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Open Letter to the City Council: An Analysis of the City’s Opportunities and Challenges Report

The Santa Monica Coalition for a Livable City (“SMCLC”) has reviewed the city’s Opportunities and Challenges Report and we have the following comments and recommendations:

I. The Report Fails To Discuss The Successes And Failures Of The 1984 Land Use Element Of The General Plan As Part Of The Update Process.

Because this is a general plan update process, this report should have discussed in detail the 1984 Land Use Element (“LUE”), its requirements, its implementation, and its successes and failures. A fundamental question not addressed in the Report is whether its original vision of our downtown is still valid. The 1984 LUE envisioned pedestrian paseos within blocks, engaging ground floor retail, a new park on the east side of downtown, buildings that were not tall, with stepbacks for light and air. This Report does not address why much of what has been built downtown departs significantly from this vision.

Instead, this report defends what has been built as a successful model and posits much more mixed use development as a given. This is a notable and material weakness in the Report which partially invalidates it as a planning tool and which should be remedied.

II. Santa Monica’s Present Resident Population And Density As Projected In The Future Do Not Support The Upzoning And Increased Mixed Use Development That Is Discussed.

There is not a population shortage in Santa Monica. On the contrary, there is an open space shortage. According to pages 3-5 of the Report, Santa Monica has a population density of 10,131 people per square mile. That’s 29 percent higher than Los Angeles, 33 percent higher than Culver City, and 71 percent higher than Beverly Hills. In pages 3-2, it states that Santa Monica’s resident population has not grown since 1970 and that household averages have actually been declining while the daily work force commuting into our city has risen to 179 percent of the resident population (at 3-4).

Over the past 35 years, a lot of housing has been built in our City at an accelerating rate. Between 1970 and 2000, a 30-year period, the number of housing units increased from 42,106 to 47,863, an average rate of 192 net additional units per year. (U.S. Census, 1970, 2000). During this period, Santa Monica lost most of its signature courtyard apartments to maximum density non-neighborhood friendly, box-like development. Since the founding of the city, nearly every R-2 lot that originally housed one or two cottages has been rebuilt to the maximum allowed. This was permitted by a little-known provision that underlay that zoning category. And this dramatic change came as a result of building at a rate of only 192 units per year.

In contrast, between 2000 and 2005, the city reported a net increase of 1,695 housing units (page 3-3), which represents an increase of 339 net units per year and these numbers do not even include all the data for the entire year of 2005. Now, on top of all of this accumulated existing housing, this Report approves of accelerating such growth by predicting another 9,000 new units, or 450 units per year over the next 20 years. This number is hyper-growth, not reasonable growth into an area of only 8 square miles!

We do not oppose the creation of moderate additional housing to promote a vibrant city. But the courts recently found, and we agree, that Santa Monica is doing far more than its fair share to meet California’s housing needs. We are against the creation of much more additional housing as a major focus of the new General Plan. Moreover, this accelerated residential growth is proposed in addition to the continuous growth of Santa Monica as a regional and international tourist draw, with tourism up almost 25% since the year 2000. No case is made in the Report that our city, acknowledged to be ever more affluent, is in need of increased revenues whether from new housing, commercial and retail development, or tourism. Likewise, none of the corresponding costs to the city or its residents resulting from such dynamic growth are documented either, such as the additional infrastructure of schools and public safety measures alone that would be required to support this major increase in resident population.

Finally, we firmly believe that such continuing, even accelerated growth is very much at odds with what residents have repeatedly said they want their community to be when asked about appropriate town scale as part of this LUE update. We do not believe, as the Report states at 1-22, that residents approved of increased heights of 5 to 8 stories downtown or up to 5 stories along corridors nor is there any evidence in the Report that residents were specifically polled in that way. We understand that residents have reported time and time again in community workshops and surveys, that they wanted to retain the overall present height and scale of their city, and that they were deeply concerned that accelerated growth like this would dramatically increase traffic gridlock, negatively change the character of the city, and significantly reduce the quality of their lives.

III. Before Committing Significantly To More Mixed-Use Development, The City Should Study The Results Of This Development Over The Past Several Years To Determine Whether It Has Met The City’s Objectives Of Housing For Our Workforce, Increased Use Of Public Transit, And Encouraging Pedestrian Sidewalk Use.

The fundamental, unanswered question which underlies the entire new housing discussion is whether the new housing would be for people who work in Santa Monica and whether they would get to work without their car. The Report hypothesizes this, but evidence cited in the Report about the experiences of downtown residents refutes it. Pages 3-71 in the Report, show only 4% of residents who live downtown as the result of mixed-use development commuted to work using public transportation, which is identical to the percentage of residents who commuted to work using public transportation in the rest of the city and 70% of them still drove. This table also shows that the average commuting time for residents who live downtown is identical to the average commuting time for residents who live in the rest of the city.

Nowhere in this Report do we find any evidence to the contrary. So there is no reason to believe that added housing will reduce the number of commuters coming into our city, as there is no reason to believe that new residents will work in Santa Monica in any greater numbers than the present population does.

Significantly, mixed-use developments also have not encouraged pedestrian use of the public sidewalks, as was hoped. Areas such as Sixth Street between Broadway and Colorado, which have been completely redeveloped per the city’s mixed-use vision, have little or no pedestrian use. It is not surprising that pedestrians avoid these areas. With uninterrupted, 50-60 foot sheer walls that line the sidewalk, the sunlight and ocean breeze are blocked out. People feel dwarfed by this much mass. This was not supposed to be the way the downtown would develop under the 1984 LUE which again raises the question of accountability, the failure to follow the general plan and no explanation in the Report of the reasons for not doing so.

For all of these reasons, before the city adopts a LUE that would significantly increase mixed-use development around the city, the city should study the extent to which such developments have or have not met the city’s stated goals, Enough mixed-use developments have been built just in the past five years to enable the city to analyze the successes and failures and learn from them before committing to considerably more such development. We urge you to do this at this all-important stage before implementing a vision that could be viewed in hindsight as a failed planning fad with irreversible consequences.

IV. The Report Appears To Emphasize Development As Demolition And Rebuilding While Overlooking The Importance Of Adaptive Reuse And Upgrading Existing Buildings.

Finally, in our review of the Report, it seems that the term “development” is used exclusively to mean demolish and rebuild. We believe the city should broaden its interpretation to embrace the adaptive reuse and upgrading of existing buildings. Santa Monica’s future should focus on implementing an aspect of its own sustainable city plan — adaptive reusing and upgrading existing buildings rather than add greater density to a city which has outgrown its infrastructure. Where possible we should conserve our resources and also be mindful of preserving what may be historic. Indeed, our City was recently designated a Preserve America Community, becoming only the third California community to be so designated by the Advisory Council on Historic Preservation in concert with four U.S. Departments. This designation acknowledges Santa Monica for using our historic assets for economic development and community revitalization. Yet the Report makes only passing references to this issue instead of integrating adaptive reuse and upgrading into the plan update. To live up to this designation, the city should make them major objectives in the LUE update.

Santa Monica Coalition for a Livable City

cc: Planning Commission

Architectural Review Board

Landmarks Commission

City Manager

City Planning Department (Andy Agle, Amanda Schacter)For more information about Santa Monica Coalition for a Livable Cty visit www.smclc.net.

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