Agenda packet, first session — Santa Monica City Council, September 30, 2025 (part 11 of 14)

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Packet Pg. 2477 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) Model Codes State Agency
Amendments
Publication of
California Building
Standards Code
July 1, 2025
City of Santa Monica
Local Amendments &
AB 130
BFLS Commission
September 10, 2025
Staff Recommendation to
the Council
September 30, 2025
Adoption of
Ordinance
Adoption of
Resolution
File Amendments with
CA Building Standards
Commission
Prior to December 31,
2025
2025 California Building
Standards Code with the
City Amendments
becomes effective on
January 1, 2026
Local Jurisdictions shall Adopt CA Building Standards Codes 180 Days After Publication
• H&SC 17958 (State Housing Law) • H&SC 18941.5 (Building Standards Law) • H&SC 13869 (Fire Protection Districts) 2025 CALIFORNIA BUILDING CODE ADOPTION PROCESS
Item 10-A
September 30, 2025
Item 10-A
September 30, 2025

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Packet Pg. 2478 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) 9 2025 CALIFORNIA BUILDING STANDARDS CODE – LOCAL AMENDMENTS •Consistent with Council direction given at its
September 9, 2025, meeting, the City’s building and
fire code definitions for high-rise buildings will
become consistent with the Statewide high-rise
definition as set forth in Health & Safety Code
13210(b), as well as proposed new local
amendments related to home hardening and fire
safety.

Item 10-A
September 30, 2025
Item 10-A
September 30, 2025

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Packet Pg. 2479 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) 10 2025 CALIFORNIA BUILDING STANDARDS CODE – LOCAL AMENDMENTS • Adopting new Wildland-Urban Interface Code by reference • Buildings and structures located in the following areas shall maintain the required hazardous vegetation and fuel management: • All unincorporated lands designated as a State Responsibility Area (SRA). • Land designated as a High and/or Very High Fire Hazard Severity Zone by a city or local agency. • Land designated in a city or local agency ordinance as a wildland-urban interface (WUI) area.

SMMC Section 8.39 Wildland-Urban Interface Code
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September 30, 2025
Item 10-A
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Packet Pg. 2480 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) 11 SANTA MONICA FIRE HAZARD SEVERITY ZONES
Item 10-A
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Packet Pg. 2481 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) 12 2025 CALIFORNIA BUILDING STANDRADS CODE
Staff Recommendations:

1. Adopt a finding of no possibility of significant effect pursuant to Section 15061(b)(3) of the California Environmental Quality Act (CEQA) Guidelines;

2. Introduce for first reading the attached ordinance to adopt the 2025 California Building Standards Code and local amendments;

3. Adopt the attached resolution making findings of local climatic, geological and topographical conditions, as required; and

4. Instruct staff to file the adopted resolution and ordinance with the California Building Standards Commission following the second reading of the ordinance, but at least 30 days before the effective date of the Codes.

Item 10-A
September 30, 2025
Item 10-A
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Packet Pg. 2482 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) 13 2025 CALIFORNIA BUILDING STANDRADS CODE
QUESTIONS?
Item 10-A
September 30, 2025
Item 10-A
September 30, 2025

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Packet Pg. 2483 Attachment: PowerPoint Presentation (7111 : Adoption of 2025 California Building Standards Code) City Council
Report
City Council Meeting: September 30, 2025
Agenda Item: 11.A
1 of 11
To: Mayor and City Council
From: Jing Yeo, Director, City Planning
Subject: Off-site Affordable Housing Pilot Incentive Program Status Update Recommended Action
Staff recommends that the City Council:

1. Receive an update on the Emergency Ordinance establishing the Pilot Program for the City’s Affordable Housing Production Program (AHPP)

2. Provide direction to Staff on whether to terminate, extend, and/or amend the Emergency Ordinance.

Summary
On June 10, 2025, direction was provided that the City “establish a pilot program allowing market-rate housing projects more flexibility in how they provide affordable housing units off-site, while also allowing these housing projects to be eligible for density bonus, incentives/concessions, and modifications.” The purpose of this program was to incentivize market-rate housing projects that were entitled but not proceeding with building permits due to financial challenges in the development market.

On August 12, 2025, City Council approved the regulatory framework needed to establish the Off-Site Affordable Housing Pilot Program. The program allows approved market-rate housing projects to access several options for fulfilling the City’s affordable housing requirements as identified in the City’s Affordable Housing Production Program (AHPP), while simultaneously proceeding with construction of the market rate portion of the housing development. Participating projects would also be eligible for a local density bonus (which is not currently an option for new applications that choose to build affordable housing off-site) in an effort to expedite housing production in Santa Monica.

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Under the approved pilot program, developers of sites with already approved projects have three alternative options if they opt out of constructing on-site affordable units:
• Option 1 – Build market rate units first, deposit a gap financing amount of $150,000 per unit into an escrow account, and develop the required affordable units off-site within four years.
• Option 2 – Rehabilitate existing units off-site that are deemed uninhabitable and, if they’re not already, deed-restrict these rehabilitated units as affordable.
• Option 3 – Pay an in-lieu fee that will go to the city’s Housing Trust Fund for future affordable housing developments.

Based on City Council’s review of the proposed pilot program, the City established parameters that allowed up to 1,000 units to participate in the program, based on applications received prior to September 30, 2025. Concurrently, staff was also asked to return to Council after conducting outreach with affordable housing providers and further consideration of the program’s terms.

To that end, this report has been prepared to provide an update on the results of the pilot program to date. In addition, details related to the City’s outreach efforts (including feedback received from affordable housing providers, the Planning Commission, and from community members) are outlined for consideration. After considering this information, staff is requesting direction on whether to terminate, extend, and / or modify the terms of the offsite affordable housing incentive program.

Discussion
Program Status Update
Subsequent to adoption of the Ordinance, the City received six applications for the pilot

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program within the first week. These applications total 1,088 units, consisting of 916 market rate units and 102 affordable units as indicated in the table:

Project
Address (ENT)
Total
Units
# of
Previously
Approved
Market
Rate Units
# of
Previously
Approved
On-Site
Affordable
Units
# of
Revised
Market
Rate Units
Pilot
Program
Option
Chosen2
Option 1 OffSite PropertyOption 1 #
of Off-Site
Affordable
Units
Option 3
Project
SF
Option 3
Estimated InLieu Fee
1902 Wilshire
(23ENT-0156)
140 126 14 140 1 1333 7th St* 14 N/A -
1527 Lincoln
(23ENT-0161)
210 189 21 210 1 1143-1145 25th
St
21 N/A -
2501 Wilshire
(23ENT-0173)
170 153 17 170 1 1333 7th St* 17 N/A -
2025-2037
Wilshire
(23ENT-0178)
150 135 15 150 1 1333 7th St* 15 N/A -
1931 Wilshire
(24ENT-0183)
260 234 26 260 1 1143-1145 25th
St
26 N/A -
2906 Santa
Monica
(20ENT-0311)
88 79 9 88 3 N/A - 51,189 sf $2,247,708.99
Total 1,018 916 102 1,018 93
Of the six applications received, five elected to utilize Option 1 – Off-Site Affordable Housing, as follows:

1. 1902 Wilshire Blvd

2. 1527 Lincoln Blvd

3. 2501 Wilshire Blvd

4. 2025-2037 Wilshire Blvd

5. 1931 Wilshire Blvd
Two off-site affordable housing properties were identified for these projects, at 1333 7th Street and 1143-1145 25th Street. Both of these off-site properties are located outside of the Off-Site Affordable Housing Prohibition Area (which encompasses the Pico

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neighborhood) [defined in SMMC Figure 9.64.060.A] and are not encumbered with prior entitlements.

The last application received was for 2906 Santa Monica Boulevard, whereby the applicant elected Option 3 – Payment of In-Lieu Fees. Based on the floor area of this project, the City would receive approximately $2.2 million in-lieu of nine affordable units on-site. Payment of the fees would be required prior to the issuance of a building permit for the project.

A new website for the pilot program has been created and lists all applications received at https://www.santamonica.gov/status-of-development-projects (click on Status of Offsite Affordable Housing Pilot Program). These six eligible projects have until their entitlement expiration dates (ranging between July 2027 to December 2028) to pull their building permits for construction. Also, as required under the newly adopted pilot program, upon the issuance of the building permit for the first market rate project, the project applicant would have 48 months (with a possible 12-month extension) to pull a building permit for the off-site affordable housing.

As the total 1,000-unit cap has been reached with the submittal of the six applications, the pilot program is no longer available to other projects unless the Ordinance is amended and extended.

Public Comments Received
Following Council direction, staff invited affordable housing providers to a virtual workshop on the AHPP. On September 17, 2025, the City hosted the workshop to solicit input from representatives of the following providers:
• Community Corporation of Santa Monica
• Hollywood Community Housing

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• EAH Housing
• Thomas Safran & Associates
• Venice Community Housing
• Abode Communities
All of the housing providers were generally in favor of the pilot program and its overall intent in providing flexibility to meet the City’s AHPP requirements. However, there were concerns regarding the implementation of the program, particularly as to the offsite affordable housing option (Option 1).

Participants in the discussion brought up the following:
• Eligibility of At-Risk Units: Potential for expanding Option 2 to include affordability for at-risk units (i.e., affordable-deed restricted units with covenants at risk of expiring (e.g. at year 55) and converting to market rate) • Moderate Income Housing
o Potential for expanding Option 1 to allow for moderate income units (or similar housing type such as workforce housing) for projects that do not utilize tax credits
o Potential for allowing fees collected from Option 3 to be used to fund moderate income units
• Option 1 Gap Financing: Overall concern that estimated gap financing amount of $150,000 is too low. Based on past projects, participants indicated that the gap financing amount does not appear to be sufficient when assuming 4% tax credits.

This means that additional funding sources could still be necessary to construct the affordable housing project.

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• Competition for Financing: Concern that the program could add more competition into an already competitive financing landscape and concern about how competitive these developments would be without the public subsidy leveraging points from TCAC.

Staff also received written public comments from Santa Monicans for Renters’ Rights (SMRR). The comments generally focused on creating more certainty around the construction of the required affordable units. Some of the key recommendations are as follows:
• Require Completion of Milestones for Off-Site Affordable Housing: Require new milestones to be achieved before issuance of a building permit and the Certificate of Occupancy for the market-rate housing to provide greater assurance that the off-site affordable housing project will be constructed. These milestones for the off-site affordable housing may include requirements such as submittal of an entitlement application, plan check submittal, construction contracts, and tax credit application.
• Increase Option 1 Gap Financing: Increase the gap financing amount for Option 1 of the program. SMRR states that the $150,000 per unit gap financing amount is not sufficient as it does not account for construction cost escalation, provision of on-site parking, accurate unit sizes, and prevailing wage requirements (should the developer fail to construct the off-site affordable housing and the City exercises its option agreement to receive the gap financing and land).
• Increase Option 3 In-Lieu Fee: SMRR indicates that the fee is not sufficient to fully cover the cost of constructing an affordable unit. Therefore, the in-lieu fee should be adjusted to reflect the actual cost of construction.

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The Planning Commission also held a discussion on the pilot program at its meeting on September 17 and was broadly supportive of the program. The Commission voted 7-0 to advise Council on suggested minor amendments to the program, as follows:
• Extend the pilot program to the end of the 6th Cycle Housing Element period, at which point the program could be re-evaluated to ensure that it is not overly expansive.
• Allow the pilot program to include moderate income units. • Actively monitor the progress and success of the pilot program.

Next Steps and Council Policy Questions
The purpose of the pilot program developed was to allow market-rate housing projects more flexibility in how they provide affordable housing units off-site, as a means to incentivize and spur overall housing production levels for approved market rate projects that were unable to proceed due to economic uncertainty.

Of note, this goal as articulated through the way the offsite affordable housing incentive program was developed diverges from the stated goals of certain community organizations, who have asked that the City prioritize the production of affordable housing units. It should be recognized that the two goals may be in conflict where a policy of increasing affordability requirements could result in less ability to develop market rate housing through decreased financial feasibility and / or increased risk for securing commercial financing.

Based on community input and recognizing the potential conflicts between incentivizing market rate housing development and securing developer funded affordable housing, staff is seeking further Council direction on the following:

Policy Question 1: Extension of Program
Background: As the total 1,000 unit cap has been reached with the submittal of the 6

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applications, the pilot program is no longer available to other approved projects.

There are approximately 30 housing projects representing approximately 3,000 housing units that could be eligible for the program.

Question:

Should the program be extended beyond the 1,000 unit cap that was established on August 12?
➢ Yes, continue the program and allow additional market-rate projects approved as of August 12, 2025 to utilize this program
➢ No, do not continue the program.
➢ Alternatively, continue the program and establish a new cap or other limit for the program.

Policy Question 2: Expansion of Option 1 to Allow Moderate Income Units Background:

Public comments were received that the program should be flexible to allow for the construction of moderate (and / or workforce units) in the off-site affordable housing if a developer elects to not utilize tax credit funding.

Question:

Should Option 1 be modified to allow moderate units?
➢ Yes, the ordinance would be amended to require that off-site affordable units be deed-restricted for lower income or moderate income households. ➢ No, the ordinance would continue to require that off-site affordable units only be for lower-income households.

Policy Question 3: Option 1 Milestones
Background:

There is general concern in written public comments that the program does not provide enough assurance that the off-site affordable housing will be constructed through sufficient requirements and milestones.

Question:

Should permitting milestones for the off-site affordable housing project be required for Option 1?
➢ Yes, the ordinance would be amended to establish milestones that may include:
o Prior to building permit for the first market rate project, require submittal of a complete entitlement application for the off-site affordable housing project
o Prior to Certificate of Occupancy for the market rate project, require that the plan check process for the off-site affordable housing project be completed. The City could also include a provision for expedited, priority

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process of off-site affordable housing projects to ensure that delays are not attributable to the City.
o Allowing the City to exercise its option on the off-site property, draw down on the gap financing, and receive an assignment of architectural and construction plans for the off-site housing development early if the developer does not complete the plan check process within a certain timeline of pulling a building permit on the market rate project ➢ No, the timeline requirements for the off-site affordable housing project would remain unchanged.

Policy Question 4: Option 1 Gap Financing Amount
Background:

Public comments were received that the gap financing amount of $150,000 per unit is too low to cover the gap for the off-site affordable housing. Comments point out that this is particularly true if the land is given to the City (in a situation where construction of the off-site affordable housing has not commenced within required timelines) and the affordable housing project then becomes a prevailing wage project that also includes on-site parking. Increasing the gap financing amount is a Council policy decision and would increase the costs to the market rate project that could potentially jeopardize feasibility.

Question:

Should the gap financing amount be modified?
➢ Yes, the gap financing amount should be increased. If increased, what amount should be established? If there is interest in feasibility considerations, staff can also return to Council with additional analysis on the gap financing amount by adjusting assumptions regarding on-site parking and unit types and providing information regarding the effect of prevailing wages. ➢ No, the gap financing amount of $150,000 per unit as currently established in the ordinance would remain unchanged.
➢ Alternatively, keep the gap financing amount at $150,000 per unit but remove the 5% annual cap on escalation and replace with the requirement that the amount would be reviewed and updated annually by Council resolution, based upon the construction cost index.

Policy Question 5: Expansion of Option 2 (Rehabilitation) to Include At-Risk Units
Background:

Public comment was received that the program should be expanded to allow deed restricted units with affordability covenants that are set to expire and are at-risk of market rate conversion.

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Question:

Should Option 2 be expanded to include At-Risk units?
➢ Yes, the ordinance would be amended to include At-Risk units. ➢ No, no changes to the ordinance would be made. At-Risk units would not be covered.

Policy Question 6: Option 3 In-Lieu Fees
Background:

Public comments were received that the in-lieu fee is too low to fully cover the cost of constructing off-site affordable units. An updated nexus study would likely be required to establish what the new in-lieu fee should be. Additionally, the City would also need to conduct feasibility analysis to determine impacts on market rate projects. Council should be aware that establishing a fee that is too high may undermine the feasibility of this option.

Question:

Should the in-lieu fee payment be modified?
➢ Yes, the in-lieu fee should be modified. If modified, a new nexus study would be required. The nexus study would require cost and time, estimated at several months.
➢ No, the in-lieu fee would remain unchanged (only modified annually according to construction cost index).

Minor Correction
If the ordinance is extended, Staff has identified the following necessary correction to Section 9.64.065(D)(3) of the ordinance. This correction addresses requirements for the off-site affordable housing project, which are typically determined by the funding source:

Requirements for Affordable Units. The affordable units in the 100% affordable housing project shall be rental units and shall comply with the provisions of subsections (E)(2)-(5) of Section 9.64.050, unless modified pursuant to Section

9.64.065(G).

Environmental Review
The ordinance for the pilot program has been analyzed as part of the 2021-2029 6th Cycle Housing Element Environmental Impact Report (EIR) [SCH No. 20212269242021] that was certified by Council on October 12, 2021, with an Addendum to the EIR approved on October 11, 2022. These amendments implement

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Program 2.C that was described and analyzed in the 6th Cycle Housing Element EIR.

Additionally, pursuant to Section 21080.085(a) of the California Public Resources Code, the ordinance is statutorily exempt from CEQA. Under PRC Section 21080.085(a), CEQA does not apply to actions contained in an approved housing element pursuant to subdivision (c) of Section 65583 of the Government Code. The ordinance implements the certified 6th Cycle Housing Element. Therefore, the ordinance is statutorily exempt and no further environmental review under CEQA is required.

Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of the ordinance. Staff will return to Council if specific budget actions are required in the future.

While the program will require extra staff time to implement, no new staff are being requested at this time and it is anticipated that the workload can be accommodated by staff. Since this is a pilot program, staff will monitor the workload and return to Council if any changes to staff is necessary. The effect of additional in-lieu fees on the City’s Housing Trust Funds is unknown and will be dependent on which eligible projects elect to utilize Option 3 of the pilot program.

Prepared By: Rachel Kwok, Environmental Planner
Approved Forwarded to Council
Attachments:

A. Written Comments
B. PowerPoint Presentation

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1 David Yakobson
From: Marc Grobman <[email protected]>
Sent: Monday, September 29, 2025 1:44 PM
To: councilmtgitems
Subject: Support and Improve Off-site Affordable Housing Program Council Comments Council Comments,
Councilmembers,
I support Santa Monica Forward's position on how to extend the Off-site Affordable Housing Pilot Program.

The off-site program has been an early success with more than 1,000 units applying to use it.

Please build on that momentum.

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements

2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Question 1: Alternative: The city should remove the cap on the number of units or projects that can use the program, and should open the program to new applicants (not yet entitled projects), with no defined end date.

The city should not impose limitations that run against AFFH, such as restricting projects to downtown. Limiting affordable projects to outside the Pico neighborhood does not conflict with AFFH, and is appropriate.

The city policy, including the off-site program, should facilitate the financial feasibility of market rate development. Requirements and costs that lead to projects stalling must be eliminated.

Further, the city should regularly re-evaluate whether new housing is financially feasible under current rules and adjust policy.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

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Packet Pg. 2495 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 Question 3: Yes on accountability measures so long as they do not impact project feasibility.

Question 4: No: The $150,000 Gap Financing amount should not be increased.

Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford).

Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot.

Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab). However, more clarification on the result of supporting Option 2 is needed to understand what the resulting offsite projects would entail, and how that would compare to the city’s current onsite housing policy.

In summary, it is crucial that city council extend the off-site affordable housing ordinance into an ongoing and open program without changes to cost or accountability requirements that would stop new housing.

Thank you!
Marc S. Grobman
2611 25th Street
Santa Monica, CA 90405
Marc
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2496 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, September 30, 2025 12:00 PM
To: councilmtgitems
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica. Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Regards,
Nikki Kolhoff
Santa Monica Resident
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2497 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Peter Mezza <[email protected]>
Sent: Tuesday, September 30, 2025 12:47 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Peter Mezza
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2498 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: SALLY STINER <[email protected]>
Sent: Tuesday, September 30, 2025 1:51 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely, sally. STINER
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2499 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: Christina Ford <[email protected]>
Sent: Tuesday, September 30, 2025 4:59 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Christina Ford
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2500 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: TROY PARR <[email protected]>
Sent: Tuesday, September 30, 2025 5:02 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: 9/30/25 Agenda Item 11-B - Continue Support for Neighborhood Organizations

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
As a member of Friends of Sunset Park (FOSP), I urge you to continue the current Neighborhood Organization Grant Program.

FOSP uses the annual $7,000 grant for mailing an annual membership appeal letter to all 7,800 residences in our neighborhood. (Before the 2020 restructuring, the City used to mail the letters. The $7,000 grant replaced that service.)

Membership forms include a section for members to list their concerns which help determine priorities for the FOSP Board.

At monthly FOSP Zoom meetings, everyone is encouraged to share comments and questions. Our Beat 2 NRO and Crime Prevention Coordinator participate in every meeting.

Informative weekly FOSP emails include city announcements, a calendar of meetings and other events, and a list of articles in local newspapers from the previous week.

Community events this year have included an FOSP general membership meeting at Clover Park, the FOSP Beach Towel Drill Team marching in the 4th of July Parade on Main Street, FOSP tabling at National Night Out, and FOSP co-sponsoring with local businesses “A Sunset Park Block Party: Art in the Alley” behind Bob’s Market.

Again, I urge you to continue the current Neighborhood Organization Grant Program.

Sincerely,
Troy Parr
90404
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2501 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: John Lin <[email protected]>
Sent: Monday, September 29, 2025 1:41 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants Council Comments Council Comments,
Councilmembers,
The upcoming decision on how to extend the Off-site Affordable Housing Pilot Program is a crucial opportunity to address our housing crisis. The consideration of this policy should be viewed through the lens of broader principles in addressing our housing crisis. This letter sets out those principles & their application to specific policy questions the Council faces, as posed by the staff report. The off-site program has been an early success with more than 1,000 units applying to use it. Council should build on that momentum and the excitement that will be created by seeing projects get started by opening the program to new developers, while avoiding any changes which would increase costs or otherwise undermine pro-housing goals.

1. To address our housing crisis, Santa Monica needs significantly more housing than our RHNA goals requires, and the city must affirmatively further fair housing. This implies:
a) Question 1: Alternative: The city should remove the cap on the number of units or projects that can use the program, and should open the program to new applicants (not yet entitled projects), with no defined end date.
b) The city should not impose limitations that run against AFFH, such as restricting projects to downtown. Limiting affordable projects to outside the Pico neighborhood does not conflict with AFFH, and is appropriate.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2502 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

However, more clarification on the result of supporting Option 2 is needed to understand what the resulting offsite projects would entail, and how that would compare to the city’s current onsite housing policy.

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements

2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2503 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 5. Yes

6. No
John
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2504 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Hajar Muqtasid St. Claire <[email protected]> Sent: Tuesday, September 30, 2025 11:58 AM
To: councilmtgitems; councilmtgitems; Lana Negrete; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick; Barry Snell; Ellis Raskin; Dan Hall
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE! Dear Mayor Negrete and City Councilmembers, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program inc...

EXTERNAL
Hajar Muqtasid St. Claire
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2505 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: [email protected]
Sent: Tuesday, September 30, 2025 9:11 AM
To: councilmtgitems
Cc: Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; [email protected]; Lana Negrete; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Sincerely,
Vanessa McCarthy
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2506 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Cathy Larson <[email protected]>
Sent: Tuesday, September 30, 2025 10:12 AM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Santa Monica needs affordable housing now.

Why would the City encourage and “giŌ” developers to delay their obligaƟons to build affordable housing? Many of you ran for office on plaƞorms that included supporƟng affordable housing. This proposal is NOT in line with that posiƟon.

Cathy Larson
Sunset Park resident
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2507 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Lmkmanning <[email protected]>
Sent: Tuesday, September 30, 2025 10:15 AM
To: councilmtgitems; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Lana Negrete; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers:

I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Sincerely,
Linda Manning
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2508 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: lmarreola <[email protected]>
Sent: Tuesday, September 30, 2025 10:29 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Larry and Carol Arreola
Sent via the Samsung Galaxy S21 5G, an AT&T 5G smartphone Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2509 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: Alison Warner <[email protected]>
Sent: Tuesday, September 30, 2025 10:38 AM
To: councilmtgitems; Lana Negrete; Jesse Zwick; Ellis Raskin; Caroline Torosis; Natalya Zernitskaya; Dan Hall; Barry Snell
Cc: Ross Fehrman; Jing Yeo; Oliver Chi; Paula Larmore; Joe Fahey Subject: Letter in Support of Agenda Item 11.A AHPP Pilot Program Extension

EXTERNAL
Dear Councilmembers,
I am writing on behalf of SanMon Inc, the owner of 2601 Lincoln Boulevard, to urge the Council to extend the AHPP Pilot Program to all approved but not yet constructed housing projects. In particular, we urge the Council to extend Option 3 (in-lieu fee) with no increase to the already high $43.91/square foot fee (beyond the annual escalation adjustments already built into the fee).

The current economic and regulatory environment in Santa Monica makes it extremely difficult to move forward with redevelopment of commercial properties with new multi-family housing projects. As most of the economic factors are beyond the City’s control, we appreciate the City looking to modify its regulatory environment to “unstick” the pipeline of approved projects. As we engage with potential development partners, the AHPP pilot program offers valuable flexibility for meeting the project's affordable housing requirements, making housing development on our site more feasible.

Based on the City’s successful track record of disbursing its Affordable Housing Trust Fund, we recognize these fees are not intended to fully cover the cost of constructing an affordable housing project. Rather, affordable housing developers have the unique ability to leverage these funds to attract additional financing from state and federal sources. The fee from our project alone would be approximately $18,000,000 or more. This would represent a significant contribution to increasing affordable housing in the City.

The per square foot in-lieu fee is already high and, from a proforma perspective, is not necessarily a better financial outcome for the project than providing the affordable units on-site. However, the certainty of being able to pay a fee and convert the on-site affordable units to market-rate units could make a difference to the project feasibility. This option broadens the available pool of investors and lenders thus increasing the likelihood of the approved project getting built. If the in-lieu fee were to be increased above the current almost $44/sf, the practical result would likely be the elimination of Option 3 as a viable choice altogether.

Overall, absent elimination of Measure GS (which we know the Council could not do alone), extending the AHPP pilot program as is one of the most impactful modifications that the City can make to try to incentivize approved projects like ours to move forward to the building permitting and construction stages. We appreciate both Staff and Councilmember efforts to help make housing development projects more feasible. We encourage City Council to provide Staff the direction to extend the AHPP Pilot Program, including Option 3 with no increase to the in-lieu fee.

Thank you,
Alison Warner
(o) 310 496 4145 | (c) 310 903 9857 | [email protected] Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2510 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 6 11611 San Vicente Blvd, Suite 900, Los Angeles, CA 90049 www.balboaretail.com
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2511 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 7 David Yakobson
From: Dan Kolhoff <[email protected]>
Sent: Tuesday, September 30, 2025 10:57 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Dan Kolhoff
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2512 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 8 David Yakobson
From: Tracey Hom <[email protected]>
Sent: Tuesday, September 30, 2025 11:00 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2513 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 9 David Yakobson
From: Karen Croner <[email protected]>
Sent: Tuesday, September 30, 2025 11:16 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. It is absolutely a move toward segregation. And of course you will be sued for this, which this city simply can’t afford. And of course this decision will receive massive media attention as the city will be seen as choosing economic discrimination so that developers can make more money.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Karen Croner
90405
Karen Croner
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2514 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 10 David Yakobson
From: Connor Webb <[email protected]>
Sent: Tuesday, September 30, 2025 11:25 AM
To: councilmtgitems; Jesse Zwick; Lana Negrete; Caroline Torosis; Natalya Zernitskaya; Barry Snell; Ellis Raskin; Dan Hall
Subject: 11.A- Extend and Open Off-site AH Program to New Applicants

EXTERNAL
Dear Council,
The decision to extend the Off-site Affordable Housing Pilot Program is an essential part of addressing our dire housing crisis. This policy should be considered within broader principles for addressing our housing crisis. This letter sets out those principles & their application to specific policy questions posed by the staff report. The off-site program has been an early success with more than 1,000 units applying to use it. Council should build on that momentum and the excitement that will be created by seeing projects get started by opening the program to new developers, while avoiding any changes which would increase costs or otherwise undermine pro-housing goals.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2515 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 11 c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing inlieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced.
d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab). However, more clarification on the result of supporting Option 2 is needed to understand what the resulting offsite projects would entail, and how that would compare to the city’s current onsite housing policy.

This council was elected on the basis of being pro-housing, and this an opportunity to demonstrate effectiveness in that pledge.

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements

2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Thank you,
Connor Webb
90404
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2516 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 12 David Yakobson
From: Sarah Gallagher <[email protected]>
Sent: Tuesday, September 30, 2025 11:30 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Sarah Gallagher
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2517 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 13 David Yakobson
From: Ria McVeigh <[email protected]>
Sent: Tuesday, September 30, 2025 11:39 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Katrina McVeigh
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2518 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 14 David Yakobson
From: Nancy Hicks <[email protected]>
Sent: Tuesday, September 30, 2025 11:51 AM
To: councilmtgitems
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Nancy Hicks
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2519 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 15 David Yakobson
From: Soloff, Michael <[email protected]>
Sent: Tuesday, September 30, 2025 11:48 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Cc: [email protected]; SMRR - Santa Monicans for Renters' Rights; Patricia Hoffman Subject: Agenda Item 11.A (9.30.25 City Councill Meeting) Attachments: SMRR Comments on Item 11A.pdf

EXTERNAL
Please find attached the comments of Santa Monicans for Renters’ Rights regarding Agenda Item 11.A on tonight’s City Council Agenda. PLEASE BE SURE TO PRINT THE ATTACHMENT AND INCLUDE IT IN THE PUBLIC COMMENTS. Thank you.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2520 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) September 30, 2025
To: Santa Monica City Council
Re: 9.30.25 Agenda Item 11A—AHPP Offsite Pilot Program
Dear Councilmembers:

On September 18, Santa Monicans for Renters’ Rights sent to the City Manager and to each of you the attached memorandum analyzing the Offsite Option and the In-Lieu Fee Option in the AHPP pilot program adopted on August 12. These are the only two options for which applications have been received to date. SMRR’s memorandum demonstrated that—as currently drafted—the Offsite Option exposes the City to substantial timing and financial risks with respect to creation of the offsite affordable housing, and makes a series of recommendations for mitigating those risks to acceptable levels. That memorandum further demonstrates that the particular in-lieu fee figure incorporated into the pilot had had no conceptual relevance to the issue at hand when first created, and that the updating of that original figure over the last 20 years had not kept pace with actual increased costs. It also explains how the City could approach constructing a conceptually relevant in-lieu fee. The memorandum further explains SMRR’s views on the conditions for and the limits of an appropriate expansion of the pilot program.

In this cover letter, SMRR briefly responds to the comments provided to Council by Cyress Equity (“CE”) regarding SMRR’s recommendations to improve the offsite option, and regarding potential expansion of the pilot. SMRR also briefly responds to the Staff Report.

1. Offsite Option Timing Risk: CE does not dispute SMRR’s suggestion that milestones be added for the offsite affordable project (“OAP”) to assure timely progress is being made toward creation of the OAP. Indeed, CE offers some suggested milestones both for steps to obtain entitlements for the OAP, and for steps to obtain the tax credits without which the OPA will never be built.1 Staff likewise offers some potential milestones for obtaining entitlements. 2 1
“Reasonable milestones would be (i) submission an entitlement package for the affordable project within 6 months of applying for the IZO, (ii) submission of a funding request to CDLAC and TCAC within 6 months of receiving building permits for the affordable project, and (iii) if funding is not initially awarded, funding requests must be resubmitted in every subsequent funding round that the project is eligible for. ”
2 “Prior to building permit for the first market rate project, require submittal of a complete entitlement application for the off-site affordable housing project[.] Prior to Certificate of Occupancy for the market rate project, require that the plan check process for the off-site affordable housing project be completed. The City could also include a Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2521 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) SMRR agrees with CE that the milestones should cover both obtaining entitlements, and obtaining tax credits. SMRR also believes that the milestones should include commencement of construction following entitlements and tax credits.

What CE does object to is the imposition of consequences on the market rate developer if the OAP milestones are missed, suggesting instead a right of the City to replace the OAP developer.3 Staff, on the other hand, proposes as possible consequences that (1) submission of entitlement package be a condition for the market rate project (“MRP”), (2) that completion of the plan check be a condition of the certificates of occupancy for the MRP (including a provision of priority for the OAP plan check to assure City does not cause delay), and/or (3) that the program should “[a]llow[] the City to exercise its option on the off-site property, draw down on the gap financing, and receive an assignment of architectural and construction plans for the off-site housing development early if the developer does not complete the plan check process within a certain timeline of pulling a building permit on the market rate project.” SMRR supports adoption of Staff’s first two suggestions, absent some compelling showing that they are not practical. SMRR also supports Staff’s third suggestion (which appears to be the same as CE’s suggestion) for all other milestones (not just for plan check completion) IF BUT ONLY IF the financial risks of completing the OAP under these circumstances are properly mitigated (as discussed below). If those risks are not properly mitigated, then some other mechanism is needed to assure that tax credits and construction commencement milestones are met.

2. Offsite Option Financial Risk: CE purports to dispute SMRR’s showing that the only two methodologies disclosed to the public for validating the $150k gap financing amount— Staff’s analysis of the gap financing provided to prior completed City funded tax credit projects, and HR&A’s review of a confidential pro forma submitted (presumably by CE) for a tax credit project—are insufficient to validate that figure as sufficient. But CE’s response actually reinforces SMRR’s point. In particular, CE essentially repeats that HR&A found that an OAP with a certain mix of one and two bedroom units, with no parking and no payment of prevailing wages, today would involve a gap financing amount of ~$150k. However, as explained in the SMRR memorandum, (1) Council has not yet said that the only type of OAP it wants built under the AHPP pilot is that specific type, (2) no one has shown that if the City does have to take the project away, that it does not trigger a prevailing wage requirement (which CE acknowledges would make the $150k grossly inadequate), and (3) no one has shown that prevailing wages will have to be paid if the City has to provide additional gap financing (either because it turns out $150k actually is not enough today, or because the limit on pre-escrow deposit of the gap financing amount to 5% per year and/or because the interest available in escrow is less than the increase in construction costs—both of which are very real risks when construction costs have risen 50% over the last five years). Thus, CE has not refuted SMRR’s showing of substantial financial risk to the City with respect to completion of the OAP. provision for expedited, priority process of off-site affordable housing projects to ensure that delays are not attributable to the City.”
3 “If milestones are not met, the City should have the option to redirect the land and funds in escrow to a different affordable partnership that can hit its milestones.” Item 11-A
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Packet Pg. 2522 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) CE also objects to SMRR’s two recommendations to mitigate this financial risk. First, CE states that SMRR recommended prepayment of the GS tax that will come due on sale of the market rate project. But SMRR did not recommend that. SMRR recommended that—just as the City recently required of RAND Corporation—the City should require pilot participants to agree that in the event the GS is not applicable to the sale of market rate project based on changes in the law, they still will pay the equivalent amount to the GS Homelessness Prevention and Affordable Housing Fund. This provides significant mitigation of the financial risks identified above, as the City will be assured of affordable housing funds if it becomes necessary to supply additional gap financing. And given that the City is acting to facilitate the market rate projects “penciling out” with the GS tax in place, there is no reason to allow the market rate developers to earn a windfall if various political efforts to limit the GS tax somehow succeed before the market rate projects are sold.

Second, CE asserts that SMRR recommended that the gap financing amount be increased to $240k. But SMRR did not recommend that. SMRR merely showed that City Staff’s methodology using gap financing in prior City funded projects—if applied to more recent data— indicated a gap financing amount of at least $240k (and probably more). The proper gap financing amount is for the City to establish, and depends upon the nature of the OAP City Council expects, the risks associated with increasing construction costs, and the risks of paying prevailing wages should the City have to exercise its options and/or add more gap financing.

Finally, CE does not dispute that—as currently written—the City loses its option on the land and the escrowed funds once construction of the OAP begins. CE states that SMRR said the escrow must continue, and objects to that as unnecessary given other security put in place at that point by persons other than the City. But SMRR never said that the escrow must continue. Rather, SMRR stated:
real security for completion of the OAPs must continue past the time building permits are pulled and construction begins. The City is better positioned than SMRR to determine whether this continuing security should be a continued option and construction escrow, a requirement of completion bonding, and/or some other form of security.

In short, SMRR believes it is essential that the City require a commitment to pay into the Homelessness Prevention and Affordable Housing Fund the equivalent amount to the GS tax on the sale of the market rate project in the event the GS tax no longer applies at that time. The City also needs to provide more transparent and convincing support for the gap financing amount. Further, if the City can verify CE’s assertions of adequate security from other sources for completion of construction of the OAP once it begins, SMRR will be satisfied on that point.

3. In-Lieu Fee Option: CE does not address the in-lieu fee option. Staff states that a new nexus study is required to alter the in-lieu fee for the pilot. SMRR understands that nexus studies are required for impact fees / exactions that are based on mitigating costs imposed by a project. That is not what is at issue here—instead, this is about an alternative to satisfying the AHPP through onsite affordable units. Any in-lieu fee in this context should represent what it will take actually to produce through other means the affordable units that the developer otherwise would have had to produce onsite (with some credible plan as Item 11-A
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Packet Pg. 2523 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) to how the City intends to otherwise create those units). Once that figure is known, it could be adjusted downward if the City wants to encourage payment of such fees in connection with a specific, immediate need for such funds to further concrete affordable housing plans.

4. Other Options: Staff has raised the possibility of extending the pilot program to include offsite moderate housing, and to allow some way of preserving affordable units at-risk of conversion to market rate units. SMRR believes that the City should first concentrate on correcting deficiencies in the offsite option and the in-lieu fee option before looking at other changes (none of which have been sufficiently explained, with enough time for SMRR and other members of the public—or Council—to adequately evaluate). These suggestions should be tabled for now.

5. Pilot Expansion: SMRR recommended that—if its other recommendations are adopted to improve that AHPP pilot, and if other conditions are met relating to City need to act immediately and City verification that it would not interfere with the recent public land Notices of Availability and responses received—the City could expand the pilot to all downtown approved projects or, if that does not put the City in a position to meet its market-rate target for the 6th RHNA Cycle, the additional units outside the downtown needed to put the City in that position.

CE asserts that there is not a competition problem given the size of the 4% program, and that projects should be allowed to go forward outside downtown. SMRR believes only Staff knows what is occurring with respect to the Notices of Availability and the responses, and therefore only Staff can provide the required assurance regarding competition for credits.

The fact that there are many credits does not answer the question, given that the program is oversubscribed already. SMRR also believes that a pilot program logically is limited in scope. SMRR further believes the biggest financial benefit to the City is from more housing in the downtown.

Thank you for considering our views on these important matters.

Sincerely,

Denny Zane Mike Soloff
Co-Chair, Santa Monicans for Renters’ Rights Co-Chair, Santa Monicans for Renters’ Rights Item 11-A
September 20, 2025
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Packet Pg. 2524 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) September 18, 2025
TO: Oliver Chi, Santa Monica City Manager
CC: Santa Monica City Council

SMRR ANALYSIS OF CURRENT AHPP PILOT PROGRAM
I. INTRODUCTION AND SUMMARY
As SMRR stated (in part) in its June 10, 2025 letter to City Council (italics in original):

We are writing to express the support of Santa Monicans for Renters’ Rights (“SMRR”) for development of a pilot program to allow greater flexibility in how market-rate housing projects contribute to the creation of deed-restricted affordable housing units in Santa Monica in order to create more affordable housing than that which otherwise will occur under the existing requirements of the State Density Bonus Law (“SDBL”) and Santa Monica’s Affordable Housing Production Program (“AHPP”). . . . The City then should present its proposal and supporting analysis to the relevant Commissions and the public well in advance of any City Council adoption of the proposed pilot program. If properly designed and justified, the City Council then should authorize a true pilot program of limited size to test in the real world the assumptions underlying the supporting analysis.

At the August 12, 2025 City Council meeting, SMRR expressed its deep concern that an AHPP pilot program had been agendized for that meeting, before there had been a meaningful opportunity for SMRR and other members of the public to review and comment on the proposed pilot terms. City Council nevertheless adopted the pilot program to proceed for up to 1000 units selected on a first-come-first served basis. But the City Council also directed that the matter return at the September 30, 2025 City Council meeting for consideration of potential amendments to the program.

Staff advises that after that meeting, the City received the following applications (and stopped accepting new applications):

Item 11-A
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Packet Pg. 2525 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) SMRR now has completed its review of the AHPP pilot program’s offsite option and in-lieu fee option (the only two options selected by the initial pilot program applicants). Based on that review, SMRR believes that the current terms of the pilot program do not properly serve the goal of creating more affordable housing. However, SMRR also believes that with appropriate improvements, the pilot program could serve that goal—resulting in a win-win for the City and developers—and therefore should move forward under those improved terms. In particular:

1. With respect to the offsite option, the current pilot program terms impose too great a risk that the offsite affordable housing project (“OAP”) will not be built for a very long time. This both undermines one of the potential value propositions of the pilot (delivery of currently frozen affordable units sooner), and increases the financial risk to the City (due to increases in construction costs over time outpacing any potential escalator on the amount that must be deposited into escrow and/or the rate of interest earned on the escrowed funds after deposit). To mitigate this risk, the pilot program should be amended to require the developer to meet various milestones along the path to commencement of construction of the OAP (e.g. hiring professionals to prepare plans for the OAP, submitting them for approval by the City, applying for tax credits, hiring contractors, etc.). Any step that is supposed to be completed under the timeline before the time the developer seeks the Certificates of Occupancy (“COOs”) for the market rate project (“MRP”) should have to be completed before the COOs for the MRP are issued. And, with respect to any step that is supposed to be taken after the COOs for the MRP in fact are issued, there should be a financial penalty for failing to timely take those steps.

Note that this would not undermine the financial certainty that Staff told the City Council at the August 12, 2025 meeting is required by the developers to move forward at this time with their projects. This is because the foregoing proposals do not impose any penalty for things that are beyond the developers’ reasonable control, such as either the failure of the California Tax Credit Allocation Committee (“CTCAC”) to grant a properly submitted tax credit application, or escalations in the cost of construction while the OAP is in the pre-development phase.

2. Also with respect to the offsite option, the current pilot program terms impose serious financial risk to the City. This is for a variety of reasons, including that the $150k per unit “gap financing amount” appears significantly lower than what it will take today to complete Item 11-A
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Packet Pg. 2526 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) the OAP even with 4% tax credit financing, and that this inadequacy will only grow over time if construction costs rise faster than 5% cap on pre-deposit escalation of the amount and then faster than the interest that can be collected on the escrow until construction begins (just as they have done over the past five years).

In particular, whatever merit the mode of analysis Staff applied to prior City funded affordable housing projects may or may not have for the question at hand, application of that same methodology to much more recent data points indicates that a much higher gap funding amount will be required (a minimum of $240k). These data points include the 4% tax credit application for the Venice Community Housing Corporation (“VCHC”) project on 20th Street that was approved by CTCAC in August of 2024; the pro forma shared by Hollywood Community Housing Corporation (“HCHC”) with City Staff to support the revisions to the 14th Street public land and 4% tax credits project that City Council approved in December of 2024; and the 9% tax credit application for the HCHC Euclid Street public land project that was approved by CTCAC in June of 2025, and then resubmitted by HCHC in July 2025 after the original tax credit award was declined due to uncertainty generated by the CEQA lawsuit over the project.

Moreover, the HR&A analysis of the single pro forma presented to it by a developer does not appear to provide credible support for the $150k. First, the pro forma assumes no parking.

While HR&A asserted that this is allowed, parking is being provided at the MRPs, and parking has been provided to varying degrees at all prior City-funded affordable housing projects (apparently depending on populations to be served and extent of ground floor retail). City Council was not asked to make a determination that the pilot OAPs will have no parking, and did not do so. Second, the unit sizes used in the pro forma—while satisfying CTCAC minimums— are substantially smaller than the minimums for inclusionary units that the pilot program ordinance incorporates as the minimums for the pilot OAPs. Third, the pro forma assumes no prevailing wages. But the only time the gap financing amount matters is when the developer fails to build the project and the land and money revert to the City (or its designee). Such a developer “default” seems the most likely scenario given (i) the likelihood that the gap financing deposit will not cover all of the required gap financing and (ii) Staff’s report at the August 12, 2025 City Council meeting that the developers want cost certainty (which means they do not intend to cover any further gap should it arise down the road). Although SMRR cannot offer and is not offering any legal opinions or advice, it would be surprising if the City has a legal opinion that prevailing wages will not have to be paid under those circumstances, and it would be shocking if the City had a legal opinion that prevailing wages would not have to be paid if the City had to contribute additional gap financing.

Furthermore, the fact that the ENR Building Cost Index – Los Angeles rose by 50% in the last 5 years illustrates the risk of cost increases outrunning either the capped at 5% gross up until time of deposit into escrow, or the interest rate available on any escrow.

To mitigate this financial risk, the first step is to insist that participants in the pilot program agree to pay the GS tax or its equivalent upon sale, whether or not the tax remains applicable to such a sale at the time of the sale. A provision similar to this was included in the recent amendment to the development agreement with RAND. Given the various past and continuing efforts to undermine Measure GS through local or Statewide initiatives and/or through legislation in Item 11-A
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Packet Pg. 2527 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Sacramento, such a provision should be included in this pilot program. Once again, this would not undermine the economics for the developers as it was announced at the August 12, 2025 City Council meeting that one developer was urging adoption of the pilot and pointed out that doing so would lead to a large payment of GS taxes upon sale of its projects in 2030. Assurance of receipt of the GS taxes helps to mitigate the financial risks discussed above, and without such assurance the value proposition for this pilot from an affordable housing point of view evaporates.

Given the statement by Staff at the August 12, 2025 City Council meeting that the developers view certainty of funding commitment a key benefit of the pilot program, the additional step to mitigate these financial risks is to increase the required initial deposit into escrow. One possibility SMRR would consider acceptable—assuming it could be done logistically and legally—would be to effectively allow some (or, if truly justified economically, potentially even all) of the additional amount (i.e., above the $150k) the City requires the developers to deposit into the escrow to constitute a prepayment of (or in some other way a credit against) the subsequent GS tax.

One other source of financial risk in the pilot program as currently drafted is its release of all of the security (i.e., the land purchase option and the deposited escrow funds) upon commencement of construction of the OAP. Given the City’s past experience with Craig Jones (which led to imposition of the requirement that COOs for an OAP must be issued prior to COOs for the associated MRP)—and given the financial woes experienced by NMS—prudence in light of history requires some continuing security until the OAP is complete. Staff is better position to determine whether that continuing security should be a continued option and construction escrow, completion bonding and/or something else.

3. Another risk posed by the pilot offsite option is that it assumes the pilot OAPs will obtain 4% Low Income Housing Tax Credits (“LIHTCs”), without which the pilot OAPs will not be built. At present the competitiveness of the pilot OAPs for an award of these tax credits is unknown. Also unknown, at least to the public (which has not seen the responses to the Notice of Availability issued on June 30, 2025 for Bergamot, 4th & 5th and Arizona, and Parking Structure 1), is the full extent to which 4% LIHTCs are needed to create the affordable housing on public land that the City committed to in the 2021-2028 Housing Element, and therefore the risk of delaying those projects if they have to compete with pilot OAPs for those tax credits. To date that risk has been mitigated by limiting the pilot to 1000 units, which in turn has limited the pilot OAPs to two ~48 unit projects. But if Staff can demonstrate that expansion of the pilot program will not delay or otherwise put at risk the affordable housing on public land to which the City committed in the Housing element, and can demonstrate that expansion needs to happen immediately if the City is to meet its 6th Cycle RHNA market-rate housing target and/or respond adequately to its current fiscal distress, then SMRR could support the expansion of the pilot program (assuming it first incorporates SMRR’s recommendations for improvements to the program) to include all already approved projects in the downtown. These downtown projects have the greatest revenue generating potential and pose the least risk of disruption to existing neighborhoods. If, but only if, participating downtown projects do not include at least the additional 800 market rate units likely needed—in addition to the 1000 market-rate units already included in the initial pilot, as well as the market rate units already completed or in construction Item 11-A
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Packet Pg. 2528 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) outside the pilot program—to assure the City will meet its current RHNA market-rate housing target, then already approved projects outside the downtown could be included as well in the expanded pilot until the 800 additional market-rate housing unit requirement is met.

4. A final risk posed by the pilot offsite option is the expiration of the affordability covenants on the OAPs in 75 years. The City should avoid this risk by insisting upon an option to purchase the OAPs at the end of the 75 year period for a de minimis price. This change will not impact the developers’ economic calculus, but will help assure the City’s affordable housing goals will continue to be served both now and in the future.

5. With respect to the in-lieu fee option, the figure used in the pilot needs to be raised. The in-lieu fee chosen—the “base unit fee” from S.M.M.C. § 9.64.070.A—never was meant to represent the cost of creating an affordable housing unit. Rather, it was the amount calculated by HR&A long ago as part of a nexus study calculating the fraction of an additional affordable housing unit that needed to be added to the City housing stock in order to house the additional low income households needed to provide additional low wage workers to meet the increased services demands created by the new City residents in each new 5 unit project. This has no conceptual relationship to paying a fee in-lieu of including affordable units in a project in order to obtain a local density bonus, instead of building those affordable housing units either onsite or offsite. Nor has the “base unit fee” escalated over the past 20 years in a manner realistically tied to the actual increase in the cost of developing affordable housing units.

The City instead should develop a realistic in-lieu fee tied to the actual cost of developing affordable housing units in 100% affordable housing projects, multiplied by the number of inclusionary affordable units the MRPs are no longer providing. This could potentially be a gap financing figure when the cost of land and creating the manager’s units is included, but it would have to be adjusted upward to take account of the delay from when the in-lieu fee would be paid to when the substitute affordable housing project would be built (including due to the risk of competition for tax credits), as well as other risks. Once a realistic figure is established, then the City can adjust it downward if but only if there is some reason to encourage developers to pay fees, rather than use the pilot offsite option, as part of the City’s overall plan to advance its affordable housing goals. No such case has been made to date.

II. SMRR REVIEW OF THE AHPP PILOT’S OFFSITE OPTION
A. Background
State density bonus law provides developers with greater density in exchange for affordable units, BUT it requires that those affordable units be inclusionary units that are onsite at the market rate project (“MRP”).

Santa Monica’s AHPP program already provides an offsite affordable option. BUT that option requires 5% more affordable units be provided offsite than are required onsite, AND does not provide the developer with the additional density onsite that the State allows.

Item 11-A
September 20, 2025
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Packet Pg. 2529 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Developers have asserted that their already approved MRPs—which all use the State density bonus law—are infeasible under current market conditions (high interest rates, tariff issues, construction labor issues, Measure GS, etc.).

In response, and at City Council direction, Staff proposed a new offsite option for projects with unexpired approvals that have not yet pulled building permits1 whereby market-rate developers
can move all of their inclusionary units offsite2
AND obtain same density in their MRPs as
otherwise would have been permitted under State density bonus law3 (including by re-entitling the already approved projects by 12/31/26 to take advantage of additional density bonuses not yet in State law when initial entitlements for the projects were obtained4), so long as they satisfy the following conditions:

1. The OAP used to satisfy a developers’ AHPP obligation for an MRP must comply with these criteria:
(a) The number of offsite affordable units the developer must provide is equal to 15% of base MRP, plus whatever additional percent of the base MRP the developer agreed to provide—if it did so—in order to receive the additional 50% State density bonus under Gov.

Code § 65915(v).5 Fractional unit obligations are handled in accordance with S.M.M.C. § 9.64.060.B;6
(b) Affordability is governed by S.M.M.C. § 9.64.060.B (“The off-site affordable housing units shall be affordable to 80% income households or lower.”); 7 (c) The unit mix may not include studios,8 and otherwise must satisfy S.M.M.C. § 9.64.050.E.2 (“The unit mix percentage for affordable two- and three-bedroom housing units shall be equal to or greater than the unit mix percentage for the corresponding market rate units.”);9
1 See S.M.M.C. § 9.64.065.B; 8/12/25 Staff Slide “Clarifying Changes To Proposed Ordinance”.

The adopted Ordinance, incorporating the Staff’s “Clarifying Changes”, is available at https://www.santamonica.gov/media/Document%20Library/Topic%20Explainers/Planning%20R esources/AHPP%20Off-site%20Affordable%20Pilot%20Ordinance%202824.pdf. 2 See S.M.M.C. § 9.64.065.D.
3 See S.M.M.C. § 9.64.065.G.
4 See S.M.M.C. § 9.64.065.B.
5 See S.M.M.C. § 9.64.065.H.
6 See S.M.M.C. § 9.64.065.D.1.
7 See S.M.M.C. § 9.64.065.D.1.
8 See S.M.M.C. § 9.64.065.D.7.
9 See S.M.M.C. § 9.64.065.D.3; 8/12/25 Staff Slide “Clarifying Changes To Proposed Ordinance”.

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Packet Pg. 2530 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) (d) The minimum size of the units must satisfy S.M.M.C. § 9.64.050.E.4 (“An affordable housing unit shall have a minimum total floor area, depending upon the number of bedrooms provided, of no less than the following: 0 bedrooms 500 square feet[;] 1 bedroom 600 square feet[;] 2 bedrooms 850 square feet[;] 3 bedrooms 1,020 square feet[; and] 4 bedrooms 1,200 square feet”);10
(e) The minimum occupancy must satisfy S.M.M.C. § 9.64.050.E.5;11 (f) There must be a 75 year affordability covenant;12
(g) An approved non-profit must own (in whole or part) and operate the OAP.
13 2. Prior to obtaining building permit for an MRP not in the Coastal Zone, the developer must:
(a) Identify land for the OAP and satisfy the City that the land is environmentally sound;14
(b) Identify the MRP(s) using the OAP to satisfy their obligations under the AHPP, and identify all the units that will be in the OAP (presumably to allow City to verify that the number and types of units satisfy the pilot AHPP requirements described above).15 (c) Identify and enter into a contract with a City approved non-profit to own (in whole or part) and operate the OAP;16
(d) Provide a title report demonstrating that the option agreement (described below) and the affordability covenant (described above) will not be behind any other lien on the property;17
10 See S.M.M.C. § 9.64.065.D.3; 8/12/25 Staff Slide “Clarifying Changes To Proposed Ordinance”.
11 See S.M.M.C. § 9.64.065.D.3; 8/12/25 Staff Slide “Clarifying Changes To Proposed Ordinance”.
12 See S.M.M.C. § 9.64.065.A.2.
13 See S.M.M.C. §§ 9.64.065.D.2.b.
14 See S.M.M.C. §§ 9.64.065.D.2.a, 5.a.i, 5.a.iii; see also S.M.M.C. §§ 9.64.060.D-.E,

9.64.065.D.2.a (incorporated portions require demonstrate to City site control and that the site not be in the prohibition area (i.e., Pico)).
15 See S.M.M.C. §§ 9.64.065.D.5.a.i.
16 See S.M.M.C. §§ 9.64.065.D.5.a.ii.
17 See S.M.M.C. §§ 9.64.065.D.6.d.

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Packet Pg. 2531 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) (e) Record an option for the City (or, at the City’s election, for a non-profit) to acquire the property for $100 in the event the developer does not pull a building permit for the OAP—and commence construction activities for the OAP—within 4 years from issuance of the building permits for MRP (with the City having the right but not the obligation to extend this period to 5 years). The option becomes void if a building permit is pulled for the OAP, and construction activities commence for the OAP, within the required time period; 18 (f) Record the affordability covenants;19
(g) Deposit into an interest-bearing escrow the “gap financing amount” of $150k per offsite unit (adjusted each year following the effective date of the pilot program ordinance by the percentage increase in the ENR Building Cost Index – Los Angeles, but the adjustment cannot exceed an annual increase of 5% (although it is unclear whether this limit applies individually each year, or cumulatively across all years prior to the deposit)).20 [Note: Developers must satisfy these same requirements before pulling building permits for MRPs that are in the Coastal zone except that (a) deadline for placing the “gap financing amount” into escrow, and recording the option, is after Coastal Commission has approved an amendment to the Coastal Development Permit allowing the relocation of the affordable units to an off-site property (without other material changes to that permit) and (b) the time-limit for pulling a building permit and commencing construction of the OAP is 18 months (or 30 months if the City grants a 12 month extension) following the approval of the Coastal Development Permit amendment.21]
This pilot offsite option improves the economics for the market-rate developers because (1) it allows them to convert the formerly inclusionary units onsite into market rate units, thereby increasing the cash flow from the MRPs, and (2) it allows them to use LIHTCs to help finance the OAPs. Indeed, according to the City Council discussion on August 12, 2025, one developer asserted that with the benefit of the pilot program it would be able to proceed with its projects and—if all its approved projects were included—pay a very large sum in GS taxes upon sale of the projects in 2030.

B. SMRR Analysis Of Current Pilot Offsite Option And Proposed Improvements To That OptionTo Better Serve City Goals
As set forth above, in order to improve the economics for already approved MRPs, the AHHP pilot program’s offsite option (1) allows the developer to obtain all the benefits of State density bonus law at the MRP without any onsite inclusionary units, (2) does not require 5% more affordable units offsite, (3) does not require that the OAP be completed prior to the issuance of 18 See S.M.M.C. §§ 9.64.065.D.6.a.
19 See S.M.M.C. §§ 9.64.065.D.6.c.
20 See S.M.M.C. §§ 9.64.065.A.6, D.5.c; 8/12/25 Staff Slide “Clarifying Changes To Proposed Ordinance”.
21 See S.M.M.C. §§ 9.64.065.D.5.b-c, D.6.

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Packet Pg. 2532 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) certificates of occupancy for the MRP, and (4) fixes the developer’s financial obligations with respect to the offsite affordable housing at the time it pulls its building permits for the MRP. But as explained below, these provisions impose a very substantial risk that (1) the OAPs will not be built for a very long time, and (2) that the City will have to contribute additional gap financing in order to get the OAPs built. Consequently, the AHPP pilot program’s offsite option should impose additional requirements to better manage these risks while still preserving the incentives for developers to utilize the pilot program.

1. The Current Pilot Offsite Option Should Be Changed To Better Manage The Timing Risks Associated With Creating The OAPs As currently written, there are no adverse consequences for a market-rate developer if the actual construction of the OAP does not begin for up to 4 years after building permits are pulled for the MRP (and the City can extend that period to 5 years). Indeed, even after that deadline passes, there still are no adverse consequences for the market-rate developer because all that happens is the developer forfeits land that would have no economic value to it anyway for at least 75 years while the land hosts the OAP, and the developer forfeits the gap financing amount that it deposited into escrow that likewise has no economic value to it anyway for at least 75 years because the developer would have had to spend that money anyway to construct the OAP.

SMRR believes this situation is unacceptable for at least two reasons. First, one of the purported value propositions for the City from the pilot program is that it will unfreeze the creation of the affordable housing units included in the approved MRPs (i.e., get them into service faster than would occur by simply waiting for economic conditions to change enough so that the approved MRPs—including their onsite inclusionary units—are built). That value proposition does not seem credible under the current terms of the pilot program.

Second, the longer it takes to begin construction on the OAPs, the greater the risk that escalations in construction costs will render insufficient the gap financing amount that the developers will deposit into escrow, and the greater the likely size of any such insufficiency. This is because, as explained in the discussion of financial risks in Part II.B.2.a at points 2-3, there is a very substantial risk that construction costs will rise faster than the pre-deposit escalation in the gap financing amount and/or the rate of interest paid on the escrowed amount. Thus delay in creating the OAPs imposes unnecessary additional financial risk on the City.

In order to mitigate these timing risks, the pilot program should be amended to require the market-rate developer (or its designee) to meet various milestones along the path to commencement of construction on the OAP (e.g. hiring professionals to prepare drawing and plans for the OAP, submitting them for approval by the City, applying for tax credits, hiring contractors, etc.). Any step that is supposed to be completed under the timeline before the time the market-rate developer actually seeks the COOs for the MRP should have to be completed before the COOs for the MRP are issued. And, with respect to any interim step that is supposed to be taken after the COOs for the MRP in fact are issued, there should be a financial penalty for failing to timely take those steps.

Note that the foregoing proposals do not undermine the financial certainty that Staff told the City Council at the August 12, 2025 meeting is required by the market-rate developers to move Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

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Packet Pg. 2533 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) forward at this time with their approved projects. This is because the foregoing proposals do not impose any penalty for things that are beyond the market-rate developers’ reasonable control, such as either the failure of CTCAC to grant a properly submitted tax credit application, or escalations in the cost of construction while the OAP is in the pre-development phase.

2. The Current Pilot Offsite Option Should Be Changed To Better Manage The Financial Risks Associated With Creating The OAPs (a) The Current Pilot Offsite Option Creates A Very Substantial Risk That The City Will Have To Provide Additional Gap Financing To The OAPs

1. $150k Per Unit Does Not Appear To Be A Credible Estimate Of The Gap Financing That Would Be Required Even If Construction On The OAPs Could Begin Today Under the terms of the pilot program, the “gap financing amount” that the developer must deposit into escrow is supposed to be “the amount of financing necessary to complete a 100% affordable housing project assuming that (a) the off-site affordable project will obtain a 4% federal Low-Income Housing Tax Credit and/or tax-exempt bond allocation; and (b) that there will be no land acquisition costs.”22 But the $150k per unit used in the pilot program as the current “gap financing amount” does not appear to satisfy this definition.

In particular, Staff based its conclusion that $150k per unit was a reasonable estimate of the gap financing required based on two analyses; namely, (1) a Staff analysis of the amount of gap financing provided to the last six City-funded projects that have been completed, and (2) HR&A’s review of a pro forma for an offsite affordable project provided by a market-rate developer. But neither of these analyses appears to lend credible support to the $150k figure.

First, Staff itself performed the following exercise:
22 See S.M.M.C. § 9.64.065.A.6.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2534 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) The detailed calculations summarized above—which Staff kindly provided after the August 12 City Council meeting—are as follows:

Whatever the merits of this methodology for the question at hand may or may not be, all of the underlying data points used in the Staff analysis involve projects whose construction began during the period from June 2019 through August 2022.23 But an application of this same methodology to more recent data points shows that the gap financing amount required for an affordable housing project in Santa Monica using tax credit financing is much higher than $150k.

The more recent data points are:
23 Methodological issues include—but are not limited to—(1) the method of grossing up historical gap funding amounts to current requirements (using a flat 5% per year), and (2) including manager’s units in the per unit cost calculation (given that the offsite project pays a per affordable unit fee into escrow, but the resulting OAP also must include one or more manager’s units subsidized by the fee charged the affordable units for deposit into escrow.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2535 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) (a) The application of Venice Community Housing Corporation (“VCHC”) for 4% LIHTCs, in connection with a 78 unit project on 20th Street in Santa Monica, that was approved by the California Tax Credit Allocation Committee (“CTCAC”) in August of 2024.24 38 of the units are 1-bedroom units, 21 are 2-bedroom units, and 19 are 3-bedroom units. Because 38 of the units are for formerly homeless persons, and 20 are for persons with disabilities, the VCHC application includes significant reserves to cover the cost of providing supportive services to the residents of these units. Taking all of the non-tax credit public funds identified by VCHC to CTCAC as part of the permanent funding for this project, and deducting from that amount both the land costs and the reserves for the cost of providing supportive services, leaves public gap funding of $228,437 per unit. Applying the Staff methodology of escalating the historical gap financing figure by 5% per year yields a gap financing amount of $239,859 per unit as of August 2025. Applying instead the actual increase in the ENR Building Cost Index – Los Angeles from August 2024 to August 2025 (8.25%) yields a gap financing amount of $247,274 per unit.25 (b) The application of Hollywood Community Housing Corporation (“HCHC”) for 9% LIHTCs, in connection with an 82 unit project on Euclid Street in Santa Monica, that was approved by the CTCAC in June of 2025 (an award that HCHC declined due to legal uncertainty caused by a CEQA lawsuit filed against the project), and that then was resubmitted to CTCAC (with updates) in July of 2025.26 19 of the units are 1-bedroom units, 15 are 2-bedroom units, and 14 are 3-bedroom units. There is no land cost for this project because it is to be built on 24 See 8/6/2024 CTCAC Project Staff Report for VCHC’s 20th Street Apartments, available at https://www.treasurer.ca.gov/ctcac/meeting/2024/0806/staff/CA-24-414.pdf; 4/17/2024 Application to CTCAC by VCHC for 4% tax credits in connection with proposed 20th Street Apartments project, available at https://www.treasurer.ca.gov/ctcac/2024/firstround/index.asp (click on link for “CA-24-414 20th Street Apartments”). The project is a joint venture with Community Corporation of Santa Monica, and broke ground in April 2025. See Sharp, S., “Affordable housing breaks ground at 1640 20th Street in Santa Monica” Urbanize (Apr. 18, 2025), available at https://la.urbanize.city/post/affordable-housing-breaks-ground-1640-20thstreet-santa-monica. 25 If the gap funding is spread only among the 76 affordable units in this project (recognizing that the funds deposited into escrow under the pilot offsite option are charged against the affordable units only), then the gap financing figures are (a) $234,448 as of August 2024, (b) $246,171 as of August 2025 using Staff’s 5% per year escalator, and (c) $253,781 as of August 2025 using the actual increase in the ENR Building Cost Index – Los Angeles from August 2024 to August 2025 (8.25%).
26 See 6/18/2025 CTCAC Project Staff Report for HCHC’s Ollie Apartments, available at https://www.treasurer.ca.gov/ctcac/meeting/2025/0618/binder.pdf (pp. 57 et seq. of pdf); 3/17/2025 Application to CTCAC by HCHC for 9% tax credits in connection with proposed Ollie Apartments project, available at
https://www.treasurer.ca.gov/ctcac/2025/firstround/9percent/applications/index.asp (click on link for “CA-25-003 Ollie Apartments”); 7/8/2025 Application to CTCAC by HCHC for 9% tax credits in connection with proposed Ollie Apartments project, available at https://www.treasurer.ca.gov/ctcac/2025/secondround/9percent/applications/index.asp (click on link for “CA-25-091 Ollie Apartments”).

Item 11-A
September 20, 2025
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Packet Pg. 2536 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) City-owned land. The City also is to provide $13.5 million from the Housing Trust Fund, which amounts to gap funding of $281,250 per unit.27
(c) The undated pro forma provided by HCHC to Staff in connection with an 82 unit project on City-owned and acquired land at 14th Street in Santa Monica that will seek 4% LIHTCs. 80 of the units are 1-bedroom units, and 2 are 2-bedroom units. The City Council had directed in August of 2024 that such a project replace the original HCHC project City Council had approved for this site in March of 2024, and the City Council formally approved this revised project in December 2024. Taking all of the non-tax credit public funds identified by HCHC in the pro forma as part of the permanent funding for this project, and deducting from that amount the land costs, leaves public gap funding of $198,927 per unit. Applying the Staff methodology of escalating the historical gap financing figure by 5% per year—and making the most conservative possible assumption that the HCHC pro forma is from December of 2024—yields a gap financing amount of $205,558 per unit as of August 2025. Applying instead the actual increase in the ENR Building Cost Index – Los Angeles from December 2024 to August 2025 (5.8%) yields a gap financing amount of $210,392 per unit.28 But these figures almost certainly underestimate the gap financing that would be required as of August 2025 for the 14th Street project because (1) HCHC also provided to Staff an undated pro forma for the Euclid Street project at the same time as it provided the pro forma for this 14th Street project, (2) a comparison of HCHC’s July 2025 application to CTCAC for the Euclid Street project, with the HCHC pro forma provided to Staff for the Euclid Street project, shows that (a) construction costs are 11.1% higher on the CTCAC application, (b) construction loan interest and origination fees are 46.7% higher on the CTCAC application, and (c) the gap financing amount is 22.7% higher on the CTCAC application, and (3) in December of 2024, Staff requested—and City Council provided—authority for Staff to provide more gap financing, as needed, than the amounts indicated on HCHC’s Euclid and 14th Street project pro formas. In addition, the HCHC pro forma assumes 40 project-based Section 8 vouchers will be assigned to the project, and generate considerable additional cash flow that in turn supports a larger commercial loan. Staff has not indicated that it will be able to provide such support to the pilot OAPs, in which case the gap financing amount may well be higher for this reason as well.

Thus, even taking the most conservative approach, the average of these three much more recent real world data points indicates the gap financing amount required under Staff’s methodology is at least $242,222 per unit as of August 2025—and it is likely that the amount is considerably higher.
27 If the gap funding is spread only among the 47 affordable units in this project (recognizing that the funds deposited into escrow under the pilot offsite option are charged against the affordable units only), then the gap financing figure is $287,234. 28 If the gap funding is spread only among the 80 affordable units in this project (recognizing that the funds deposited into escrow under the pilot offsite option are charged against the affordable units only), then the gap financing figures are (a) $203,900 as of December 2024 at the latest, (b) $210,697 as of August 2025 using Staff’s 5% per year escalator, and (c) $215,652 as of August 2025 using the actual increase in the ENR Building Cost Index – Los Angeles from August 2024 to August 2025 (8.25%).

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2537 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Second, HR&A performed a review of a developer provided pro forma. That review was summarized at the August 12, 2025 City Council meeting as follows:

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

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Packet Pg. 2538 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) But, based on the information disclosed in these slides (no other information having been provided to the public), it does not appear that the HR&A analysis provides credible support for a $150k per unit “gap financing amount” for the following reasons:
(a) The pro forma analyzed by HR&A does not include parking, which HR&A (Paul Silvern) identified at the August 12 meeting as a significant driver of cost savings. HR&A stated at the meeting that parking is not legally required. However, all of the market rate projects participating in the pilot provide parking (and so presumably would have provided parking to the inclusionary units had they remained onsite).29 And every one of the affordable projects included in the Staff’s analysis—as well all of the more recent deed-restricted affordable housing 29 The first five projects below applied for the pilot offsite option. The last project applied for the pilot in-lieu fee option. All of the data in this chart is from the approved plans for these projects that are linked to Status of Administrative Approvals chart available at https://www.santamonica.gov/media/Document%20Library/Topic%20Explainers/Santa%20Mon ica's%20Housing%20Progress/Status%20of%20Administrative%20Approvals_9.9.25.pdf.

PROJECT UNITS PARKING
1902 Wilshire (23ENT-0156) 140 168 residential, 22 commercial 1527 Lincoln (23ENT-0161) 210 279 residential
2501 Wilshire (23ENT-0173) 170 194 residential, 60 commercial 2025-2037 Wilshire (23ENT-0178) 150 184 residential, 27 commercial 1931 Wilshire (24ENT-0183) 260 308 residential, 18 commercial 2906 Santa Monica (20ENT-0311) 88 92 residential, 43 commercial Item 11-A
September 20, 2025
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Packet Pg. 2539 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) projects approved for construction in the City—include parking to varying degrees.30 Furthermore, on the face of the slides, it is unclear whether HR&A analyzed whether the reduction in cost due to no parking would in fact reduce the gap funding otherwise required, would instead reduce the amount of tax credits for which the pilot OAPs could qualify due to their resultant lower cost basis, or some combination of both. Finally, and most importantly, a decision to eliminate all parking at the pilot OAPs was not called out in the Staff Report, and the City Council did not discuss—let alone vote on—whether or not to adopt a no-parking policy for pilot OAPs.
(b) The pro forma analyzed by HR&A assumed 1-bedroom units of 450 sq. ft., and 2- bedroom units of 700 sq. ft. This complies with CTCAC minimum unit sizes. However, under the pilot program—both as proposed by Staff and as adopted by the City Council—the OAPs are required to comply with S.M.M.C. § 9.64.050.E.2-.5.31 And S.M.M.C. § 9.64.050.E.4 provides that “[a]n affordable housing unit shall have a minimum total floor area, depending upon the number of bedrooms provided, of no less than the following: . . . 1 bedroom 600 square feet[;] 2 bedrooms 850 square feet . . . .”). In other words, the pro forma analyzed by HR&A underestimates the required size of every one of the 72 units by 150 sq. ft., or a total of 10,800 sq. ft. (which equates to an additional 20% of the “Gross Building SF” of 51,000 SF used on the pro forma HR&A analyzed).
30 The data in this chart is taken from Urbanize articles about the first six completed projects, from the VCHC and HCHC tax credit applications to CTCAC for next two projects, from the HCHC pro forma for the next project, and from the presentation by EAH to City Council on 4/10/24 for the last project.

PROJECT DEVELOPER UNITS POPULATION PARKING
1820&1826 14th St. CCSM 39 Seniors 10 below grade
1445&1453 10th St. EAH 40 Seniors 10 at grade
2120 Lincoln Blvd. CCSM 37 General 9 car garage
1819 Pico Blvd. CCSM 48 General 49 below grade
1834-1848 14th St. CCSM 73 General 55 below grade
1413 Michigan
Ave.

EAH 58 Supportive 9
20th St. Apts. VCHC 78 Supportive & General 26 covered
Euclid St. Apts. HCHC 48 General 35 covered, 3 uncovered 14th St. Apts. HCHC 82 Seniors & Senior Supportive 42 at grade 4th St. Apts. EAH 122 Supportive & General 115 below grade (59R/56C) 31 See S.M.M.C. § 9.64.065.D.3; 8/12/25 Staff Slide “Clarifying Changes To Proposed Ordinance”.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2540 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) (c) Most importantly, the pro forma analyzed by HR&A assumes that prevailing wages will not be paid, which HR&A (Paul Silvern) identified at the August 12 meeting as another significant driver of cost savings. But the Staff Report for August 12, 2025, did not even reference—let alone contain—a legal analysis concluding that the web of relationships created by the pilot program do not trigger the State’s Prevailing Wage Law in the first instance.

Moreover, the reason why the pilot program requires the market-rate developer to deposit the “gap financing amount” into escrow presumably is to provide assurance to the City that— notwithstanding the pilot program eliminating the AHPP requirement that COOs for OAPs must be issued before COOs for the MRPs—the pilot OAPs will actually get built even if the marketrate developers are either unable or unwilling to build them. While SMRR cannot offer legal advice to the City, and SMRR is not doing so, it would be surprising if the City has legal advice that the Prevailing Wage Law does not apply under those circumstances, and it would be shocking if the City has legal advice that the Prevailing Wage Law would not apply if the City has to provide additional gap financing to the OAPs. Therefore, whatever merit the assumption of no prevailing wage being paid might or might not have if the market-rate developers build the OAPs themselves without any further City funding, it does not seem to be a reasonable assumption to use when determining the “gap financing amount” the City should require the market-rate developers to deposit as security to assure completion of the OAPs. Indeed, given that the $150k initial deposit does not appear adequate as explained above, given that the rate of growth in that amount both pre-deposit and post-deposit could well be less than the escalation in construction costs as explained below, and given that Staff reported at the August 12, 2025 City Council meeting that developers would not be willing to add to the escrow because cost-certainty is a major benefit of the pilot program, it seems that by far the most likely scenario is that the City will have to build the OAPs (either directly or through a non-profit affordable housing developer).

In short, the HR&A analysis of a single market-rate developer pro forma does not lend credible support to $150k as the “gap financing amount” because the pro forma does not represent the type of OAP for which the “gap financing amount” is supposed to provide security. This is because (1) the HR&A analysis assumes no parking even though the MRPs in the pilot program all include parking, the affordable housing projects used in the Staff analysis all include parking to varying degrees, the more recent affordable housing projects under development in the City all include parking to varying degrees, and City Council neither discussed nor voted to remove all parking from the pilot OAPs; (2) the HR&A analysis assumes substantially smaller units than are required for units in the OAPs under the City Council adopted terms of the pilot program, and (3) the HR&A analysis assumes prevailing wages will not be paid when—absent some as yet not referenced or provided legal analysis—it seems that prevailing wages will have to be paid if the City if forced to use the escrowed funds to build the OAPs, which is by far the most likely scenario.

2. There Is A Substantial Risk That The “Gap Financing Amount” Will Grow Less Slowly Prior To Deposit Into Escrow Than The Rate At Which The Cost Of Building The OAPs Will Grow Prior To Deposit
The pilot program provides that:

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2541 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) The gap financing amount shall be increased annually, commencing on the first anniversary from the effective date of this ordinance, by the last published annual average in the ENR Building Cost Index for the LA region, but shall not exceed an annual increase of five (5) percent. The gap financing amount should be calculated from the effective date of the ordinance until deposited into escrow in accordance with Section 9.64.065(D).

S.M.M.C. § 9.64.065.A.6. The pilot program contains no limit on how long the pre-deposit period may last (other than that it cannot last past the time the market-rate developer wants to pull building permits for the associated MRP, if it is not in the Coastal zone, or the time of an approved Coastal zone permit amendment if the MRP is in the Coastal zone).

This provision imposes a very substantial risk that—even if the $150k figure was a credible estimate of the “gap financing amount” for projects built today (which it is not)—the growth in the “gap financing amount” prior to deposit into escrow would not have kept up with the growth in cost of building the OAPs. This is patent from the fact that the ENR Building Cost Index – Los Angeles has grown 50% in the last five years.
32 This provision also contains a number of ambiguities which, depending upon how they are resolved, could further exacerbate the foregoing problem. First, it is unclear whether the gap financing amount is only “increased annually” (such that all change in the ENR Building Cost Index for the LA region occurring after the last annual adjustment but before the next annual adjustment is simply ignored), or is calculated using the change in that index “from the effective date of the ordinance until deposited into escrow”. If it is the former, that further exacerbates the risk that the gap financing amount will not have grown as fast prior to deposit as the costs to build the OAPs have grown prior to deposit. Second, it is unclear whether the 5% annual cap on growth is applied each year (such that the increase in any year cannot exceed 5% even if in a prior year the increase was less than 5%), or whether it is applied cumulatively (such that the average annual increase cannot exceed 5%, although any individual annual increase can do so when there was less than a 5% increase in one or more prior years). If the former, this too further exacerbates the risk that the gap financing amount will not have grown as fast prior to deposit as the costs to build the OAPs have grown prior to deposit.

3. There Is A Substantial Risk That The “Gap Financing Amount” Will Grow Less Slowly After Deposit Into Escrow Than The Rate At Which The Cost Of Building The OAPs Will Grow After Deposit Into Escrow
The pilot program provides that the gap financing amount will be deposited into an interestbearing escrow account.33 Under the terms of the pilot program, for MRPs located outside the coastal zone, this escrow can last up to four years (five if the City grants a 1-year extension). 34 32 This index is available (after paying a subscription fee) at https://www.enr.com/economics/historical_indices/losangeles. 33 See S.M.M.C. § 9.64.065.D.5.c.
34 See S.M.M.C. § 9.64.065.D.5.c.ii.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2542 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) And if those funds are needed to build the OAPs after a failure by the market-rate developer to do so, it could be a substantial additional period before construction of the OAPs actually begins.

Staff has not yet advised what interest rate an account of this type can earn today. However, a general review of bank interest rates indicates that this interest rate on the escrow deposit would not have come close to covering the 50% increase in the ENR Building Cost Index – Los Angeles over the last five years (and may well not even have covered the 5% annual increase that the pilot program would have required pre-deposit).

4. The Release Of All Security Upon The Commencement Of Construction Of The OAP Creates Risk For The City
The pilot program releases both the City’s option on the land—and all escrowed funds—upon the commencement of construction of an OAP (pulling building permits and beginning construction activity).35 No security is retained to assure completion of the OAP, however.

Given the City’s prior experience with Craig Jones36 (which led to the pre-pilot AHPP offsite requirement that COOs for an MRP could not issue prior to the issuance of COOs for the associated OAP)—and the financial woes of NMS37—the risk posed by this pre-completion release of all security is patent.
(b) SMRR Proposed Changes To The Pilot Offsite Option To Mitigate The Financial Risks It Poses To The City
SMRR believes four changes are required to properly mitigate the financial risks to the City posed by the pilot offsite option.

First, the City should require any developer utilizing the program to sign a written agreement that it will pay the amount of the GS tax upon sale for use in accordance with Measure GS, whether or not the GS tax is in place at the time of sale. A similar (but not identical) provision was included in the recent development agreement amendment that the City negotiated with RAND Corporation.38
The GS tax has been under assault locally through an initiative circulated in 2024 (which was withdrawn, but could return), by proposed legislation in Sacramento (which was withdrawn in 35 See S.M.M.C. §§ 9.64.065.D.5.c.ii-iii, .6.a.
36 See “Developer skips out on affordable housing”, Santa Monica Daily Press (Jun. 21, 2010), available at https://smdp.com/news/developer-skips-out-on-affordable-housing/. 37 See Hall, M. “Lawsuits undermine Neil Shekhter’s once grand rea estate empire”, Santa Monica Daily Press (Mar. 15, 2024), available at https://smdp.com/news/lawsuits-undermineneil-shekhters-once-grand-real-estate-empire/. 38 See “Amendment No. 2 To Development Agreement By And Between City Of Santa Monica And The RAND Corporation ______, 2025” at Section 7.2, available as part of Attachment C to Item 12.A on the City Council’s July 29, 2025 Agenda, available at https://santamonicacityca.iqm2.com/Citizens/Detail_Meeting.aspx?ID=1467.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

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Packet Pg. 2543 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) favor of an L.A. City only statute (which was then itself withdrawn), but could return), and by a Statewide ballot measure (which was held ineligible for the ballot by the California Supreme Court in 2024, but is about to go into circulation again for 2026). Assurance that the GS tax or its equivalent will in fact be received by the City would provide significant mitigation of the financial risks identified above. Moreover, the City should not be taking on financial risk through the offsite option in order to improve the economics of the market-rate developers sufficiently for them to proceed even with the GS tax—as they have advised they can do—only to set up a potential windfall for the developers if changes are made to remove the GS tax.

Second, the “gap financing amount” should be increased to a realistic level (i.e., a level that takes into account that $150k is inadequate, and that the pre-deposit and post-deposit rates of increase can be less than the increase in the cost of construction of the OAPs). SMRR recognizes that this proposal—unlike all of the others—changes the financial calculus for the market-rate developers.

Accordingly, SMRR is open to the idea that some (or, if economically justified, potentially even all) of the increased deposit (i.e., the amount above $150k)—if actually spent creating the OAPs—would be treated by the City as some form of credit against subsequently paid GS tax.

Given that the City lacks the power to reduce the amount subsequently paid in GS taxes, some form of rebate program would have to be developed to create this economic effect for the market-rate developers.

Third, as explained in more detail in Part II.B.1 above, imposing interim milestones toward development of the OAPs is needed to shorten the time between deposit of the gap financing amount into escrow and actual construction of the OAPs.

Fourth, real security for completion of the OAPs must continue past the time building permits are pulled and construction begins. The City is better positioned than SMRR to determine whether this continuing security should be a continued option and construction escrow, a requirement of completion bonding, and/or some other form of security.

3. Management Of The Risks Posed By Competition For Tax Credits The pilot offsite option assumes that the OAPs will obtain 4% LIHTCs, without which the OAPs will not be built. But the tax credits available to projects in Santa Monica are not unlimited, as all tax credit programs are oversubscribed. Data is not yet available regarding the competitiveness of the OAPs contemplated by the pilot offsite option, something that this pilot program will test.

Nor does the public yet have data on the extent to which these same tax credits will be required to fulfill the City’s public land commitments for affordable housing under the Housing Element.

The public knows that HCHC’s 82 unit project on 14th Street plans to seek 4% tax credits (although the timing apparently depends upon when it can obtain other State funding it included in its pro forma). But the public does not know what has been received in response to the June 30, 2025 Notice of Availability for Bergamot, 4th & 5th and Arizona, and Parking Garage 1— Item 11-A
September 20, 2025
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Packet Pg. 2544 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) although Staff presumably already has seen any responses and can enlighten the public and City Council on this score.39
To date the pilot offsite program has mitigated these risks by limited the pilot to 1000 units. As a result, only two OAPs are being considered—one for 46 affordable units at 1333 7th Street and one for 47 affordable units at 1143-1145 25th Street.40 Depending upon whether—and if so, to what extent—the responses to the Notice of Availability indicate the need for those public land projects to obtain 4% LIHTCs (i.e., depending upon whether and to what extent expanding the pilot would create undesirable competition for such tax credits between the public land projects and the pilot OAPs)—and assuming that the need to meet the City’s RHNA market-rate housing target and/or to respond adequately to the City’s current fiscal distress precludes waiting for additional information regarding the tax credit competitiveness of the already contemplated pilot OAPs on 7th Street and 25th Street (and other uncertainties posed by the pilot offsite option)—SMRR could be open to expanding the pilot program (so long as it first is revised as recommended in this analysis). In particular, SMRR believes that if these conditions are met, then all approved projects in the downtown should be allowed to participate in an expanded pilot because (1) they have the highest revenue generating potential at a time when the City is facing fiscal distress, and (2) they pose the least risk of disruption to the existing City neighborhoods. If the already approved downtown projects that choose to participate in the expanded pilot—when combined with the original pilot projects, as well as the market-rate units already completed or in construction—put the City in a position to meet its RHNA market-rate housing target, then that should be the extent of any pilot expansion.

If, on the other hand, the downtown projects electing to participate in an expanded pilot by a deadline for them to apply do not put the City in a position to meet its RHNA market-rate housing target, then SMRR would consider allowing projects outside the downtown to participate in the expanded pilot up to whatever number of additional market rate units are needed to assure Santa Monica’s RHNA market-rate housing target is met.

In other words, given that (1) the City’s 6th RHNA cycle market-rate housing target is 2,727 units, (2) the annual progress reports submitted by Santa Monica to HCD for the first three years of this 6th Housing Element Cycle show that Santa Monica issued building permits for 899 market rate units, and some additional units undoubtedly have pulled building permits during this fourth year, and (3) the original pilot involves 1018 market rate units, another 800 market rate units are needed to assure (to the extent reasonable) that Santa Monica meets its RHNA marketrate target during the 6th Housing Element Cycle. If the already approved downtown projects that choose to participate in an expanded pilot program either meet or exceed this 800 unit figure, then that should be the extent of the pilot expansion. If those participating downtown projects do not meet this 800 unit figure, then additional projects outside the downtown should 39 See June 30, 2025 City of Santa Monica Notice of Availability/Offer to Lease Surplus Property, available at
https://www.santamonica.gov/media/Housing/City%20of%20Santa%20Monica%20- %20SLA%20NOA%20to%20Affordable%20Housing%20Developers.pdf. 40 See Chart of Pilot Applications prepared by Staff and included in Part I above.

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Packet Pg. 2545 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) be allowed to participate in an expanded pilot to the extent necessary to reach a total of 800 additional market rate units in an expanded pilot program.

4. Management Of The Risk Posed By 75 Year Affordability Covenants As noted in Part II.A above, the pilot offsite program requires 75 year affordability covenants.

But as we are seeing today with the expiration of 55 year affordability covenants, the expiration of such covenants imposes the risk of losing affordable housing units in the future. Given that the potential to reacquire the OAPs 75 years into the future does not play any role in the investment decisions of market-rate developers (or those who invest in their projects), the City should insist that it have the option to acquire the pilot program OAPs for a de minimis amount upon expiration of the affordability covenants.

III. SMRR REVIEW OF THE AHPP PILOT’S IN-LIEU FEE OPTION A. Background
S.M.M.C. § 9.64.065.F provides:

F. In Lieu Fee Option for Off-Site Housing (without land provided).

1. Notwithstanding Section 9.64.070, an applicant for a multiple-unit project may satisfy the affordable housing obligation in Chapter 9.64 by paying an in-lieu fee based on the following formula:
(Base Unit Fee per Square Foot) x (total square feet of the residential floor area in the multi-unit project)41

2. For purposes of this Section, the City's base unit fee per square foot shall be established pursuant to Section 9.64.070 by resolution of the City Council.

Commencing on July 1, 2026, and on July 1st of each fiscal year thereafter, the City's base unit fee per square foot shall be adjusted based on changes in construction costs and land costs.

3. The affordable housing fee shall be paid prior to issuance of a building permit for any multiple-unit project utilizing Section 9.64.065(F).

4. The City shall deposit any payment made pursuant to this Section 9.64.065(F) in a reserve account separate from the General Fund to be used only for 41 As the August 12, 2025, Staff advised the Council that the residential floor area referenced is the residential floor area in the project after taking advantage of the local density bonus. But this should be made explicit if this approach is retained (notwithstanding SMRR’s objections described below) because the references to the in-lieu fee in S.M.M.C. §§ 9.64.065.H.1.c, .2.c, are made in the context of using the base project only to calculate the number of offsite units required.

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Packet Pg. 2546 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) development of affordable housing, administrative costs related to the production of this housing, substantial rehabilitation of existing affordable housing, a City sponsored program of rental subsidies for lower income Santa Monica residents, and monitoring and evaluation of this affordable housing production program.

B. The Current Pilot Program Should Be Changed To Utilize An In-Lieu Fee Reasonably-Related To The Cost Of Creating Affordable Housing Units And To The City’s Overall Affordable Housing Plan

1. The “Base Unit Fee” Established Pursuant To Section 9.64.070 Is An Improperly Low In-Lieu Fee To Use For The Pilot Program The pilot program is using the “base unit fee” of S.M.M.C. § 9.64.070A, the fee already charged under the AHPP to multi-family projects of 2-5 units. However, the origin of the “base unit fee” is a 1998 nexus study by HR&A, which first calculated (1) the demand effect of new market rate housing on goods and services, and (2) the number of lower-income households (at that time 60% of AMI or below) needed to supply a portion of the lower-wage employees needed to service this demand. The nexus study then divided the cost to the City of creating a unit of housing affordable to such lower income households (assuming no other public subsidy) by the square footage of the typical market-rate multi-family project that HR&A used to establish the demand effect, and the result was deemed the “base unit fee”. The two key charts from the Executive Summary to that nexus study summarizing these calculations are:

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Packet Pg. 2547 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 42 What these charts show is that the “base unit fee” was supposed to represent the cost to create roughly one affordable housing unit for every 15 market rate units. By contrast, the inclusionary requirement in the single project that has elected to pay the pilot in lieu fee—measured against the total number of market rate units allowed under the pilot program—is one affordable housing units for every 9.78 units.

It appears than an update to the nexus study was completed by HR&A in July 2005 but, unlike the 1998 nexus study, it is not available online.43 According to a May 2005 Staff Report (which includes preliminary updated calculations by HR&A), the methodology is essentially the same, but updated data is used, and the demand for workers earning up to moderate income was included in the updated analysis.44
42 This 1998 HR&A Report is an attachment to a July 21, 1998 Staff Report entitled “Recommendation to Adopt Resolution Establishing Affordable Housing Base Fee”, available at https://publicdocs.smgov.net/WebLink/DocView.aspx?id=2206828&searchid=89ab0638-0a04- 461c-91a2-09ebf39869a6&dbid=0&repo=SMGOV.
43 The updated HR&A report was attached to a July 12, 2005 Staff Report entitled “Resolution to Increase the Affordable Housing Fee and Introduction and First Reading of an Ordinance Amending the Affordable Housing Production Program to Establish a Reduction or Waiver Provision of Chapter 9.56 and to Modify Affordable Housing Definitions and Consideration of Other Amendments to Provide for the Annual Adjustment of the Affordable Housing Fee and the Timing of the Affordable Housing Fee Calculation for a Particular Development”, but it is only available for inspection at the Clerk’s Office per a sheet in the online version, available at https://publicdocs.smgov.net/WebLink/DocView.aspx?id=2211477&searchid=3a50ebaa-8472- 47f7-afe7-e048020e099f&dbid=0&repo=SMGOV.
44 See May 10, 2005 Staff Report entitled “Strategies to Increase the City’s Supply of New Affordable Units” at pp. 5-6 & Attachments A-B, available at Item 11-A
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Packet Pg. 2548 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) The current value of the “base unit fee” is the result of an annual adjustment pursuant to a formula developed by HR&A—and adopted by City Council in 2006—in which median price change of condominium sales is used as a proxy for change in land cost, change in Engineering News Record’s Construction Cost Index – Los Angeles is used as a proxy for change in construction cost, and each of these is weighted by the average weight of land versus construction costs in two most recent City-funded affordable housing developments. The current “base unit fee” for apartments is $43.91 per square foot.45 Under the AHPP pilot program, this figure is then multiplied by the residential floor area. Per the Staff chart included in Part I above, for the single project that has elected to pay the pilot inlieu fee this works out to $2.248 million—which equates to just under $250k per each inclusionary unit that no longer is part of that project.

There are two fundamental problems with using the “base unit fee” to calculate an in-lieu fee for the pilot program. First, the “base unit fee” is intended as an impact fee based on the additional demand for deed-restricted affordable housing caused by 2-5 unit multi-family housing projects.

This bears no conceptual relationship to the purpose of the AHPP pilot in-lieu fee, which is to obtain a reasonable financial contribution to the City’s affordable housing programs in exchange for granting a local density bonus equivalent to State density bonus without requiring the MRP to include any affordable housing units onsite or build any affordable housing units offsite.

Second, the “base unit fee” is far too low to satisfy the purpose of the pilot in-lieu fee. Part of this is due to the nature of the “base unit fee” calculation, as illustrated by the 1998 nexus study.

But part of this is also due to the apparent failure of the annual increase methodology to keep up with the actual increases in the cost of constructing affordable housing over the last 20 years.

This is evident from the fact that (1) this same methodology is used to gross up the “affordable housing unit development cost” pursuant to S.M.M.C. § 9.64.070.B, (2) the “affordable housing unit development cost”—developed by HR&A as part of the same nexus studies discussed above—is supposed to represent “the City’s total cost to develop a unit of affordable housing (i.e., land, construction, professional fees and other ‘soft’ costs and financing costs) minus the amount of construction loan that can be supported by the net operating income derived from operating a typical City-assisted affordable housing development,” without any other public https://publicdocs.smgov.net/WebLink/DocView.aspx?id=2211484&page=1&dbid=0&repo=SM GOV.
45 See Staff Memorandum entitled “Proposed FY 2024-25 Annual Automatic Adjustment for the Affordable Housing Unit Base Fee”, attachment c to Agenda Item 5.C for the City Council’s October 8, 2024 meeting, available at
https://santamonicacityca.iqm2.com/Citizens/Detail_Meeting.aspx?ID=1416.

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Packet Pg. 2549 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) subsidy,46 and (c) the current “affordable housing unit development cost” is just $460,747,47 which is far below the actual cost to the City of developing an affordable housing unit when there is no other public subsidy.48

2. Developing A Proper Pilot In-Lieu Fee
The logical conceptual starting point for a proper pilot in-lieu fee is what it would cost the City to replace the foregone inclusionary units with units developed in a 100% affordable housing project, multiplied by the number of inclusionary units the developer no longer has to provide under the pilot program. While that could be the gap financing amount the City supplies to projects (including the cost of land and the cost of creating manager units), consideration would also have to be given to the delays between the time the in-lieu fee is paid and the time when an affordable housing construction would begin (a time frame likely to be lengthened given the increased competition for LIHTCs from both the pilot OAPs and public land OAPs), as well as other risks—i.e., the figure would have to be higher than current gap financing figures including the cost of land and creating manager units. This figure could be adjusted downward if the City had a particular need for cash to achieve its affordable housing goals that it cannot otherwise satisfy, and therefore wanted to incentivize participants in the pilot program to select the in-lieu fee option. But no such case has been made to date.
* * *
Thank you for your consideration of SMRR’s views on this important matter. Please let us know if you have any questions or otherwise with to discuss any of the foregoing. 46 See Staff Memorandum entitled “Proposed FY 2024-25 Annual Automatic Adjustment for the Affordable Housing Unit Development Cost”, attachment d to Agenda Item 5.C for the City Council’s October 8, 2024 meeting, available at
https://santamonicacityca.iqm2.com/Citizens/Detail_Meeting.aspx?ID=1416; May 10, 2005 Staff Report entitled “Strategies to Increase the City’s Supply of New Affordable Units” at pp. 5- 6 & Attachments A-B, available at
https://publicdocs.smgov.net/WebLink/DocView.aspx?id=2211484&page=1&dbid=0&repo=SM GOV; 1998 HR&A Report at 5, attached to July 21, 1998 Staff Report entitled “Recommendation to Adopt Resolution Establishing Affordable Housing Base Fee” at , available at https://publicdocs.smgov.net/WebLink/DocView.aspx?id=2206828&searchid=89ab0638- 0a04-461c-91a2-09ebf39869a6&dbid=0&repo=SMGOV.
47 See Staff Memorandum entitled “Proposed FY 2024-25 Annual Automatic Adjustment for the Affordable Housing Unit Development Cost”, attachment d to Agenda Item 5.C for the City Council’s October 8, 2024 meeting, available at
https://santamonicacityca.iqm2.com/Citizens/Detail_Meeting.aspx?ID=1416. 48 For just one example, the HCHC pro forma for the 14th Street project, which includes 80 senior 1-bedroom units, and two 2-bedroom manager units, indicates a per unit cost of ~$780k per unit (including the value of the land, but excluding the permanent private loan supported by the rental income).

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Packet Pg. 2550 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Sincerely,
Denny Zane Mike Soloff
Co-Chair, Santa Monicans for Renters’ Rights Co-Chair, Santa Monicans for Renters’ Rights Item 11-A
September 20, 2025
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Packet Pg. 2551 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Diana Bianchini <[email protected]>
Sent: Monday, September 29, 2025 7:24 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE! Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Diana Bianchini
90405
Item 11-A
September 20, 2025
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September 20, 2025

11.A.a
Packet Pg. 2552 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Gail Gordon <[email protected]>
Sent: Tuesday, September 30, 2025 7:35 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Gail Gordon
90405
Item 11-A
September 20, 2025
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September 20, 2025

11.A.a
Packet Pg. 2553 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Gail Gordon <[email protected]>
Sent: Tuesday, September 30, 2025 7:36 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Gail Gordon
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2554 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Robert Dean <[email protected]>
Sent: Tuesday, September 30, 2025 7:56 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Robert Dean
90405

CONFIDENTIALITY NOTICE
The information contained in this communication (including, without limitation, in any attachment) is confidential and is intended for disclosure only to the addressee(s). If you are not an intended recipient or have otherwise received this communication in error, please notify the sender and then delete it, and you are hereby notified that any review, use, dissemination, distribution or copying of any of the contents of this communication is strictly prohibited.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2555 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: Amanda Robertson <[email protected]>
Sent: Tuesday, September 30, 2025 8:23 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Amanda Robertson (310) 614-8071
Please excuse any typos! Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2556 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: Stuart Grusin <[email protected]>
Sent: Tuesday, September 30, 2025 8:35 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Stuart Grusin
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2557 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Dannie Charney <[email protected]>
Sent: Monday, September 29, 2025 8:09 PM
To: councilmtgitems; Lana Negrete; Ellis Raskin; Caroline Torosis; Barry Snell; Jesse Zwick; Dan Hall; Natalya Zernitskaya; Santa Monica City Manager's Office; Council Mailbox; Josh Kurpies; Oliver Chi
Subject: AGENDA ITEM 11-A Off-Site AHPP

EXTERNAL
VERY VERY BAD IDEA FROM A COUNCIL WITH NOTHING BUT BAD IDEAS... this insures segregation -the LAST THING WE NEED is more luxury housing ... SHAME ON YOU - Agenda Item 11-A
Off-site Affordable Housing Pilot Program Expansion
An expansion is being proposed by the City of a program that was adopted as a “pilot” to allow developers to buy their way out of building the required 20% affordable units for large housing projects. This action would expand or make the pilot permanent, incentivizing luxury housing construction by allowing developers to either (a) build required affordable units off-site, segregating low-income housing, or pay an "in-lieu" fee instead of building affordable housing. Many find this program to be no more than a pass for developers to build affordable units at a bargain rate.

Danielle Charney
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2558 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Kathy Knight <[email protected]>
Sent: Monday, September 29, 2025 5:03 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
We oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, we oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Kathy Knight and Joe Faris
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2559 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Vincenzo Landay <[email protected]>
Sent: Monday, September 29, 2025 5:33 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: OPPOSE 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:
 This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa  The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.
 Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit.

A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
V
…………………………………………………………………………………….…...

Vincent Landay. ”Memento Vivere”
Santa Monica Native & Current Resident
……………………………………………………………………………………………
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2560 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Karen Wise <[email protected]>
Sent: Monday, September 29, 2025 6:50 AM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

EXTERNAL
Council Comments Council Comments,
Councilmembers,
The upcoming decision on how to extend the Off-site Affordable Housing Pilot Program is a crucial opportunity to address our housing crisis. The consideration of this policy should be viewed through the lens of broader principles in addressing our housing crisis. This letter sets out those principles & their application to specific policy questions the Council faces, as posed by the staff report. The off-site program has been an early success with more than 1,000 units applying to use it. Council should build on that momentum and the excitement that will be created by seeing projects get started by opening the program to new developers, while avoiding any changes which would increase costs or otherwise undermine pro-housing goals.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2561 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2562 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Karen
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2563 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 6 David Yakobson
From: suzie roth <[email protected]>
Sent: Monday, September 29, 2025 5:56 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Suzie
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2564 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 7 David Yakobson
From: leona mason <[email protected]>
Sent: Monday, September 29, 2025 6:00 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Leona Mason
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2565 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 8 David Yakobson
From: ALICE ELLIS <[email protected]>
Sent: Monday, September 29, 2025 6:15 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Alice Ellis
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2566 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 9 David Yakobson
From: JORDAN ELLIS <[email protected]>
Sent: Monday, September 29, 2025 6:20 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Jordan Ellis
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2567 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 10 David Yakobson
From: Adam Monaghan <[email protected]>
Sent: Monday, September 29, 2025 7:33 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Adam Monaghan
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2568 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 11 David Yakobson
From: Nancy Owens <[email protected]>
Sent: Monday, September 29, 2025 7:54 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses while they enjoy even more profit? A "yes" vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Nancy Owens
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2569 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 12 David Yakobson
From: PAULINE YANO <[email protected]>
Sent: Monday, September 29, 2025 8:06 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Pauline Yano
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2570 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 13 David Yakobson
From: Julie Rhee <[email protected]>
Sent: Monday, September 29, 2025 8:07 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Julie Rhee
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2571 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 14 David Yakobson
From: Michelle LoMonaco <[email protected]>
Sent: Monday, September 29, 2025 9:20 PM
To: councilmtgitems
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

Sincerely,
Michelle LoMonaco 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2572 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 15 David Yakobson
From: Warren Allen <[email protected]>
Sent: Monday, September 29, 2025 9:20 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Warren and Sally Allen
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2573 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 16 David Yakobson
From: Caitlin Lili <[email protected]>
Sent: Monday, September 29, 2025 9:41 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Caitlin Lili
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2574 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 17 David Yakobson
From: Julia Nicholls <[email protected]>
Sent: Monday, September 29, 2025 9:45 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Julia Nicholls
90404
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2575 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 18 David Yakobson
From: Tali Ekstein <[email protected]>
Sent: Monday, September 29, 2025 10:00 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Tali Ekstein
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2576 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 19 David Yakobson
From: Ann Maggio <[email protected]>
Sent: Monday, September 29, 2025 10:04 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2577 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 20 David Yakobson
From: Bruce Leddy <[email protected]>
Sent: Monday, September 29, 2025 10:23 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; Noma Boardmember
Subject: Item 11.A - 9/30/25: Off-Site Affordable Housing Pilot Program - OPPOSE

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose item 11A on the 9/30/25 City Council Agenda, which would expand or make permanent the Off-site Affordable Housing Pilot Program.

Given the extremely low cost of "in lieu" fees – where developers can essentially buy their way out of having to build any affordable housing by paying only $135K per unit instead of building costs which are well above $500K per unit – it is unlikely any affordable units will ever be built. And we desperately need affordable housing in Santa Monica.

For those very few developers who do build off-site affordable housing, putting it all in one location all but guarantees that they will provide only the bare minimum in amenities and building quality since they won't be able to charge as much for the units. Meanwhile, their all-market rate buildings can be built with luxury standards for the highest profit margin.

When our Affordable Housing Production Plan was approved, developers agreed that including 15% affordable units in their buildings "pencilled out," meaning that they could still make the profits they needed to with the ratio of market-rate to affordable. Now, with density bonuses, this has been watered down to less than 10%, and with the off-site program, 0%. We are going backwards on affordable housing and falling far short of our RHNA mandates.

I urge you to vote NO on item 11A so that developers will still be required to have at least some percentage of affordable units wherever they build in our city.

Bruce Leddy
25 year resident
NOMA 90402
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2578 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 21 David Yakobson
From: Jeanne Laurie <[email protected]>
Sent: Monday, September 29, 2025 10:24 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Jeanne Laurie
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2579 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 22 David Yakobson
From: ALICEANN GRUSIN <[email protected]>
Sent: Monday, September 29, 2025 10:27 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Aliceann Grusin
90405
Sent from my annoying device.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2580 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 23 David Yakobson
From: Peter A Donald <[email protected]>
Sent: Monday, September 29, 2025 10:38 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:
 This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.  The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.
 Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?  A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.
 Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
-pad蚋蚌蚍蚎Peter A Donald
2618 32nd St.

Santa Monica, CA 90405
310 871-4862
[email protected]
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2581 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 24 Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2582 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 25 David Yakobson
From: Amanda O'Brien <[email protected]>
Sent: Monday, September 29, 2025 10:59 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2583 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 26 David Yakobson
From: Amanda O'Brien <[email protected]>
Sent: Monday, September 29, 2025 10:59 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Amanda OBrien
1744 Bryn Mawr Ave
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2584 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 27 David Yakobson
From: [email protected]
Sent: Monday, September 29, 2025 11:55 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
It is clear that the developers are using every and any chance they have to develop property, eliminate residential areas, and focus solely on their profit at our community’s expense. Under the guise of “Affordable Housing” developers have attempted to over build areas, while not offering any true “affordable housing” for those struggling financially.

Therefore, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either:
(a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct.

Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2585 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 28 Sincerely,
Charles Blum
90405
Dr. Charles L. Blum
[email protected]
1752 Ocean Park Boulevard
Santa Monica, CA 90405
310-392-9795
www.drcharlesblum.com
CONFIDENTIALITY NOTICE: This E-Mail communication (including attachments) is covered by the Electronic Communications Privacy Act 18, U.S.C 2510-2521, is confidential and may be legally privileged. If you are not the intended recipient, you are hereby notified that any retention, dissemination, distribution or copying of this communication is strictly prohibited. Please reply to the sender that you have received this message in error, and then delete it. Thank You.

Ferpa Notice: Additionally, these records are protected by the Family Educational Rights and Privacy Act and are provided to the intended recipient under an exception to the Act found in Section 99.32.

These records must be maintained confidentially and may not be re-disclosed. They must be destroyed when your legitimate educational interest no longer exists.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2586 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 29 David Yakobson
From: Heather Thomason <[email protected]>
Sent: Tuesday, September 30, 2025 12:03 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Caroline Torosis; Natalya Zernitskaya; Barry Snell
Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- Oppose

EXTERNAL
Dear Mayor Negrete and Council Members,
I am compelled to object to the off-site affordable housing program as currently designed. I fear the city will come to regret this deal—it's too favorable to developers, provides insufficient value to our community, and exposes us to unacceptable financial risk.

The in-lieu fees are far too low to actually build the affordable housing we desperately need. These fees must reflect modern construction costs, or we're simply collecting money we can never use to house our residents.

The city assumes all the risk in the in-lieu scenario—interest rate fluctuations, land cost changes, construction cost overruns—all become our taxpayers' problem while developers walk away with their profits guaranteed.

The density bonus loophole fundamentally undermines what little value this program provides.

Developers retain full density bonuses while converting affordable units to market-rate, allowing them to build even more luxury units without actually providing the affordable housing our community needs.

Even in a scenario where they do actually build them off-site, our effective inclusionary rate dips below an already inadequate 10%.

The pilot data is woefully insufficient. The 1,000-unit pilot filled in two days with only 6 applications from just 2 developers—5 from a single developer. We cannot measure effectiveness with such limited data, nor should we ignore what this concentration suggests: that this program may have been designed primarily to benefit one developer. I urge the council to examine how this happened and what it means for our city.

I understand some believe abundant market-rate housing solves California's affordability crisis. But it's hard to accept this when 90%+ of new Santa Monica units will remain unaffordable to all but the wealthiest residents—not our teachers, not our service workers, not the families who make this city function.

We must prioritize incentivizing and subsidizing only truly affordable, below-market-rate housing for the people of Santa Monica.

Thank you for considering my thoughts.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2587 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 30 Heather Thomason, 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2588 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 31 David Yakobson
From: Leanna Einbinder <[email protected]>
Sent: Tuesday, September 30, 2025 12:39 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Leanna Einbinder
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2589 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 32 David Yakobson
From: Bill Josephs <[email protected]>
Sent: Tuesday, September 30, 2025 4:06 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
William Josephs, 2454 23rd Street, Santa Monica, CA
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2590 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 33 David Yakobson
From: Taunya Post <[email protected]>
Sent: Tuesday, September 30, 2025 6:12 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Taunya Post
2247 24th street
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2591 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 34 David Yakobson
From: trisha roth <[email protected]>
Sent: Tuesday, September 30, 2025 6:25 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Trisha ROth
90405
Sent from my iPad
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2592 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 35 David Yakobson
From: trisha roth <[email protected]>
Sent: Tuesday, September 30, 2025 6:25 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Trisha Roth
90405
Sent from my iPad
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2593 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 36 David Yakobson
From: Isabel <[email protected]>
Sent: Tuesday, September 30, 2025 6:54 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Isabel Cardoso Ferreira
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2594 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Tracey Alexander <[email protected]>
Sent: Sunday, September 28, 2025 11:07 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2595 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2596 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Tracey
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2597 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Andrew Wilder <[email protected]>
Sent: Monday, September 29, 2025 4:27 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

It is housing apartheid and not what Santa Monica should stand for! This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing. This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Andrew Wilder
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2598 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: julie anderson <[email protected]>
Sent: Monday, September 29, 2025 3:46 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Julie Anderson
2641 4th St, #1
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2599 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Katherine Reuter <[email protected]>
Sent: Monday, September 29, 2025 3:56 PM
To: councilmtgitems
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

The city is now considering making this a permanent program. Key Problems:
 This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.
 The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.
 Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica. Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Katherine Reuter
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2600 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Elaine Becker <[email protected]>
Sent: Monday, September 29, 2025 4:09 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. Sincerely, [Your Name] 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2601 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: oesr <[email protected]>
Sent: Monday, September 29, 2025 4:15 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "inlieu" fee instead of building affordable housing. This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct.

In lieu fees have NEVER been successful dating back decades. If we want a diverse city then people need to live near each other. Separate buildings does not promote anything! Right now there is nothing in Santa Monica that is affordable and continuing ‘In Lieu’ fees will not promote affordable housing. It will only do what it always has – put off affordable housing.

Jane Dempsey
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2602 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: Debbie Millar <[email protected]>
Sent: Monday, September 29, 2025 4:25 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This program is a gimme to developers.

This program incentivizes the construction of 90% market-rate apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct.

A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Debbie Millar
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2603 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Laura Kachergus <[email protected]>
Sent: Monday, September 29, 2025 1:54 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Laura Kachergus
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2604 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: rob arocd.com <[email protected]>
Sent: Monday, September 29, 2025 2:34 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing. This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Rob Levin
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2605 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Mary Duprey <[email protected]>
Sent: Monday, September 29, 2025 2:35 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Council members,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Mary Duprey
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2606 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: Marilyn Elias <[email protected]>
Sent: Monday, September 29, 2025 2:36 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Marilyn Elias
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2607 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Hilary Galanoy <[email protected]>
Sent: Monday, September 29, 2025 12:06 PM
To: councilmtgitems
Cc: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu" fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Hilary Galanoy
2636 32nd Street
Santa Monica, CA 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2608 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Jerry <[email protected]>
Sent: Monday, September 29, 2025 12:09 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Jerry Nodiff
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2609 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Todd Sherman <[email protected]>
Sent: Monday, September 29, 2025 12:12 PM
To: councilmtgitems; Dan Hall; Lana Negrete; Ellis Raskin; Barry Snell; Caroline Torosis; Natalya Zernitskaya; Jesse Zwick
Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE! Please oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

EXTERNAL
To: Mayor Negrete and City Councilmembers
Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE! Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:
 This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.  The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.
 Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Todd Sherman
90405
Todd Sherman
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2610 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 2800 28th Street, Suite 130
Santa Monica, CA 90405
310.780.5565 mobile
310.664.6705 ext. 101
310.664.6706 (fax)
[email protected]
www.FirstPacific1.com
DRE #00925920
CONFIDENTIALITY NOTICE: This message and/or any attachment(s) is confidential and intended for the use only by the recipient(s). If you are not the intended recipient, you are not authorized to disclose, reproduce, or distribute the contents of this message. If this e-mail is received in error, please immediately notify the sender by reply e-mail and destroy all copies of the original message.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2611 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: Jackie Stansbury <[email protected]>
Sent: Monday, September 29, 2025 12:12 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
In addition to the following points, I want to say that I support AFFORDABLE housing. New structures that increase our city's density should be 100% affordable. A token few units does nothing to ease the issue of affordability. Further, it is time to define affordable. What is the dollar amount that can reasonably be charged to a minimum wage individual, or family that works 40 hours a week? If these rates are not pre-set, developers and landlords will never rent affordably. Meanwhile, they are destroying our city and quality of life.

I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. [email protected]
(310) 339-9417
Santa Monica, CA 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2612 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 6 David Yakobson
From: [email protected]
Sent: Monday, September 29, 2025 12:14 PM
To: councilmtgitems
Cc: councilmtgitems; Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Adrian Harewood
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2613 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 7 David Yakobson
From: Dannie Charney <[email protected]>
Sent: Monday, September 29, 2025 12:14 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Danielle Charney
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2614 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 8 David Yakobson
From: Aram Kadish <[email protected]>
Sent: Monday, September 29, 2025 12:15 PM
To: councilmtgitems
Cc: Caroline Torosis; Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. Sincerely, Aram Kadish
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2615 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 9 David Yakobson
From: Levin, Amy C <[email protected]>
Sent: Monday, September 29, 2025 12:18 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Amy Levin
90405
*****************************************
Amy Levin, LCSW, PhD
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2616 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 10 David Yakobson
From: Terrence Marre <[email protected]>
Sent: Monday, September 29, 2025 12:18 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Terrence Marre
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2617 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 11 David Yakobson
From: Kathleen Kelleher McCarthy <[email protected]> Sent: Monday, September 29, 2025 12:26 PM
To: councilmtgitems
Cc: Barry Snell; Caroline Torosis; Ellis Raskin; Dan Hall; Jesse Zwick; Lana Negrete; Natalya Zernitskaya
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Kathleen Kelleher McCarthy
1206 Grant St.

Santa Monica, CA
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2618 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 12 David Yakobson
From: Gail Block <[email protected]>
Sent: Monday, September 29, 2025 1:01 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2619 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 13 David Yakobson
From: Gail Block <[email protected]>
Sent: Monday, September 29, 2025 1:02 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
SDear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Gail Block
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2620 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 14 David Yakobson
From: Gail Block <[email protected]>
Sent: Monday, September 29, 2025 1:03 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
SDear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Gail Block
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2621 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 15 David Yakobson
From: Susan Shapiro <[email protected]>
Sent: Monday, September 29, 2025 1:09 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Susan Shapiro
90405
Sent from Outlook
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2622 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 16 David Yakobson
From: Elias <[email protected]>
Sent: Monday, September 29, 2025 1:19 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Elias Davis
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2623 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 17 David Yakobson
From: Wendy Dembo <[email protected]>
Sent: Monday, September 29, 2025 1:15 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Wendy Dembo
90403
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2624 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 18 David Yakobson
From: Patty McCollim <[email protected]>
Sent: Monday, September 29, 2025 1:50 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Richard Sproul
& Patty McCollim
90405

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2625 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Eleanor Huntington <[email protected]> Sent: Monday, September 29, 2025 9:56 AM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2626 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2627 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Eleanor
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2628 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: Leslie Neale <[email protected]>
Sent: Monday, September 29, 2025 10:18 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Leslie Neale
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2629 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: Michael Rosenberg <[email protected]>
Sent: Monday, September 29, 2025 10:18 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Michael Rosenberg
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2630 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 6 David Yakobson
From: Rosie Lee <[email protected]>
Sent: Monday, September 29, 2025 10:33 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Rosie Lee
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2631 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 7 David Yakobson
From: Lisa Golden <[email protected]>
Sent: Monday, September 29, 2025 10:39 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Lisa and Jonathan Balfus
2329 26th St
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2632 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 8 David Yakobson
From: Kate Coppess <[email protected]>
Sent: Sunday, September 28, 2025 6:27 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2633 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 9 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2634 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 10 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Kate
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2635 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 11 David Yakobson
From: Bronwyn Barkan <[email protected]>
Sent: Monday, September 29, 2025 10:55 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Caroline Torosis Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica. Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Bronwyn Barkan 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2636 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 12 David Yakobson
From: Mindi Shank <[email protected]>
Sent: Monday, September 29, 2025 11:00 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
You cannot claim to care about affordable housing ever again if you expand this hypocritical “program” that is yet another gift to developers. Maybe the city should be renamed “Developers’ Paradise” because it is no longer for the people who live here and have for decades. This is a shameful reversal of the very thing you claim to care about the most- housing affordability. Stop pretending that you care about the everyday people of Santa Monica. This shows staff and council are bought and paid for with this move and so many others that continuously GIVE to developers and contractors over the interests of the residents.

I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Mindi Shank
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2637 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 13 David Yakobson
From: [email protected]
Sent: Monday, September 29, 2025 11:01 AM
To: councilmtgitems
Cc: Caroline Torosis; Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing. This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions.

The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Kelly Hsiao
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2638 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 14 David Yakobson
From: Will von Bernuth <[email protected]>
Sent: Monday, September 29, 2025 11:05 AM
To: councilmtgitems
Cc: Caroline Torosis; Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

Key Problems:
 This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.  The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.
 Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Will von Bernuth
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2639 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 15 David Yakobson
From: Nancy Morse <[email protected]>
Sent: Monday, September 29, 2025 11:07 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: 9/30/25 item 11-A - Off-site Affordable Housing Pilot Program - OPPOSE!

EXTERNAL
To: Mayor Negrete and City Councilmembers
Subject: 9/30/25 item 11-A - Off-site Affordable Housing Pilot Program - OPPOSE! Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing. This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems:
• This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them.

This is not a path to an "affordable" Santa Monica.
• The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.
• Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Nancy Morse
90404
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2640 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 16 David Yakobson
From: Robert Bernstein <[email protected]>
Sent: Monday, September 29, 2025 11:23 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Robert Bernstein
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2641 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 17 David Yakobson
From: Gavin Scott <[email protected]>
Sent: Monday, September 29, 2025 12:02 PM
To: councilmtgitems
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
We oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This AugustSeptember pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Sincerely,
Gavin and Nicola Scott
1801 Marine Street
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2642 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Leslie Lambert <[email protected]>
Sent: Monday, September 29, 2025 9:27 AM
To: councilmtgitems
Subject: Item 11A

EXTERNAL
I am writing this as a resident but also in strong support of the Planning Commission's recommendations regarding the Affordable Housing Incentive Pilot Program.

I have serious reservations about the workability of Option 1, which is Developers' contribution of land and $150,000 per unit for the production of off site affordable housing. I strongly recommend that you solicit input from the nonprofit affordable housing development community as to whether this contribution is sufficient without requiring additional housing funding from the City or the State. As we all know, these housing funds are extremely limited. Further, use of these funds will trigger prevailing wages, which will increase development costs.

Allowing affordable housing developers to use 9% tax credits, instead of the Program's restriction to 4% tax credits, will help. But I believe that even that change may not be sufficient to cover the cost of producing affordable housing. Again, please consult affordable housing developers for their insight since they, more than anyone, know the cost of producing affordable housing. I would be happy to be proven wrong.

I applaud your efforts to increase housing production. However, it should not be at the expense of affordable housing. I suggest that you refer to the RHNA numbers which require far more affordable housing than market rate housing.

Thank you for your consideration.

Leslie Lambert
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2643 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Kevin McCarthy <[email protected]>
Sent: Monday, September 29, 2025 9:28 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Kevin McCarthy
1206 Grant St, Santa Monica, CA 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2644 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Lauren Wyka <[email protected]>
Sent: Monday, September 29, 2025 9:35 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

It would be nice to see you work more for the people who live here long term, so sad to see how this is going, without wanting insight from the residents. Extremely disheartening.

Sincerely,
Lauren Wyka
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2645 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: Cheryl Downey <[email protected]>
Sent: Monday, September 29, 2025 9:38 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Cheryl Downey
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2646 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 David Yakobson
From: Mary Hubbell <[email protected]>
Sent: Monday, September 29, 2025 9:41 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Mary Hubbell
90405
Sent from Mary's iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2647 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: MIke Choe <[email protected]>
Sent: Monday, September 29, 2025 9:13 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Sincerely,
Michael Choe
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2648 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Dolores <[email protected]>
Sent: Monday, September 29, 2025 9:09 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2649 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Judy Kruger <[email protected]>
Sent: Friday, September 26, 2025 2:01 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya
Cc: councilmtgitems; Jing Yeo; Judy Kruger; Paula Larmore; Bruce Fairty Subject: Agenda Item 11.A, Pilot Program to Incentive Housing - SUPPORT Attachments: 9.26.25 Chamber Letter to City.pdf

EXTERNAL
Good Afternoon Mayor Negrete and Councilmembers:

Please see attached letter in support of Council Agenda Item 11.A to be heard at City Council Meeting on September 30, 2025.

Thank you in advance for your consideration.

Best Regards,
Judy
Judy Kruger
CEO & President
213-703-1340
[email protected]
smchamber.com
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2650 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) September 26, 2025
City Council
City of Santa Monica
1685 Main Street
Santa Monica, CA 90401
Re: Agenda Item 11.A, Pilot Program to Incentive Housing - SUPPORT Dear Mayor Negrete and Councilmembers:

On behalf of the Santa Monica Chamber of Commerce, I am writing to support extension of the proposed pilot program to incentivize property owners and developers to move forward with building housing on sites that already have an approved (but not yet built).

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. The building permit data provided in the August 12th City Staff Report (page 4) regarding the limited number of multi-family housing units that have been constructed over the past 15 years and, particularly, the very low number of units that commenced construction in the past two years is alarming.

Given the stagnant state of multi-family housing production in Santa Monica, we appreciate the Council acknowledging that this type of bold action is necessary. Since the Council’s August 12th vote for a limited initial program (1,000-unit cap), the Planning Commission reviewed the program and unanimously recommended extension of the pilot program, including retaining all three options, with minor amendments.

Our Santa Monica businesses have continued to experience economic uncertainty and if the Council is successful at stimulating housing production with this pilot program, it will provide more opportunities for a “built in” local customer base to patronize our businesses.

Given the City’s low production of housing over the past few years and the overall difficult environment for obtaining the financing to move forward with housing projects, the Chamber requests that the City Council extend the pilot program to all sites that have approved housing projects.

Respectfully Submitted,

Judy Kruger
President & CEO
Board Executives
Chair
Paula Larmore
Harding, Larmore,
Kutcher & Kozal LLP
Past Chair
Charlie LopezQuintana
ETC Hotels
Treasurer
Addie VanGessel
Tavern on Main
Vice-Chair
Dustin Peterson
Fairmont Miramar
Hotel & Bungalows
Vice-Chair
Jeremy Rawitch
RAND
Vice-Chair
Vee Gomez
Beach Yoga SoCal
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Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2651 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 David Yakobson
From: Ethan Widlansky
Sent: Friday, September 26, 2025 3:35 PM
To: councilmtgitems
Subject: Off-site Affordable Housing Pilot Incentive Program Status Update - Planning Commission Recommendations
Attachments: Pilot Program Letter - Hamilton and Lambert.pdf Hi There—
I hope you’re well. Please find a letter attached to this email written by Chair Hamilton and Commissioner Lambert on behalf of the Planning Commission regarding Item 11-A OƯ-site AƯordable Housing Pilot Incentive Program Status Update.

Cheers,
Ethan
Ethan Widlansky (He/Him)
Staff Assistant, City Planning
santamonica.gov
Facebook | Twitter | Instagram
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2652 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Date: September 30, 2025
To: Mayor and City Council
From:

Joshua Hamilton, Chair, Santa Monica Planning Commission Leslie Lambert, Commissioner, Santa Monica Planning Commission Re: Off-site Affordable Housing Pilot Incentive Program Status Update - Planning Commission Recommendations
Dear Mayor Negrete, Vice Mayor Torosis, and Councilmembers, The Planning Commission respectfully submits this letter regarding the Off-site Affordable Housing Pilot Incentive Program status update scheduled for your consideration today. As noted in the staff report, the Planning Commission voted 7-0 on September 17, 2025, in support of the pilot program with suggested amendments. These amendments are: (i) extending the Pilot Program until expiration of the 6th Cycle Housing Element; and (ii) creating a monitoring program to ensure that the objectives of the AHPP are being met. We write to elaborate on our recommendations and express our strong support for this innovative approach to housing production.

Summary:

The Planning Commission views the Off-site Affordable Housing Pilot Program as a practical and creative way to accelerate the production of much needed market rate and affordable housing units while helping the City fulfill the intent of its Housing Element and comply with the 6th Cycle RHNA
This program takes into consideration the practical realities of building market rate housing in today's challenging development market. By providing developers the opportunity to break ground on much needed housing while setting aside resources for affordable housing developments, we create a pathway forward that serves multiple objectives.

The Planning Commission supported the 48-month window for pulling permits on affordable housing properties, particularly given that the penalty for missing this deadline is forfeiting the property to the City free and clear. While this represents a significant penalty, it provides a reasonable timeframe given the inconsistencies of state and local funding for affordable housing.

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2653 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Importantly, funding off-site affordable units creates opportunities for additional density on these sites and, most critically, enables leveraging Developer funds with Tax Credits and bond financing. This approach will result in a greater number of affordable units than would otherwise be provided on-site. However, assembling these additional financing sources requires time. Overall, the Commission thought that this was a fair trade-off.

We must emphasize a critical concern regarding the payment of In-Lieu Fees. Not every developer will own land free and clear that can be pledged towards their affordable housing obligation. Most will likely use the in-lieu fee option. However, there must be careful guardrails ensuring that funds deposited into the affordable housing trust fund, specifically from these resources, are used exclusively for housing and not diverted to other city obligations. If this core promise is broken, we have breached the promises of our AHPP goals, and the pilot program loses its moral justification and cannot be sustained.

Recommendations for Program Extension:

Policy Question 1 - Extension of Program: We strongly recommend extending the pilot program beyond the 1,000 unit cap through the end of the existing Housing Element period, set to expire in 2029. As noted in the staff report, there are approximately 3,300 market rate and 800 affordable housing units that could be eligible for the program. These units are in projects that are fully entitled and ready to start. Given the scale of our housing needs and the fact that six applications, totaling approximately 1,000 units, have already been submitted under the Pilot Program, the need for this program is being demonstrated.

The Commission also recommended that the Program be extended until expiration of the 6th Cycle Housing Element in 2029. The Pilot Program should be monitored on an ongoing basis to ensure that the City's objectives under the AHPP program are met.

Policy Question 2: Moderate Income Units: Although the Commission recognizes that including moderate income units in the Pilot Program would render the off-site affordable housing projects infeasible and is not recommending their inclusion, the need for moderate income housing production is great. The RHNA Moderate Income goal is 1,702 units. The City is nowhere near meeting this objective. Since there are no public housing dollars for moderate income housing, creative incentives must be developed. While the Planning Commission did not specifically address this question at our September 17 meeting, the Commission has consistently voiced strong support for essential housing for middle income families in other discussions. The Housing Element establishes broad goals of serving diverse household types and income levels and specifically created a Moderate Income Housing Overlay to encourage construction through height and density flexibility near transit. The effectiveness of this program, from a feasibility standpoint, must be Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2654 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) evaluated and an alternative approach developed if necessary. The Planning Commission will study this issue further, but there is generally broad consensus that essential housing for middle-income families is in critically short supply and represents a high policy priority.

Policy Question 3: Option 1 Milestones: As noted in the summary, the Planning Commission expressed support for the proposed milestones due to the severe penalties of non-compliance. Given the practical realities of assembling financing for an affordable housing project, the Planning Commission accepted the timeframe proposed by staff.

Policy Question 4 - Gap Financing Amount: We encourage the City Council to revisit the workability of the $150,000 per unit figure. There is concern in the non-profit development community that $150,000 plus land may not result in covering the full cost of developing an affordable housing unit and that additional housing subsidies will be necessary. Given the lack of housing funds, this could result in unbuilt affordable housing. Two alternatives for preventing this undesirable outcome would be to (i) increase the per unit developer contribution; or (ii) allow the affordable housing developer to use 9% Tax Credits. While the Commission agreed that the gap financing amount should be re-evaluated and possibly increased, we want to ensure that market rate units remain financially viable. We suggest that staff confirm that affordable housing developers consider this developer contribution to be adequate without additional housing funding.

Policy Question 5 - At-Risk Units: The Planning Commission did not extensively discuss using Pilot Program funds for unit preservation, nor did it recommend the inclusion of such units in the Pilot Program. Given the practical constraints and limited funding of this new program, it is not feasible at this time to include these units. However, the City Council should explore future program alternatives for preserving units threatened by expiring covenants. The Commission also discussed the issue of encouraging the Program’s off-site acquisition and rehabilitation projects in neighborhoods where low income tenants are rent burdened.

We urge the City Council to extend this program until expiration of the 6th Cycle Housing Element and to implement the oversight mechanisms necessary to ensure its success and integrity.

Respectfully submitted,
Joshua Hamilton, Chair, Santa Monica Planning Commission Leslie Lambert, Commissioner, Santa Monica Planning Commission cc: Jing Yeo, Director, City Planning
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2655 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 1 David Yakobson
From: Santa Monica Forward <[email protected]> Sent: Sunday, September 28, 2025 10:04 AM
To: Dan Hall; Jesse Zwick; Natalya Zernitskaya; councilmtgitems; Ellis Raskin; Lana Negrete; Barry Snell; Caroline Torosis; Oliver Chi; Council Mailbox Cc: Bradley Ewing; Carl Hansen; [email protected] Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

EXTERNAL
Councilmembers,
The upcoming decision on how to extend the Off-site Affordable Housing Pilot Program is a crucial opportunity to address our housing crisis. The consideration of this policy should be viewed through the lens of broader principles in addressing our housing crisis. This letter sets out those principles & their application to specific policy questions the Council faces, as posed by the staff report. The off-site program has been an early success with more than 1,000 units applying to use it. Council should build on that momentum and the excitement that will be created by seeing projects get started by opening the program to new developers, while avoiding any changes which would increase costs or otherwise undermine pro-housing goals.

1. To address our housing crisis, Santa Monica needs significantly more housing than our RHNA goals require, and the city must affirmatively further fair housing. This implies:
a. Question 1: Alternative: The city should remove the cap on the number of units or projects that can use the program, and should open the program to new applicants (not yet entitled projects), with no defined end date.
b. The city should not impose limitations that run against AFFH, such as restricting projects to downtown. Limiting affordable projects to outside the Pico neighborhood does not conflict with AFFH, and is appropriate.

2. The city policy, including the off-site program, should facilitate the financial feasibility of market rate development. Requirements and costs that lead to projects stalling must be eliminated. Further, the city should regularly re-evaluate whether new housing is financially feasible under current rules and adjust policy.
a. Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b. Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c. Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced.
d. Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2656 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 2 lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements

2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Thank you,
Brad Ewing and Carl Hansen, Co-Chairs
Sam Shapiro-Kline, Vice Chair
Santa Monica Forward
--
We are working for a diverse, progressive, sustainable and equitable Santa Monica.

SantaMonicaForward.org
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2657 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 3 David Yakobson
From: Frank Gruber <[email protected]>
Sent: Sunday, September 28, 2025 10:38 AM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

EXTERNAL
Council Comments Council Comments,
Councilmembers,
The decision on how to extend the Off-site Affordable Housing Pilot Program is an opportunity to increase housing production, both market rate and affordable. I urge you to extend the program. We need more flexibility, not less, in how we allow for housing development. For too long idealistic but unrealistic goals have hindered housing production. Non-profit developers like CCSM have shown that affordable housing can be most effectively delivered in small 100% affordable projects. Unbundling affordable from market-rate is a way to help make this happen.

As for the details regarding costs and accountability, etc., I trust you to make informed and beneficial choices. But please extend the off-site affordable housing ordinance into an ongoing and open program that works and which would not stop new housing.

Thanks,
Frank Gruber
Frank
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2658 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 4 David Yakobson
From: Kent Strumpell <[email protected]>
Sent: Sunday, September 28, 2025 2:22 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2659 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 5 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2660 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 6 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Kent
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2661 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 7 David Yakobson
From: Sam Shapiro-Kline <[email protected]>
Sent: Sunday, September 28, 2025 5:49 PM
To: Dan Hall; Natalya Zernitskaya; Barry Snell; Caroline Torosis; Jesse Zwick; Ellis Raskin; Lana Negrete; councilmtgitems; Oliver Chi
Subject: 11.A Extend, Open-Up, & Enhance the Offsite Affordable Housing Program

EXTERNAL
Hello Council,
I concur with the views of Santa Monica forward on the off-site ordinance. There are a couple points I would like to highlight for why opening the ordinance to new applicants and not introducing any constraints that reduce project feasibility will be so valuable for our city.

In-Lieu Fee is an AH Multiplier: Big Affordable projects at 4th/Arizona and Bergamot will imminently need more funds for gap financing. With 1,069 potential affordable units across these sites, and a gap comparable to the PS3 project of ~$100K per unit (vs. $150K + Land on sites not owned by the city), that means the city needs to find $107M. Meanwhile, GS has raised ~$15M thus far for AH production. At its current rate, the in-lieu fee inducing the creation of ~2,000 units would produce $50-80M in funds that could be used to deliver Arizona and Bergamot. This could translate to 500-800 units of affordable housing, vs. 200 units via our standard onsite rules.

Changing the Narrative: The current narrative around the city has been negative, with retail vacancy, persistent homelessness, and declining tourism. Unlocking housing development would change how Santa Monica is perceived, as a booming city with skyscrapers going up downtown, and new residents moving in. Businesses will see those articles and look to invest, driving our economy and tax base.

In the spirit of the Jewish high holidays, I’d draw an analogy to a book which I was fond of as a child - Herschel and the Hanukkah Goblins. In this book, the hungry goblin reaches into a pickle jar, and when trying to grasp all the pickles at once finds he cannot remove his hand from the jar. The goblin cries to Herschel that he is trapped, blaming Herschel for his predicament. Herschel tells the goblin that all he must do is release the pickles and his hand will be free.

This story rings true in our current predicament, as Santa Monica has historically asked for all the pickles (i.e., affordable units, fees) and come up with nothing as a result, leading to a crisis. Hopefully now we can be wiser, and extract the pickles one by one.

Thanks,
Sam Shapiro-Kline
Vice Chair, Santa Monica Forward
Measure GS Resident Oversight Committee
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2662 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 8 David Yakobson
From: Genevieve Cabanilla <[email protected]> Sent: Sunday, September 28, 2025 7:53 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2663 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 9 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2664 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 10 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Genevieve
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2665 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 11 David Yakobson
From: Alex Novakovich <[email protected]>
Sent: Sunday, September 28, 2025 10:31 PM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Alex Novakovich
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2666 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 12 David Yakobson
From: Miles Freeman <[email protected]>
Sent: Sunday, September 28, 2025 10:32 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2667 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 13 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2668 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 14 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Miles
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2669 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 15 David Yakobson
From: Todd Lynch <[email protected]>
Sent: Sunday, September 28, 2025 9:19 PM
To: councilmtgitems
Subject: 11.A Support Extension and Opening of Off-site Program to New Applicants

Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2670 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 16 a) Question 3: SMF supports accountability measures so long as they do not impact project feasibility. On this question, we defer to whether Staff can create an appropriate solution that is acceptable to housing developers.
b) Question 4: No: The $150,000 Gap Financing amount should not be increased, as it has been carefully calculated leveraging an external consultant using real financial figures to assess feasibility. The city should not contradict its own analysis by raising the gap amount, which could cause projects to become infeasible. Whether the city council chooses the “No” option or “Alternative” to regularly re-evaluate cost levels, the city must review whether overall housing policy leads to construction.
c) Question 6: No: 1 project, at 2906 Santa Monica, has applied to use the In-lieu fee, indicating that at it’s current rate the in-lieu fee may result in projects becoming feasible. The city cannot afford to delay projects moving forward by pausing Option 3 in favor of another study (which entails additional cost that the city cannot afford). Rather, Option 3 should move forward with existing in-lieu fee rates, and the city should re-consider those rates 6 months from now depending on whether housing is being produced. d) Additionally, Santa Monica’s strongest path for producing large amounts of affordable housing at a low cost is through quickly building the 1,069 units projected for the surplus lands at 4th/Arizona and Bergamot. Whether or not the in-lieu fee is a precise 1-1 replacement for an affordable housing unit, these fees will be highly valuable in supporting building units that have lower gap financing requirements due to use of the city’s surplus land. Avoiding delay and generating these fees, which can be paired with Measure GS funds, will be crucial to having sufficient support when affordable housing developers are poised to build more than 1,000 units on those two sites. A rough estimate would indicate a need for ~$100M in gap financing for 1,069 units, which significantly exceeds the capacity of the city’s Housing Trust Fund today.

In the spirit of allowing further flexibility to enable housing production, Santa Monica Forward is supportive of Yes on both Option 2 (Moderate Income Units) and Option 5 (At-Risk Rehab).

Please vote to support the following on each Option:

1. Alternative: No cap, open to new entitlements
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2671 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 17 2. Yes

3. Yes, only if demonstrated that this will not cause projects to become infeasible

4. No or Alternative

5. Yes

6. No
Todd
California
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2672 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 18 David Yakobson
From: Holly Silvers <[email protected]>
Sent: Monday, September 29, 2025 6:08 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Holly Granelli
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2673 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 19 David Yakobson
From: John Reynolds <[email protected]>
Sent: Monday, September 29, 2025 6:16 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. Sincerely, John Reynolds 17th street, SM 90405 Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2674 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 20 David Yakobson
From: Josh Marcus <[email protected]>
Sent: Monday, September 29, 2025 6:19 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Joshua Marcus
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2675 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 21 David Yakobson
From: [email protected]
Sent: Monday, September 29, 2025 6:20 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Megan FitzGerald
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2676 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 22 David Yakobson
From: Danielle Borgia <[email protected]>
Sent: Monday, September 29, 2025 6:29 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2677 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 23 David Yakobson
From: Karen Taylor <[email protected]>
Sent: Monday, September 29, 2025 6:32 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses and reap even bugger profits, while failing to deliver on integrated, affordable housing? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Karen Taylor
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2678 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 24 David Yakobson
From: Brian Lanich <[email protected]>
Sent: Monday, September 29, 2025 6:36 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Brian Lanich
90405
Brian Lanich
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2679 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 25 David Yakobson
From: Jenny Blum <[email protected]>
Sent: Monday, September 29, 2025 6:43 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Jennifer Blum
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2680 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 26 David Yakobson
From: Alan Kerner <[email protected]>
Sent: Monday, September 29, 2025 6:43 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Alan Kerner
1761 Sunset Ave
90405
Sent from my iPad
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2681 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 27 David Yakobson
From: Tom Nunziato <[email protected]>
Sent: Monday, September 29, 2025 6:48 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Get Outlook for iOS
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2682 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 28 David Yakobson
From: Betty Green <[email protected]>
Sent: Monday, September 29, 2025 6:51 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name] Betty Green 90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2683 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 29 David Yakobson
From: Lynda M Rush <[email protected]>
Sent: Monday, September 29, 2025 7:10 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Lynda Rush
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2684 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 30 David Yakobson
From: Mayra Herrera <[email protected]>
Sent: Monday, September 29, 2025 7:19 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Mayra Herrera
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2685 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 31 David Yakobson
From: Tina <[email protected]>
Sent: Monday, September 29, 2025 7:23 AM
To: councilmtgitems; [email protected]
Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program. This August-September pilot program incentivized luxury housing construction by allowing developers to either (a) build required affordable units off-site within 4 years (segregating low-income housing), or (b) pay a minimal $135,000 "in-lieu" fee instead of building affordable housing.This was in theory to address housing projects that had been permitted, but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program. Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit? A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Tina Cox
90405
Tina
"Time spent with cats is never wasted"
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2686 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 32 David Yakobson
From: RONNA JOSEPH <[email protected]>
Sent: Monday, September 29, 2025 7:29 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Ronna Joseph
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2687 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 33 David Yakobson
From: Allyson Dworkin <[email protected]>
Sent: Monday, September 29, 2025 7:39 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Allyson Dworkin
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2688 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 34 David Yakobson
From: Faustino Garza <[email protected]>
Sent: Monday, September 29, 2025 7:41 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2689 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 35 David Yakobson
From: REM Thimble <[email protected]>
Sent: Monday, September 29, 2025 7:50 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Sent from my iPad
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2690 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 36 David Yakobson
From: mwdobbs <[email protected]>
Sent: Monday, September 29, 2025 7:55 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them.

This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Michael Dobbs
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2691 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 37 David Yakobson
From: Jenny Monbouquette <[email protected]>
Sent: Monday, September 29, 2025 7:56 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Jenny Monbouquette
90405
Jenny Monbouquette
(310)266-3665
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2692 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 38 David Yakobson
From: The Gold Stanley <[email protected]>
Sent: Monday, September 29, 2025 8:17 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
[Your Name]
90405
Sent from my iRaPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2693 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 39 David Yakobson
From: Harold Monbouquette <[email protected]>
Sent: Monday, September 29, 2025 8:36 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Harold Monbouquette
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2694 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 40 David Yakobson
From: Ellen Hiura <[email protected]>
Sent: Monday, September 29, 2025 8:41 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Ellen Hiura
90405
Sent from my iPhone
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2695 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 41 David Yakobson
From: Geoff Coster <[email protected]>
Sent: Monday, September 29, 2025 8:48 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Geoff Coster
90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2696 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 42 David Yakobson
From: Phyllis Chavez <[email protected]>
Sent: Monday, September 29, 2025 9:00 AM
To: councilmtgitems
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

This was in theory to address housing projects that had been permitted but not constructed because the developers claimed they couldn't start construction due to adverse economic conditions. The city is now considering making this a permanent program.

Key Problems: This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica. The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference. Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Phyllis Chavez
Sunset Park/90405
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2697 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) 43 David Yakobson
From: Karen Melick <[email protected]>
Sent: Monday, September 29, 2025 8:54 AM
To: councilmtgitems
Cc: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Subject: Subject: 9/30/25 item 11-A -- Off-site Affordable Housing Pilot Program -- OPPOSE!

EXTERNAL
Dear Mayor Negrete and City Councilmembers,
I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Key Problems:

This program incentivizes the construction of 90% market-rate luxury apartment buildings, with less than 10% affordable units tied to them. This is not a path to an "affordable" Santa Monica.

The $135,000 "in lieu "fee is far below actual construction costs ($500K-$1M per unit), leaving taxpayers to cover the difference.

Developers get to keep massive profits and density bonuses originally granted for building affordable units that they no longer have to construct. Why should they be allowed to take away Santa Monica's blue sky with their height bonuses, while they enjoy even more profit?
A yes vote would be a bargain for developers and result in a loss of affordable housing for Santa Monica.

Again, I oppose expanding or making permanent the Off-site Affordable Housing Pilot Program.

Sincerely,
Karen Melick
Sunset Park resident
Item 11-A
September 20, 2025
Item 11-A
September 20, 2025

11.A.a
Packet Pg. 2698 Attachment: Written Comments [Revision 3] (7265 : Off-site Affordable Housing Pilot Incentive Program) Off-Site Affordable Housing
Pilot Incentive Program
City Council
September 30, 2025
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2699 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Purpose
• Provide update on program status
• Summarize results of additional outreach to affordable housing providers and review of public comments
• Receive direction on 7 policy questions on next phase of the pilot program Purpose
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2700 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) • Pilot program adopted on August 12, responsive to June 10 Council direction • Program objectives included:
• Target projects that have received their approvals prior to August 12, 2025 in order to unlock “frozen” units
• Consistent with Housing Element Program 2.C, provide 3 new options to comply with AHPP
• Increase flexibility in off-site affordable housing option by removing requirement that CofO for affordable housing project be issued before CofO for market rate project • Create new local density bonus program
• Limited to 1,000 units or until September 30, 2025 whichever comes first [return to Council on Sept 30]
Review Pilot Program Objectives
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2701 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program)  Be multiple-unit project of 6 units or more
 Have obtained final approval of all required discretionary and ministerial City permits, on or before August 12, 2025
 AB130 time limits do not apply to previously approved projects  Cannot be under construction or have been completed
 A previously approved project can be redesigned and approved prior to December 31, 2026  Could use new standards for housing projects and new pilot program potentially resulting in more units
Pilot Program Eligibility
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2702 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Pilot Program Options
• Option 1: Alternative Site
• Construct same number of off-site affordable units (all lower income) after the market rate project begins construction
• Pay gap financing at $150,000 per unit (assumes 4% tax credits) • Option 2: Rehabilitation Option
• Complete substantial rehabilitation of existing units in a number equivalent to required off-site affordable units
• Option 3: In-Lieu Fee Option
• Pay in-lieu fee of $43.91/sf for apartments and $51.30/sf for condominiums per off-site affordable housing unit (adjusted annually) into Housing Trust fund Pilot Program Options
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2703 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Program Status Updates • 6 applications received for 1,018 units • 5 for off-site option
• 1 for in-lieu fee option
Option 3 Estimated
In-LIeu Fee
Option 3
Project SF
Option 1 # of OffSite Affordable
Units
Option 1 Off-Site Property
Pilot
Program
Option
Chosen
# of Previously
Approved OnSite Affordable
Units
# of Previously
Approved
Market Rate
Units
Project Address Total Units
1333 7 14 N/A -
th 1902 Wilshire 140 126 14 1 St*
1143-1145 25 21 N/A -
th 1527 Lincoln 210 189 21 1 St
1333 7 17 N/A -
th 2501 Wilshire 170 153 17 1 St*
1333 7 15 N/A -
th 150 135 15 1 St* 2025-2037
Wilshire
1143-1145 25 26 N/A -
th 1931 Wilshire 260 234 26 1 St
88 79 9 3 N/A - 51,189 sf $2,247,708.99 2906 Santa
Monica
Total 1,018 916 102 93
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2704 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Program Status Updates • Website launched • https://www.santamonica.gov/status -of-development-projects • Click on “Status of Off-Site Affordable Housing Pilot Program • 1,000 unit cap reached – program is no longer available unless
Ordinance is extended and
amended
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2705 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Roundtable - Affordable Housing Providers
• September 17, 2025 - City hosted workshop to solicit input from representatives of the following affordable housing providers:
• Community Corporation of Santa Monica
• Hollywood Community Housing
• EAH Housing
• Thomas Safran & Associates
• Venice Community Housing
• Abode Communities
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2706 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Roundtable – Affordable Housing Providers • Eligibility of At-Risk Units • Expand Option 2 to include affordability for at-risk units (i.e., affordable-deed restricted units with covenants imminently at risk of expiring and converting to market rate) • Moderate Income Housing • Expand Option 1 to include moderate units or allow fees from Option 3 to be used for moderate units • Option 1 Gap Financing
• Concern that gap financing amount of $150,000 is too low even with 4% tax credits and additional funding may be needed • Competition for Financing
• Concern that the program could add more competition into an already competitive financing landscape • Concern about how competitive these developments would be without the public subsidy leveraging points from TCAC
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2707 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Other Comments Received
• Santa Monicans for Renters’ Rights (SMRR) • Require completion of development milestones for off-site affordable housing • Increase Option 1 gap financing amount to account for construction cost escalation, on-site parking, and prevailing wage
• Increase Option 3 in-lieu fee to reflect actual cost of construction • Require program participants to commit to paying Measure GS tax upon sale of the project • Planning Commission discussed at 9/17/25 meeting and voted for Council to consider following minor amendments to the program: • Extend pilot program to end of 6th Cycle Housing Element • Allow pilot program to include moderate-income units • Actively monitor progress and success of the program
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2708 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Program Results • The stated purpose of program was to allow flexibility for market rate projects in how they provide affordable housing units, in an effort to spur housing production • Based on policy objective, objectives were met – market rate development has been spurred, which has also led to the advancement of affordable housing unit development • Of note, the program has inherent tradeoffs between prioritization of affordable housing vs. reducing economic uncertainty to produce housing for market rate projects • These two goals may be in conflict because increasing the requirements for off-site affordable housing may impact the financial feasibility of producing market rate housing
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2709 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 1
Extension of Program
• Background
• Total 1,000 unit cap has been reached with initial 6 applications • Approximately 3,000 units in 30 housing projects could be eligible for the program • Should the program be extended beyond the 1,000 unit cap that was established on August 12?
• YES MEANS…continue the program and allow additional market-rate projects approved as of August 12, 2025 to utilize this program
• NO MEANS…do not continue the program. • ALTERNATIVELY…continue the program and establish a new cap or other limit for the program.

Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2710 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 2
Expansion of Option 1 to Allow Moderate Income Units
• Background
• Public comments and feedback from additional outreach requested flexibility to allow moderate income units in off-site affordable housing if developer is not using tax credit funding • Should Option 1 be modified to allow moderate units?
• YES MEANS…the ordinance would be amended to require that off-site affordable units be deedrestricted for lower income OR moderate income households. • NO MEANS…the ordinance would continue to require that off-site affordable units only be for lowerincome households.

Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2711 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 3
Option 1 Milestones
• Background
• Public comments and additional outreach have expressed concern that the pilot program does not provide assurance that off-site affordable will be constructed Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2712 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 3
• Should permitting milestones for the off-site affordable housing project be required for Option 1?
• YES MEANS...the ordinance would be amended to establish milestones that may include: • Submit application for off-site affordable housing project prior to issuance of building permit of market rate • Complete plan check process for the off-site affordable housing project prior to CofO for market rate • Allow the City to exercise its option on the off-site property, draw down on the gap financing, and receive an assignment of architectural and construction plans for the off-site housing development early if the developer does not complete the plan check process within a certain timeline of pulling a building permit on the market rate project • NO MEANS…timeline requirements remain unchanged Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2713 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 4
Option 1 Gap Financing Amount
• Background
• Public comments and additional outreach have expressed concern that the $150,000/unit gap financing is too low
• Particular concern if land is given to the City due to prevailing wage requirements and likelihood that affordable housing provider will include on-site parking • Increasing gap financing amount is a policy decision that may affect feasibility of market rate project • Staff assessment of our past 6 affordable housing projects funded with Housing Trust Fund dollars identified a comparable gap financing amount of $158,781 / unit, assuming a 5% per year escalation factor since the acquisition of the project
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2714 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 4
Should the gap financing amount be modified?
• YES MEANS…increase and establish a new amount • If there is interest in feasibility considerations, staff can also return to Council with additional analysis on recommended gap financing accounting for on-site parking, unit types, and providing information regarding the effect of prevailing wages. • NO MEANS…$150,000 gap financing per unit would remain unchanged. • ALTERNATIVELY…keep the gap financing amount at $150,000 per unit • Remove 5% annual cap on escalation • Replace with requirement that the amount would be reviewed and updated annually by Council resolution based upon construction cost index
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2715 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 5
Expansion of Option 2 (Rehabilitation) to Include At-Risk Units • Background
• Public comment received that Option 2 should be expanded to include at-risk units • Should Option 2 be expanded to include At-Risk units? • YES MEANS…the ordinance would be amended to include At-Risk units in Option 2 • NO MEANS…At-Risk units would not be eligible for Option 2 Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2716 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Policy Question 6
Option 3 In-Lieu Fees
• Background
• Public comment received that Option 3 in-lieu fees are too low • Updated nexus study would likely be required to establish new fee • Should the in-lieu fee payment be modified?
• YES MEANS…the in-lieu fee should be modified. If modified, a new nexus study would be required. The nexus study would require cost and time, estimated at several months. • NO MEANS…the in-lieu fee would remain unchanged and would increase only annually in accordance with construction cost index
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2717 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Response to Comments on Measure GS
Measure GS Tax Commitment
• Background
• Public comment has been received stating that participants in the program should commit to payment of Measure GS tax
• There have been attempts to modify property transfer tax requirements in California. • Should the City attempt to establish a provision requiring developers electing to participate in the pilot commit to payment of our Measure GS tax, or an equivalent amount should the law change?
• YES MEANS…the City would identify potential options to require payment of Measure GS tax amounts upon the sale of a project participating in the program. • NO MEANS…if changes to the law negate Measure GS, projects participating in the program may be exempted from paying the tax.

Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2718 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) Questions?
Item 11-A
September 30, 2025
Item 11-A
September 30, 2025

11.A.b
Packet Pg. 2719 Attachment: PowerPoint Presentation (7265 : Off-site Affordable Housing Pilot Incentive Program) City Council
Report
City Council Meeting: September 30, 2025
Agenda Item: 11.B
1 of 9
To: Mayor and City Council
From: Oliver Chi, City Manager, City Manager's Office, Administration Subject: Considerations for Reforming the Neighborhood Organization Grant Program Recommended Action
Staff recommends that the City Council:

1. Review and comment on the Neighborhood Organization Grant program policy options and direct staff on how to proceed with program; and

2. Council adopt a finding of no possibility of significant effect pursuant to Section 15061(b)(3) (Common Sense Exemption) of the California Environmental Quality Act (CEQA) Guidelines.

Summary
Santa Monica has a long tradition of supporting neighborhood organizations as important partners in civic engagement, communication, and community building.

These organizations provide forums for dialogue on public safety, mobility, land use, and resilience planning, while also ensuring that residents maintain a direct connection with the City.

Currently, the City provides funding to seven neighborhood organizations through the Neighborhood Organization Grant Program (NGP), which allocates up to $7,000 annually per group for outreach, events, and communications. Allowable uses include newsletters, community meetings, and civic activities. Political activity has always been restricted, and recipients must disclaim on their websites that City funds are not used for political purposes.

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At the July 8, 2025, meeting, Council raised concerns following political endorsements made by at least two neighborhood organizations during recent elections. While such endorsements may be permissible under some federal nonprofit designations, Council directed staff to review the NGP framework and identify options to ensure that City resources and communication platforms are not connected to political activities. The program remains suspended pending Council’s review.

With the goals of civic engagement, accountability, and transparency of the use of public funds, staff undertook a review of the NGP program aimed at achieving the following objectives:
• Ensure every resident has equitable access to information. • Provide fair and transparent use of taxpayer funds.
• Support inclusive community engagement while maintaining compliance with legal standards.
• Clarify the boundaries between civic participation and political activity.

Through this assessment, staff has developed several different policy options for Council consideration. For those community groups that seek formal status as officially recognized City recognized neighborhood organization through the NGP program, staff has identified three primary options for consideration:
• Option 1: Provide Participating Groups With Enhanced Communications Support
Through this option, the City Council could choose to reinstate Seascape magazine, provide an annual City-funded mailer for each recognized neighborhood group, and / or maintain City communication platforms for compliant organizations.

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• Option 2: Modernized Neighborhood Organization Program Continue to provide grant funding to each recognized participating group (e.g., $5,000 / group per year), and consider an equitable distribution formula based on the number of households in the boundaries of each organization (e.g., $0.50 / household). In addition, modernization could also require each group that chooses to participate in the NGP to enter into a formal participation agreement with the City, whereby funds would only be allowed for use on neutral civic activities, while also establishing a five-year program ineligibility penalty (including removal from City publications) for groups engaging in political endorsements.
• Option 3: In-Kind Support and Civic Engagement Enhancements Provide in-kind support such as fee waivers for neighborhood events and cosponsorship of eligible activities, and perhaps also expand voter engagement activities through the reinstatement of City-sponsored election forums.

Of note, these above identified options may be pursued individually or combined to create a comprehensive framework that balances civic engagement, accountability, and clear boundaries between civic and political activity.

Background
Neighborhood Organizations in Santa Monica
Santa Monica’s neighborhood organizations vary in structure and scope. Some are organized as 501(c)(3) nonprofits, while others are 501(c)(4) social welfare organizations. Together, the seven formally recognized groups represent over 50,000 households across the City:
• Friends of Sunset Park (7,193 households)
• North of Montana Association (5,084 households)
• Ocean Park Association (8,033 households)

11.B
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• Pico Neighborhood Association (7,476 households)
• Mid City Neighbors (7,972 households)
• Northeast Neighbors (1,622 households)
• Wilshire Montana Neighborhood Coalition (12,560 households) Santa Monica’s Currently Recognized Neighborhood Organization Boundaries Participation has historically been voluntary, with no formal City ordinance defining neighborhood organizations. Recognition has flowed primarily through eligibility for NGP funding.

Evolution of the Grant Program
The NGP was established when the City ended its direct production of mailed newsletters (Seascape and district mailings), shifting outreach responsibilities to neighborhood groups. Since then, grants have primarily been used to fund physical

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newsletters mailed to households, supplemented by neighborhood meetings and events.

While the City has expanded its digital-first communications (including SaMoNews, santamonica.gov, and social media), neighborhood groups argue that physical newsletters remain an essential tool for reaching residents – particularly older adults and those not digitally connected.

Current Program Requirements
For a neighborhood organization to participate in the NGP program, that group must meet criteria such as:
• Tax-exempt nonprofit status (501(c)(3) or 501(c)(4)). • Public bylaws and open meetings.
• An active board of directors.
• At least one general membership meeting annually.
• A membership threshold (50 households or 10% of eligible households).

Allowable uses of grant funds include printed newsletters, event support, organizational tools (databases, websites), and training. A closeout process requires documentation of expenditures and review by City staff.

Comparative Practices
Santa Monica’s approach to neighborhood funding is unusual relative to peer cities.

Based on staff research, practices in other jurisdictions include:
• Mountain View: Provides smaller, reimbursement-based grants ($1,333–$3,333 annually), prorated by association membership. Explicitly prohibits use for

11.B
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political activity or routine business. Offers a one-time $7,500 startup grant for new groups.
• Palm Springs: Coordinates 52 associations through a dedicated Office of Neighborhoods and a 501(c)(4) umbrella group (ONE-PS). Modest funding ($8,000 total plus $250 per group) emphasizes engagement rather than direct subsidies. Developers must present projects to neighborhood groups before Council review.
• West Hollywood: Supports about 10 neighborhood watch groups with in-kind fee waivers and reimbursement-based support for National Night Out events.

Explicit exclusions for political activity and non-civic expenditures.

These models reflect a broader trend: cities are shifting toward event-based support, reimbursement systems, and clear guardrails, rather than the broad and relatively higher direct funding seen in Santa Monica.

Legal Considerations
The City has discretion to impose conditions on its funding programs under the Spending Clause of the U.S. Constitution (Art. I, sec. 8, cl. 1). Conditions must be clear, related to the program’s purpose, and not otherwise unconstitutional. If groups object, their recourse is to decline participation.

IRS rules also already limit political activity:
• 501(c)(3) organizations are strictly prohibited from endorsing candidates or engaging in substantial lobbying.
• 501(c)(4) organizations may engage in political activity, provided it is not their primary activity.

City-imposed restrictions can supplement these federal rules by creating programspecific requirements associated with the choice made by an organization to apply for NGP program participation (e.g., no endorsements, five-year ineligibility for violations).

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Importantly, restrictions would apply only as a condition of City recognition or funding, not to independent organizational activity outside the City’s program.

Options Identified for Council Consideration
In response to Council’s request to identify ways of addressing political activity by neighborhood groups while maintaining the City’s longstanding commitment to civic engagement, staff has identified the following options:

Option 1: Provide Participating Groups With Enhanced Communications Support • Consider reinstating Seascape magazine as a City-managed publication, with dedicated space for neighborhood content (estimated cost: $200,000 annually). • Alternatively (or in combination), consider providing each recognized neighborhood group with one annual City-funded postcard mailer (estimated cost: $50,000 annually).
• Continue listing neighborhood groups on City platforms, limited to those in compliance with program terms.
• Pros: Improves equitable access to information; reestablishes a valued citywide communication tool.
• Cons: Additional ongoing City costs.

Option 2: Modernized Neighborhood Organization Program
• Maintain modest grant funding but distribute equitably scaled by households (e.g., $0.50 / household) or standardized flat amounts(e.g., $5,000 / group). • Require formal participation agreements with all groups. • Limit grant uses to neutral civic activities (mailings, clean-ups, safety planning). • Establish clear guardrails for any group electing to apply for the NGP program to be recognized as a formal City neighborhood organization:
o Explicit prohibition on political endorsements.
o Five-year ineligibility for groups that engage in such activity, including removal from City publications and communications as a recognized neighborhood organization.

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• Pros: Creates fairness, transparency, and clear boundaries between civic and political activity.
• Cons: May be perceived as restrictive by some groups.

Option 3: In-Kind Support and Civic Engagement Enhancements • Replace or supplement direct funding with in-kind support, such as fee waivers for community events (block parties, neighborhood cleanups, movie nights). • Provide City co-sponsorship of eligible neighborhood events. • Consider reinstating City-hosted election forums, to provide a neutral access program to candidates and create a more inclusive voter engagement process. • Pros: Expands civic participation while reducing reliance on cash grants. • Cons: Limits organizational autonomy and flexibility.

Financial Impacts / Budget Actions
There is no immediate budget action required with this report. However, based on City Council determinations, actions that require funding adjustments will be assessed and integrated into the broader Citywide fiscal stability plan being developed by staff for presentation in October. An overview of the actions that could have a budgetary impact includes:
• Current suspension of the NGP program has generated temporary FY 2025-26 savings of approximately $49,000.
• Reinstating Seascape is estimated at $200,000 annually. • Providing one postcard mailer to all households per neighborhood organization estimated at $50,000 annually.
• A revised grant program would require appropriation consistent with the funding model chosen.

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• In-kind support costs will vary by scale but may be offset by reduced direct grants.
• A City-sponsored election forum would require modest additional resources.

Prepared By: Christopher Smith, Deputy City Manager
Approved Forwarded to Council
Attachments:

A. NGP Application
B. IRS Chart-Neighborhood Association
C. Written Comment
D. PowerPoint Presentation

11.B
Packet Pg. 2728
Neighborhood
Organization Grant
Program
Instructions ● Requirements ● Forms Fiscal
Year 2023-2024
The Neighborhood Organization Grant Program is designed to provide financial support to assist neighborhood organizations with programs and activities that increase connectivity among neighbors and provide meaningful opportunities for residents to be engaged in improving their communities, so that they may build membership and further communication with the residents within their neighborhood

KEY DATES
Covers Expenses Incurred July 1, 2023 – June 15. 2024
Application Deadline March 30, 2023
Final Close-Out Report Deadline June 22, 2024
Attachment A

11.B.a
Packet Pg. 2729 Attachment: NGP Application (7202 : Community Organizations and Participation in Grant Programs)

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Santa Monica City CouncilSeptember 30, 2025

Santa Monica City Council
September 30, 2025