Community Development Department
City Planning Division
1685 Main Street – Mail Stop 28
Santa Monica, CA 90401
June 10, 2026
Southern California Association of Governments
900 Wilshire Blvd., Ste. 1700
Los Angeles, CA 90017
Sent via email: [email protected]
RE: SCAG SB 79 Transit-Oriented Development Stops, Zones, and Tiers Draft Map Dear SCAG Staff,
Thank you for the opportunity to provide comments regarding SCAG’s Senate Bill (SB) 79 draft map published on June 1, 2026. After review of the draft map, the City requests corrections to the map based on the City’s understanding of SB 79, local data related to transit and bus operations, and ongoing discussions with SCAG Staff.
I. Revise GTFS Pedestrian Access Points
Per SCAG’s Mapping and Approach and Methodology published in May 2026, SB 79 requires that the distance of a transit-oriented housing development project from a TOD stop be measured from the nearest edge of the parcel containing the proposed project to a pedestrian access point for the TOD stop and that MPOs may rely on the General Transit Feed Specification (GTFS) data to map pedestrian access points. Furthermore, a pedestrian access point is the primary location where pedestrians enter a transit station or boarding platform.
The current draft map uses the correct GTFS data locations for pedestrian access points for the four Metro stations with SB 79 qualifying TOD stop boundaries within the City of Santa Monica; however, the draft map also includes among these points the center of platform GTFS data point, which is not a pedestrian access point as defined by SCAG and therefore should be excluded.
The example above shows the 17th Street / SMC Station center of platform GTFS data point (highlighted in the middle) currently included on SCAG’s SB79 draft map.
II. Add TOD Bus Stops: 1) Santa Monica Blvd & 3rd St and 2) Santa Monica Blvd & 4th St and 3) Broadway & Ocean Ave
Per SCAG’s Mapping and Approach and Methodology, qualifying TOD bus stops must meet several criteria. The first requirement of a qualifying stop is that it meet the definition of a major transit stop, which as defined by Public Resources Code 21065.43, is “a site containing any of the following:
a) An existing rail or bus rapid transit station.
b) A ferry terminal served by either a bus or rail transit service. c) The intersection of two or more major bus routes with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods.
Next, a bus stop must be adjacent to a full-time dedicated bus lane. In Santa Monica, full-time dedicated bus transit lanes are codified in Santa Monica Municipal Code Section 3.12.675(a) and include:
1. Santa Monica Boulevard between Ocean Avenue and 5th Street has a full-time dedicated bus lane on the south side only (eastbound).
2. Broadway between Ocean Avenue and 5th Street has a full-time dedicated bus lane on the north side only (westbound).
The last requirement for a qualifying stop, as indicated in SCAG’s SB 79 Methodology documentation, is that the bus stop has service frequencies of 15 minutes or less during the combined morning and afternoon peak commute periods. In Santa Monica, the bus routes that operate with service intervals of 15 minutes or less include:
• Big Blue Bus 1;
• Big Blue Bus 3;
• Big Blue Bus 7;
• Metro 4;
• Metro 33;and
• Metro 720.
There are three bus stops in Santa Monica that meet all three requirements described above. These include 1) Santa Monica Boulevard and 3rd Street, 2) Santa Monica Boulevard and 4th Street, and 3) Broadway and Ocean Avenue as demonstrated below:
1. Santa Monica Boulevard and 3rd Street
a. At the intersection of two or more major bus routes (Metro Line 4 and Metro Line 33) with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods.
b. Adjacent to the full-time dedicated bus lane on Santa Monica Boulevard between Ocean Avenue and 5th Street.
c. Serviced by bus routes with operating intervals of 15 minutes or less, including Metro Line 4.
2. Santa Monica Boulevard and 4th Street
a. At the intersection of two or more major bus routes (Big Blue Bus Routes 2 & 3, Big Blue Bus Routes 1 & 7, and Metro Line 4) with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods. b. Adjacent to the full-time dedicated bus lane on Santa Monica Boulevard between Ocean Avenue and 5th Street.
c. Serviced by bus routes with operating intervals of 15 minutes or less, including Big Blue Bus Routes 1 and 7, and Metro Line 4.
3. Broadway and Ocean Avenue
a. At the intersection of two or more major bus routes (Metro Line 4 and Metro Line 33) with a frequency of service interval of 20 minutes or less during the morning and afternoon peak commute periods.
b. Adjacent to the full-time dedicated bus lane on Broadway between Ocean Avenue and 5th Street.
c. Serviced by Metro Line 4 bus route with operating intervals of 15 minutes or less.
TOD bus stops to be added: 1) Santa Monica Blvd and 3rd St, 2) Santa Monica Blvd and 4th St, and 3) Broadway and Ocean Ave III. Remove TOD Bus Stop at Pico Blvd & Lincoln Blvd
The current draft map includes a bus stop located near the intersection of Pico Boulevard and Lincoln Boulevard; however, this stop does not meet all the criteria of a qualifying bus service TOD stop as described above.
The bus stop at Pico Boulevard and Lincoln Boulevard is adjacent to a bus lane located along Lincoln Boulevard, but the bus lane is not a full-time dedicated lane and is only operational during peak Santa Monica Blvd
& 4th St TOD Stop
Santa Monica Blvd
& 3rd St TOD Stop
Broadway and
Ocean Ave
afternoon commute hours. For this reason, the City requests that the currently mapped TOD bus stop at Pico Boulevard and Lincoln Boulevard be removed from the map.
Bus stop at Pico Blvd & Lincoln Blvd to be removed from SCAG’s SB79 draft map We appreciate SCAG’s efforts to produce a final SB 79 map and welcome any opportunities to connect and discuss. If you have any questions, please feel free to contact me at [email protected].
Sincerely,
Rachel Kwok
Environmental Planner