for city council approval on May 13, 2025 and encourage the city council members to vote in favor.

As a homeowner in Sunset Park who has suffered through getting approvals to build an ADU in my backyard, I have first hand experience of the red tape and lack of equity when it comes to building anything in this city. The proposals to facilitate duplex creation in single family neighborhoods, encourage ADUs, streamline approvals, as well as advocating for simplification of residential zoning to form-based zoning, and reducing timelines to progress through ARB review are all great ideas that will increase equity in the city through diversification of housing types, improve the rate of housing production, and grow the city's tax base.

Also, because I live on the same block as the property in item 12.A.6 and 7, I was infuriated by the misleading information spread by "Friends of Sunset Park" in a flyer on my doorstep, which insinuated that 2644 30th St is being rezoned inappropriately.

I strongly encourage this city council to not only vote in favor of the items restoring Commercial zoning to 2644 30th St, but also to look into reforms of the officially city-sanctioned "civic" groups like Friends of Sunset Park to make them more representative of the neighborhood at large and reduce the spread of misinformation.

Boris Suchkov
--
“We take cars for granted and we’re like, yeah, that’s just how you get around. But if you change your perspective and realize what’s really going on, you realize they wreck everything. Like, cars wreck everything. They wreck cities. They wreck your wallet, your finances. They wreck your family. They kill you. They make you fat. They cost ten times more to make paths and roads for than the alternative of putting stuff closer together and having bikes and walking and stuff. Cars just wreck everything.” -Mr. Money Mustache
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2278 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Steven Kim <[email protected]>
Sent: Sunday, May 11, 2025 3:29 PM
To: councilmtgitems; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: Opposition to Proposed Zoning Change at 2644 30th Street – Sunset Park

EXTERNAL
Dear Santa Monica City Councilmembers,
I am a longtime homeowner at 2645 30th Street, directly across from the proposed development at 2644 30th Street, and I am writing to express my strong opposition to the requested zoning change that would allow a 7-story (85-foot) mixed-use commercial development in the middle of our Sunset Park neighborhood.

This proposal blatantly violates the principles and protections established in Santa Monica’s Land Use and Circulation Element (LUCE), which prioritizes preserving the scale and character of existing residential neighborhoods like Sunset Park. LUCE specifically states that new development should be compatible with surrounding uses and directed away from low-density areas, guiding growth instead to designated boulevards and transit corridors.

Currently, the maximum residential height allowed in Sunset Park is 30 feet in Pitched roof home. An 85-foot structure — nearly triple that limit — would be a massive intrusion into a community of one- and two-story homes. The impacts would be devastating:
 Irreversible disruption of neighborhood character
 Severe parking overflow (already worsened by businesses along Ocean Park Blvd)  Loss of privacy, sunlight, and livability
 Noise and traffic from added commercial activity
This is not smart growth — it is speculative overdevelopment at the expense of established families, homeowners, and the identity of Sunset Park.

I urge you to uphold LUCE’s vision and reject this zoning change. Our neighborhood deserves to be protected, not sacrificed for an outsized and incompatible project.

Sincerely,
Steven Kim
2645 30th Street
Santa Monica, CA 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2279 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Margery Kratz <[email protected]>
Sent: Sunday, May 11, 2025 2:19 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,

Margery Kratz
1205 Grant Street
Santa Monica, CA 90405
———————————
Margery Kratz
310.463.4129 Cell
310.450.5461 Home
[email protected]
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2280 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 David Yakobson
From: Michael Fisher <[email protected]>
Sent: Sunday, May 11, 2025 2:14 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of the profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is the City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Michael Fisher
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2281 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 1 David Yakobson
From: Kelli <[email protected]>
Sent: Monday, May 12, 2025 7:37 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning.

Thank you,
Kelli Urode
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2282 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2 David Yakobson
From: Kelli <[email protected]>
Sent: Monday, May 12, 2025 7:36 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you,
Kelli Urode
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2283 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 3 David Yakobson
From: Kelli <[email protected]>
Sent: Monday, May 12, 2025 7:36 AM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Kelli Urode
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2284 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 4 David Yakobson
From: Cindy Mollo <[email protected]>
Sent: Sunday, May 11, 2025 10:17 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Cynthia Mollo
2677 Centinela Avenue
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2285 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 5 David Yakobson
From: Cindy Mollo <[email protected]>
Sent: Sunday, May 11, 2025 10:16 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Cynthia Mollo
2677 Centinela Avenue
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2286 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 6 David Yakobson
From: Cindy Mollo <[email protected]>
Sent: Sunday, May 11, 2025 10:15 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Cynthia Mollo
2677 Centinela Avenue
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2287 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 7 David Yakobson
From: Darko Suvak <[email protected]>
Sent: Sunday, May 11, 2025 9:20 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Darko Suvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2288 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 8 David Yakobson
From: Darko Suvak <[email protected]>
Sent: Sunday, May 11, 2025 9:20 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Darko Suvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2289 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 9 David Yakobson
From: Charles Gibson <[email protected]>
Sent: Sunday, May 11, 2025 8:56 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor Pro Tem Torosis, and City Council Members, I strongly oppose the proposed amendment removing the owner-occupancy requirement for ministerial approval of duplexes and lot splits in single-family zones.

This change would undermine our family neighborhoods, replacing them with profit-driven, market-rate development. It disregards the Planning Commission’s recommendation against adoption.

State law explicitly requires owner-occupancy for three years following a lot split. Eliminating this safeguard—and lifting demolition limits—invites speculative acquisition of single-family homes by developers.

Notably, this proposal was pushed by a single corporate representative, linked to two SB9 projects in Santa Monica, who stands to profit enormously. Are we reshaping our city at the request of one developer? I urge you to uphold the owner-occupancy requirement in line with state law and in defense of neighborhood integrity.

Thank you,
Charles Gibson
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2290 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 10 David Yakobson
From: Adam Cohen <[email protected]>
Sent: Sunday, May 11, 2025 8:49 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Adam Cohen
Live: Cedar Street, Santa monica
Work: hollywood:

Adam Cohen  Super Delicious
6121 Santa Monica Blvd. Suite G
Hollywood, CA 90038
[email protected]
O: (323) 785-2660
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2291 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 11 David Yakobson
From: Ivana Suvak <[email protected]>
Sent: Sunday, May 11, 2025 8:22 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Ivana and Darko Suvak
2666 32nd street
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2292 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 12 David Yakobson
From: Ivana Suvak <[email protected]>
Sent: Sunday, May 11, 2025 8:21 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Ivana and Darko Suvak
2666 32nd street
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2293 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 13 David Yakobson
From: Ivana Suvak <[email protected]>
Sent: Sunday, May 11, 2025 8:21 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Ivana and Darko Suvak
2666 32nd street
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2294 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 14 David Yakobson
From: Staci Weiss <[email protected]>
Sent: Sunday, May 11, 2025 8:11 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
[YOUR NAME HERE]
STACI VERK 323.363.1456
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2295 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 15 David Yakobson
From: Cydney Kirschbaum <[email protected]>
Sent: Sunday, May 11, 2025 8:02 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Cydney and Kenneth Kirschbaum
30+ year residents of Sunset Park
Cydney Kirschbaum
[email protected]
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2296 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 16 David Yakobson
From: Cydney Kirschbaum <[email protected]>
Sent: Sunday, May 11, 2025 8:01 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Cydney and Kenneth Kirschbaum
30+ year residents of Sunset Park
Cydney Kirschbaum
[email protected]
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2297 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 17 David Yakobson
From: Cydney Kirschbaum <[email protected]>
Sent: Sunday, May 11, 2025 8:01 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Cydney and Kenneth Kirschbaum
30+ year residents in Sunset Park
Cydney Kirschbaum
[email protected]
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2298 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 18 David Yakobson
From: Jacob Wasserman <[email protected]>
Sent: Sunday, May 11, 2025 7:57 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems; Council Mailbox
Subject: In Support: Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Jacob Wasserman
90403
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2299 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 19 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2300 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 20 David Yakobson
From: Mary Duprey <[email protected]>
Sent: Sunday, May 11, 2025 7:18 PM
To: councilmtgitems
Cc: Lana Negrete; Jesse Zwick; [email protected]; Dan Hall; Council Mailbox; Natalya Zernitskaya; Caroline Torosis; Barry Snell; Ellis Raskin Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Mary Duprey
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2301 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 21 David Yakobson
From: Mary Duprey <[email protected]>
Sent: Sunday, May 11, 2025 7:13 PM
To: Natalya Zernitskaya
Cc: Lana Negrete; Jesse Zwick; [email protected]; Dan Hall; Council Mailbox; Caroline Torosis; Barry Snell; Ellis Raskin; councilmtgitems Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Mary Duprey
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2302 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 22 David Yakobson
From: Patty McCollim <[email protected]>
Sent: Sunday, May 11, 2025 7:04 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, We object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Richard Sproul
& Patty McCollim
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2303 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 23 David Yakobson
From: Patty McCollim <[email protected]>
Sent: Sunday, May 11, 2025 7:01 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, We object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Richard Sproul
& Patty McCollim
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2304 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 24 David Yakobson
From: Patty McCollim <[email protected]>
Sent: Sunday, May 11, 2025 6:57 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, We object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Richard Sproul
& Patty McCollim
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2305 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 25 David Yakobson
From: Mary Duprey <[email protected]>
Sent: Sunday, May 11, 2025 6:48 PM
To: Dan Hall
Cc: Lana Negrete; Jesse Zwick; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; [email protected]; Council Mailbox; councilmtgitems Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects.

Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Mary Duprey
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2306 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 26 David Yakobson
From: Diane Sabatini <[email protected]>
Sent: Sunday, May 11, 2025 6:11 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolutions 25-007 and 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Diane Sabatini
Diane Sabatini | 1801 Pier Avenue
Santa Monica, CA 90405 |
(c) 310.804.9811
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2307 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 27 David Yakobson
From: Diane Sabatini <[email protected]>
Sent: Sunday, May 11, 2025 6:10 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, Another objectionable proposed amendment.

I object to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Diane Sabatini
Diane Sabatini | 1801 Pier Avenue
Santa Monica, CA 90405 |
(c) 310.804.9811
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2308 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 28 David Yakobson
From: Darlene Vogel <[email protected]>
Sent: Sunday, May 11, 2025 6:10 PM
To: councilmtgitems; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Darlene Vogel ]
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2309 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 29 David Yakobson
From: Darlene Vogel <[email protected]>
Sent: Sunday, May 11, 2025 6:10 PM
To: councilmtgitems; Jesse Zwick
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Darlene Vogel
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2310 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 30 David Yakobson
From: Diane Sabatini <[email protected]>
Sent: Sunday, May 11, 2025 6:09 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, What is going on with the City Council choices?
I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Diane Sabatini
Diane Sabatini | 1801 Pier Avenue
Santa Monica, CA 90405 |
(c) 310.804.9811
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2311 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 31 David Yakobson
From: Darlene Vogel <[email protected]>
Sent: Sunday, May 11, 2025 6:09 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you, Darlene Vogel
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2312 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 32 David Yakobson
From: S V <[email protected]>
Sent: Sunday, May 11, 2025 5:00 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Sharon Cunningham
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2313 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 33 David Yakobson
From: S V <[email protected]>
Sent: Sunday, May 11, 2025 4:59 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected] Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Sharon Cunningham
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2314 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 34 David Yakobson
From: Steven Kim <[email protected]>
Sent: Sunday, May 11, 2025 4:24 PM
To: councilmtgitems
Subject: 5/13/25 agenda item 12-A

EXTERNAL
Dear Santa Monica City Councilmembers,
I am a longtime homeowner at 2645 30th Street, directly across from the proposed development at 2644 30th Street, and I am writing to express my strong opposition to the requested zoning change that would allow a 7-story (85-foot) mixed-use commercial development in the middle of our Sunset Park neighborhood.

This proposal blatantly violates the principles and protections established in Santa Monica’s Land Use and Circulation Element (LUCE), which prioritizes preserving the scale and character of existing residential neighborhoods like Sunset Park. LUCE specifically states that new development should be compatible with surrounding uses and directed away from low-density areas, guiding growth instead to designated boulevards and transit corridors.

Currently, the maximum residential height allowed in Sunset Park is 30 feet in Pitched roof home. An 85-foot structure — nearly triple that limit — would be a massive intrusion into a community of one- and two-story homes. The impacts would be devastating:
 Irreversible disruption of neighborhood character
 Severe parking overflow (already worsened by businesses along Ocean Park Blvd)  Loss of privacy, sunlight, and livability
 Noise and traffic from added commercial activity
This is not smart growth — it is speculative overdevelopment at the expense of established families, homeowners, and the identity of Sunset Park.

I urge you to uphold LUCE’s vision and reject this zoning change. Our neighborhood deserves to be protected, not sacrificed for an outsized and incompatible project.

Sincerely,
Steven Kim
2645 30th Street
Santa Monica, CA 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2315 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 35 David Yakobson
From: Kenneth Legaux <[email protected]>
Sent: Sunday, May 11, 2025 2:58 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25- 007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning. Thank you,
Kenneth Legaux Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2316 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 36 David Yakobson
From: Dominique Chausse <[email protected]>
Sent: Sunday, May 11, 2025 3:00 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I strongly object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! Surely you all are not trying to emulate the chaos and destruction we are witnessing at the federal level. This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Dominique Chausse
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2317 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 37 David Yakobson
From: Kenneth Legaux <[email protected]>
Sent: Sunday, May 11, 2025 2:57 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you,
Kenneth Legaux Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2318 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 38 David Yakobson
From: Kenneth Legaux <[email protected]>
Sent: Sunday, May 11, 2025 2:56 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods. Thank you, Kenneth Legaux Sunset Park
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2319 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 39 David Yakobson
From: Jesus Gonzalez <[email protected]>
Sent: Sunday, May 11, 2025 2:49 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it. Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owneroccupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Jesus Gonzalez
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2320 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 40 David Yakobson
From: Jesus Gonzalez <[email protected]>
Sent: Sunday, May 11, 2025 2:48 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning.

Thank you,
Jesus Gonzalez
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2321 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 41 David Yakobson
From: Robert Posek <[email protected]>
Sent: Sunday, May 11, 2025 2:45 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Robert Posek
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2322 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 42 David Yakobson
From: Robert Posek <[email protected]>
Sent: Sunday, May 11, 2025 2:44 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Robert Posek
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2323 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 43 David Yakobson
From: Robert Posek <[email protected]>
Sent: Sunday, May 11, 2025 2:43 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Robert Posek
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2324 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 44 David Yakobson
From: Jon Gibson <[email protected]>
Sent: Sunday, May 11, 2025 2:25 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25- 008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard.

Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE.

Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning. Thank you, Jonathan Gibson Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2325 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 45 David Yakobson
From: Jon Gibson <[email protected]>
Sent: Sunday, May 11, 2025 2:25 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you, Jonathan Gibson Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2326 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 46 David Yakobson
From: Jon Gibson <[email protected]>
Sent: Sunday, May 11, 2025 2:24 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profitdriven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods. Thank you, Jonathan Gibson Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2327 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 47 David Yakobson
From: Margery Kratz <[email protected]>
Sent: Sunday, May 11, 2025 2:20 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Margery Kratz
1205 Grant Street
Santa Monica, CA 90405
———————————
Margery Kratz
310.463.4129 Cell
310.450.5461 Home
[email protected]
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2328 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 48 David Yakobson
From: Margery Kratz <[email protected]>
Sent: Sunday, May 11, 2025 2:20 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you.

Sincerely,
Margery Kratz
1205 Grant Street
Santa Monica, CA 90405
———————————
Margery Kratz
310.463.4129 Cell
310.450.5461 Home
[email protected]
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2329 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 49 David Yakobson
From: Michael Fisher <[email protected]>
Sent: Sunday, May 11, 2025 2:18 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Michael Fisher
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2330 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 50 David Yakobson
From: Michael Fisher <[email protected]>
Sent: Sunday, May 11, 2025 2:16 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change would allow all the overly broad “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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Michael Fisher
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2331 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 51 David Yakobson
From: Emily Davidson <[email protected]>
Sent: Sunday, May 11, 2025 2:13 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
E. Davidson
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2332 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 52 David Yakobson
From: Joanne Leslie <[email protected]>
Sent: Sunday, May 11, 2025 2:12 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I endorse the views of Santa Monica Forward, shared below. I appreciate the City Council working to increase housing options and I especially encourage everything you can do to support below market housing.

Thank you,
Joanne Leslie
90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2333 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 53 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2334 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 54 David Yakobson
From: Emily Davidson <[email protected]>
Sent: Sunday, May 11, 2025 2:11 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Emily Davidson
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2335 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 55 David Yakobson
From: Tom Richards <[email protected]>
Sent: Sunday, May 11, 2025 2:10 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Tom Richards
2913 tenth st #1
Santa Monica 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2336 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 56 David Yakobson
From: Tom Richards <[email protected]>
Sent: Sunday, May 11, 2025 2:10 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Tom Richards
2913 tenth st #1
Santa Monica 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2337 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 57 David Yakobson
From: Tom Richards <[email protected]>
Sent: Sunday, May 11, 2025 2:10 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Tom Richards
2913 tenth st #1
Santa Monica 90405
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2338 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 58 David Yakobson
From: Lisa Sandbank <[email protected]>
Sent: Sunday, May 11, 2025 2:09 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 Elimination of owner-occupancy requirement: -OPPOSEEXTERNAL Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, Owner-occupancy requirement for duplexes and lot splits on parcels zoned for single-unit residential prevents speculative purchase by developers.

The Planning Commission has recommended not to remove this requirement. It was recommended by a single corporate representative who will privately benefit.

I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Lisa Sandbank
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2339 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 59 David Yakobson
From: Carolyn Peralta <[email protected]>
Sent: Sunday, May 11, 2025 2:08 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Carolyn Peralta
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2340 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 60 David Yakobson
From: Clint Malin <[email protected]>
Sent: Sunday, May 11, 2025 2:06 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Clint Malin
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2341 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 61 David Yakobson
From: Dalila Fuentes <[email protected]>
Sent: Sunday, May 11, 2025 2:04 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Dalila Fuentes
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2342 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 62 David Yakobson
From: Dalila Fuentes <[email protected]>
Sent: Sunday, May 11, 2025 2:03 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Dalila Fuentes
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2343 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 63 David Yakobson
From: Dalila Fuentes <[email protected]>
Sent: Sunday, May 11, 2025 2:02 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Dalila Fuentes
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2344 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 64 David Yakobson
From: janet rt <[email protected]>
Sent: Sunday, May 11, 2025 1:59 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Janet Tunick
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2345 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 65 David Yakobson
From: janet rt <[email protected]>
Sent: Sunday, May 11, 2025 1:58 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport!
This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Janet Tunick
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2346 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 66 David Yakobson
From: janet rt <[email protected]>
Sent: Sunday, May 11, 2025 1:59 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Janet Tunick
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2347 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 67 David Yakobson
From: Elliot Gordon <[email protected]>
Sent: Sunday, May 11, 2025 1:49 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Elliot Gordon
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2348 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 68 David Yakobson
From: Elliot Gordon <[email protected]>
Sent: Sunday, May 11, 2025 1:49 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Elliot Gordon
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2349 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 69 David Yakobson
From: Peter Schechter <[email protected]>
Sent: Sunday, May 11, 2025 1:47 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
[YOUR NAME HERE]
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2350 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 70 David Yakobson
From: DARKO SUVAK <[email protected]>
Sent: Sunday, May 11, 2025 1:46 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Darko and Ivana Suvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2351 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 71 David Yakobson
From: DARKO SUVAK <[email protected]>
Sent: Sunday, May 11, 2025 1:45 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Ivana and Darko Šuvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2352 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 72 David Yakobson
From: Peter Schechter <[email protected]>
Sent: Sunday, May 11, 2025 1:46 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Peter Schechter
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2353 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 73 David Yakobson
From: DARKO SUVAK <[email protected]>
Sent: Sunday, May 11, 2025 1:44 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Darko Suvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2354 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 74 David Yakobson
From: Darko Suvak <[email protected]>
Sent: Sunday, May 11, 2025 1:42 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Darko Suvak
32nd st
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2355 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 75 David Yakobson
From: Darko Suvak <[email protected]>
Sent: Sunday, May 11, 2025 1:40 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25-008, which change the LUCE and Districting Map for 2644 30th Street, respectively.

If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building.

This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard. Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE. Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning.

Please oppose this upzoning.

Thank you,
Darko Suvak
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2356 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 76 David Yakobson
From: Peter Schechter <[email protected]>
Sent: Sunday, May 11, 2025 1:45 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you
Peter Schechter
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2357 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 77 David Yakobson
From: [email protected]
Sent: Sunday, May 11, 2025 1:36 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects.

This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things!
Thank you,
Ofer Grossman
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2358 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 78 David Yakobson
From: [email protected]
Sent: Sunday, May 11, 2025 1:36 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Ofer Grossman
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2359 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 79 David Yakobson
From: Samantha Eknoian <[email protected]>
Sent: Sunday, May 11, 2025 1:36 PM
To: councilmtgitems
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential.

Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profit-driven development of market-rate units.

The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split.

Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers.

In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request?
I urge you to retain an owner-occupancy requirement that is consistent with current state law and is crucial to the integrity of our neighborhoods.

Thank you,
Samantha Eknoian
Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2360 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 80 David Yakobson
From: Phyllis Chavez <[email protected]>
Sent: Sunday, May 11, 2025 1:31 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.6-7 -- Upzoning of 30th Street Parcel -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to Resolution 25-007 and Resolution 25- 008, which change the LUCE and Districting Map for 2644 30th Street, respectively. If this change is made, the lot, which is entirely on the interior of a residential street and includes a parking lot, could, with the state height density bonuses, allow for an 85 foot building. This is way too tall for the interior of a residential street! 2644 30th Street is a 2-story office building and parking lot that fronts both 29th and 30th Streets. It is an interior parcel and is NOT located on a boulevard.

Nevertheless, staff is trying to upzone this parcel to Neighborhood Commercial. In doing so, staff has failed to engage with the community and analyze the impact of the change on the character of the neighborhood as required by the LUCE.

Also of concern are the numerous questionable statements made by staff in order to justify what appears to be illegal spot zoning. Please oppose this upzoning. Thank you, Phyllis Chavez, Sunset Park Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2361 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 81 David Yakobson
From: Phyllis Chavez <[email protected]>
Sent: Sunday, May 11, 2025 1:30 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of parcel size threshold -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment to the text of the City’s Zoning Ordinance to eliminate parcel size threshold for streamlined review of housing projects. This change 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. This could mean parcels as big as the entire Business Park area, or even the Santa Monica Airport! This is a far-reaching, adverse change to our zoning. We cannot leave so much of the development of our city purely to staff discretion. The public must be able to weigh in on huge projects before they are approved -- it's the democratic way to do things! Thank you, Phyllis Chavez, Sunset Park Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2362 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 82 David Yakobson
From: Phyllis Chavez <[email protected]>
Sent: Sunday, May 11, 2025 1:28 PM
To: councilmtgitems
Cc: Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; [email protected]
Subject: 5/13/25 Item 12.A.2 -- Elimination of owner-occupancy requirement -- OPPOSE!

EXTERNAL
Dear Mayor Negrete, Mayor pro-tem Torosis, and City Council Members, I object to the proposed amendment that eliminates an owner-occupancy requirement pertaining to ministerial approval of duplexes and lot splits on parcels zoned for single-unit residential. Adopting this ordinance will lead to the destruction of family neighborhoods in favor of profitdriven development of market-rate units. The Planning Commission who reviewed this recommended against adopting it.

Current state law expressly requires owner-occupancy for 3 years from the date of the approval of a lot split. Removing the owner-occupancy provision – as well as all limitations to demolition – will open all single-family residential properties to speculative purchase by developers. In fact, according to a Public Records Act request to the City, this elimination of the Owner Occupancy Requirement was recommended by a single corporate representative who is associated with two different SB9 developments in Santa Monica, who stands to rake in millions off his projects. Who is City Council serving if it gives our city away to this request? I urge you to retain an owner-occupancy requirement that is consistent with current state law and is the integrity of our neighborhoods. Thank you, Phyllis Chavez, Sunset Park Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2363 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 83 David Yakobson
From: Harry Clennon <[email protected]>
Sent: Sunday, May 11, 2025 12:42 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Harry Clennon
90404
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2364 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 84 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2365 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 85 David Yakobson
From: Babak M <[email protected]>
Sent: Sunday, May 11, 2025 10:06 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Babak Mozaffari
90401
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2366 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 86 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2367 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 87 David Yakobson
From: Zachary Dietrich <[email protected]>
Sent: Sunday, May 11, 2025 9:56 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Zach Dietrich
90404
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2368 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 88 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Sent from my iPhone
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2369 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 89 David Yakobson
From: Liliya Jones <[email protected]>
Sent: Sunday, May 11, 2025 9:39 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Support Item 12.A

EXTERNAL
Councilmembers,
As a constituent, and a young person trying to build a life in Santa Monica, I urge you to support increased housing production in our city.

I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Liliya Jones
90403
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2370 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 90 their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2371 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 91 David Yakobson
From: Jeremy Bamberger <[email protected]>
Sent: Sunday, May 11, 2025 9:35 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Jeremy Bamberger
90405
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quadplexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it.

Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2372 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 92 Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2373 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 93 David Yakobson
From: Sam Shapiro-Kline <[email protected]>
Sent: Sunday, May 11, 2025 9:22 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Sam Shapiro-Kline
90403
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2374 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 94 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2375 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 95 David Yakobson
From: Cassie Stuurman <[email protected]>
Sent: Sunday, May 11, 2025 9:07 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems
Subject: Subject: Support Item 12.A

EXTERNAL
Councilmembers,
I am writing in support of item 12.A updating zoning ordinance and city code. I echo the views of Santa Monica Forward, shared below.

Thank you,
Cassie Stuurman
90404
--------------
Enhancing the production of housing across Santa Monica is an urgent priority, and the city should move to facilitate administrative approvals for all sites, greater production of ADUs, and the creation of duplexes and quad-plexes via lot splits. Further, council should direct adjustments to staff proposals on ADUs, zoning density alignment, and ARB procedure as described in the following paragraphs.

Administrative Approval: Current timelines to approve new developments are taking too long, and blocking the creation of housing which the city desperately needs. Council should approve the change in ordinance to allow parcels over 1 acre in size to use administrative approval. Further, council should seek ways to streamline and reduce the time to permitting.

ADUs: Council should support changes to ADU minimum and maximum size limits, as well as the increase in number of permitted ADUs & JADUs on existing multifamily parcels. Further, council should eliminate the limitation that no more ADUs are created than existing units on a parcel, which inhibits the improvement of existing duplexes and triplexes in a way that encourages their preservation as rent controlled housing. Council should also eliminate owner-occupancy requirements for JADUs in order to enable their creation.

Lot Splits & Duplexes: The elimination of owner-occupancy requirements and limitations on redevelopment of vacant parcels will help to increase housing in high opportunity neighborhoods, and council must vote to pass it. Council should also support increases to FAR and reductions in constraints to facilitate new projects, as recommended by Staff.

LUCE and Zoning Density Alignment: The implementation of density limits is an antiquated approach to zoning which reinforces segregation by encouraging fewer, larger units that are not affordable to middle and lower income residents. Santa Monica should use this opportunity to improve the way it zones by Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2376 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 96 moving to form-based zoning centering on FAR, height, and setbacks. Form-based zoning focuses on making sure that new buildings are compatible with their surroundings, rather than restricting the number of residents who can make Santa Monica their home. As staff notes, the proposed density requirements will continue to lock our residential neighborhoods in amber, entirely blocking new housing production.

Adjustment to Section 9.55.120 on the Architectural Review Board: Council should reject this adjustment to ordinance, and clarify instead that the scheduling of a review by the ARB counts towards the meeting limit, and reduce the meeting limit to 2 from 3. As Staff demonstrates in the Administrative Approval Timelines analysis, ARB approval is a significant drag on the permitting of new housing. Council should aim to reduce timelines for ARB approval, not extend them by allowing the ARB to delay timelines by not discussing items.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2377 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 97 David Yakobson
From: Alex Brown <[email protected]>
Sent: Saturday, May 10, 2025 1:19 AM
To: councilmtgitems; Lana Negrete; Jesse Zwick; Caroline Torosis; Ellis Raskin; Natalya Zernitskaya; Dan Hall; Barry Snell
Cc: Judy Kruger (Santa Monica Chamber of Commerce)
Subject: Letter of Support Council Meeting Agenda Item 12.A, May 13, 2025 Attachments: LOS SM City Zoning 12.A May 2025.pdf

EXTERNAL
Hello Councilmembers,
I am submitting the attached Letter of Support for Agenda Item 12.A for the upcoming City Council meeting on May 13, 2025.

Thank you,
Alex Brown
Director Government Affairs
510-402-4767 | [email protected]
smchamber.com
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2378 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 2525 Main St., Unit 103 | Santa Monica, CA 90405
RE: May 13, Agenda Item 12.A, Housing Streamlining – Support Dear Mayor Negrete and City Councilmembers,
On behalf of the Santa Monica Chamber of Commerce, we are writing to thank the City Council for directing important Zoning Ordinance changes to facilitate housing production and to support both (a) alignment of the City’s definition of “housing project” with the definition in State Law (the Housing Accountability Act) and (b) streamlining for all housing projects regardless of the project site’s land area (removing the current one-acre limit for projects to qualify for an Administrative Approval process).

We frequently hear from our members that the cost and lack of available housing options in Santa Monica directly impacts their ability to attract and retain local employees.

Removing the discretionary hearing process for housing projects reduces cost, time and risk for much needed housing in our City. Thus, we applaud the Council for acknowledging the important role the City’s entitlement and permitting requirements play in housing production.

In addition, Santa Monica businesses have continued to experience economic uncertainty and the removal of additional restrictions on housing will provide more opportunities for a “built in” local customer base to patronize our businesses.

The Chamber respectfully requests the City Council approve the housing streamlining and State-law consistency and implementation items included in the draft ordinance for Agenda Item 12.A
provided by City Staff.

Sincerely,

Board Executives
Chair
Charlie LopezQuintana
ETC Hotels
Past Chair
Younes Atallah
Regent Santa Monica
Beach
Treasurer
Celia Fisher
Beach Moms
Vice-Chair
Dustin Peterson
Fairmont Miramar
Hotel & Bungalows
Vice-Chair
Dr. Kathryn Jeffery
Santa Monica College
Vice-Chair
Vee Gomez
Beach Yoga SoCal
Vice-Chair
Greg Morena
The Albright
Board Members
Dom Bei
SM Firefighters
Rudy Flores
SM Police Officers
Paula Larmore
Harding, Larmore,
Kutcher & Kozal LLP
Michael Altchule
UCLA Health
Board Continued
Eddie Guerboian
Jeweler
Neil Carrey
Attorney
Jeremy Rawitch
RAND
Elnie Vannatim
Cedars Sinai
Addie VanGessel
Tavern on Main
Gina Gribow
EKA Public Affairs
Jessica Rincon
Le Merigot Hotel
Florence Granteral
Fall
Neuehouse
Stephanie Eglin
Macerich
Lilit Avagyan
US Bank
Melissa Cohen
Boston Properties
Jenn Verma
Lionsgate
Ben Marcus
UP Partners
Elias Garcia
Kaiser Permanente
Yvette Sims
Hair by Yvette
Cheree
Judy Kruger
President & CEO
Charlie Lopez-Quintana
Chair of the Board of Directors
May 10, 2025
Santa Monica City Council
City of Santa Monica
1685 Main Street
Santa Monica, CA 90401
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2379 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 98 David Yakobson
From: [email protected]
Sent: Friday, May 9, 2025 11:19 PM
To: councilmtgitems; Barry Snell; Caroline Torosis; Dan Hall; Ellis Raskin; Jesse Zwick; Lana Negrete; Natalya Zernitskaya
Cc: [email protected]; Elaine Polachek
Subject: City Council 5/13 agenda item 12-A -- 3 concerns

EXTERNAL
May 9, 2025

To: Mayor Negrete and Councilmembers

From: Zina Josephs

RE: 5/13/25 agenda item 12-A

I oppose the following 3 staff recommendations and urge the Council to remove them from the action item:

1) "Elimination of 1-acre Administrative Approval threshold for housing projects."

After the Gelson's project (551 apartments in 12 5- and 6-story buildings) was approved ministerially (Administrative Approval), the City Council passed an ordinance requiring Council approval for projects on parcels larger than 1 acre. (The Gelson's parcel is 4 acres.)

This ordinance, as written, undoes that ordinance and would allow Administrative Approval of projects of any size, for example, in the 40-acre Santa Monica Business Park. There are no public hearings with the Administrative Approval process, only at the Architectural Review Board.

Around 500 residents participated in the second Gelson's Zoom call. (I was unable to get into the first Zoom call, which was limited to 100 participants.) Among the resident comments, Ms. Zernitskaya was one of the very few people who supported the project.

Imagine the uproar among residents if an even larger housing project went forward in the Business Park.

I urge you to maintain the 1-acre Administrative Approval threshold for housing projects.

2) "Removing the owner-occupancy requirement for lots splits and duplexes." -- This would be an invitation to out-of-town and out-of-state developers to buy up single family homes and make huge profits by building multiple housing units on R-1 parcels. As was noted in a recent opinion piece in the Santa Monica Mirror:
"SB9, a statewide law, was designed to expand opportunities for families to create moderate-income housing for relatives and friends, and to build wealth from their R-1 parcels. The author of the state law said at the time the law was passed that SB9 was focused on homeowners, affordable housing units, and multigeneration Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2380 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) 99 wealth creation by building equity from splitting R-1 lots into two parcels. Real estate developers and speculators were never part of the SB9 law.

The primary legislative tool to insure SB9 encouraged family development, not real estate speculation, is the owner occupancy requirement built into the SB9 law. That provision requires a homeowner to live in one of the newly built SB9 housing units as the homeowner’s principal residence for three years after approval of an SB9 lot split. According to the state Housing and Community Development (“HCD”) agency, owner occupancy also means that only a person who owns the lot, not a corporation, can use SB9’s streamlined city approval process. A corporate SB9 owner “cannot legitimately claim intentions of residing in one of the units as its principal residence since [corporations] do not physically reside anywhere.” Now, three City Councilmembers (Zwick, Zernitskaya, and Hall) propose to fundamentally change Santa Monica’s SB9 Ordinance, by “removing the owner-occupancy requirement for lot splits … and clarifying that vacant or demolished parcels… are eligible for lot splits…” Their resolution is currently on the City Council Agenda for the May 13, 2025, Council meeting. According to a Public Records Act request to the City, these two changes were recommended by Stephen Anderson, who is the corporate representative of the two SB9 developments in Santa Monica, proposed by Delaware corporations.

The Council should reject the suggested SB9 amendments. They are not good housing policy for the City and its residents. The amendments will instead allow out-of-state developers to build expensive multi-family units in R-1 zones. They will also boost the prospects of Mr. Anderson’s corporate SB9 projects in Santa Monica...." I urge you to maintain the owner-occupancy requirement for lots splits and duplexes.

3) Amending the Zoning Ordinance to upzone 2644 30th Street to "Neighborhood Commercial."

2644 30th Street is not located right on Ocean Park Blvd. -- it's a 2-story office building right behind the retail center with The Counter, Il Forno, Hurry Curry, and Crimson.

It's also right across 29th and 30th Streets from single family homes.

Thanks to the 6th Cycle Housing Element, "Neighborhood Commercial" on Ocean Park Blvd. is allowed 55 feet in height. With the state density bonus, this could possibly increase a building on 2644 30th Street to 85 feet in height, right across the street from single family homes.

The property owner's attorney told the Planning Commission that this zoning change was necessary so her client could re-rent office space in the building after it was vacated for remodeling.

If the property owner is indeed just trying to remodel the building, why not grant a "variance" for his current nonconforming usage of the property, instead of upzoning?

I urge you NOT to amend the Zoning Ordinance to upzone 2644 30th Street to "Neighborhood Commercial."

Thank you for your consideration.

Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

12.A.g
Packet Pg. 2381 Attachment: Written Comments [Revision 1] (6801 : Housing Updates and Ordinances) Administrative Approvals (Chapter 9.39):
• Add the following text to Section 9.39.020(A)(1)(c): "If, upon initial review of a project application, the Director or their designee finds that there is substantial evidence a project may have a specific, adverse impact upon the public health or safety (as those terms are defined by Government Code Section 655895.5), and there is no feasible method to satisfactorily mitigate or avoid the adverse impact, the project shall be ineligible for an Administrative Approval. Upon any such finding by the Director or their designee, the finding may be appealed to the Planning Commission. Alternatively, if not appealed, the project application may proceed pursuant to the Development Review Permit procedures in Chapter 9.40." • Note that Table 9.37.160 will need to be updated to reflect this change. • Add a sunset clause that specifies the amendments to Chapter 9.39 will terminate after five (5) years.

Definition of “Housing Project” (Section 9.52.020.1125):
• Delete the proposed new text in subdivisions (B)(2)(b) and (B)(3)(d), which discuss hotel uses, and instead add a new Subdivision (E) that says: “Unless otherwise consistent with and authorized pursuant to the Housing Accountability Act (Government Code Section 65589.5, as may be amended), a mixed-use development shall not qualify as a Housing Project if it includes the following uses:
a hotel, motel, bed and breakfast inn, or other transient lodging, except a portion of the project may be designated for use as a residential hotel, as defined in Section 50519 of the Health and Safety Code.”
ADU updates
• Update applicable portions of the code to state that an Accessory Dwelling Unit may be permitted up to 1,350 square-feet if it contains at least three bedrooms.

SB 9/SB 450 Owner Occupancy Requirement (Section 9.31.125(D)(6)):
• Replace the amended text with the following (note that existing text is not underlined, and our proposed amendments to the existing text are underlined):
"Occupancy. Property owner shall intend to live on one of the resulting parcels for three years following subdivision completion. For the purposes of this subdivision, "owner" shall include the beneficiary of a trust or any other individual with a beneficial fee interest in the property that will be subdivided pursuant to this Chapter.”
Item 12-A
May 13, 2025
Item 12-A
May 13, 2025

← All documents from this meeting