Open Letter to The City Council From OPA: Policy Analysis

Land Use and Circulation Elements, General Plan The Sustainable Neighborhood committee of the Ocean Park Association has spent the past month thoroughly reviewing the Opportunities and Challenges Report on the LUCE revisions. There’s much we like in this document, including: 1.  The connections between land use and circulation planning. 2. The recognition that chain stores and their large floor plates are hurting the pedestrian environment downtown and along Wilshire Boulevard. 3. The acknowledgment that “super blocks” (hospitals, schools, Sea Colony, RAND) impede pedestrian activity and that the City should create linkages through these properties. 4. The discussion of “smart streets” which encourage multi-modal means of transport and enhance bicycle and pedestrian safety. 5. The frequent concerns about environmental sustainability. However, we are apprehensive about the direction in which the report seems to be steering the future of Santa Monica. Our thorough review, coupled with our observations from participation in all of the major public input workshops and informal outreach to dozens of Ocean Park residents draws our attention to the troubling gap between the “opportunities and challenges” the consultants have identified and what we believe the majority of residents identify as the “opportunities and challenges” facing our community’s future. Broadly speaking, we see this critical issue missing from the report: 1. The report seems to suggest that the growth numbers it uses would be in addition to growth that will naturally occur as a result of maintaining existing zoning.  When 8,800 new residents is put forth as a “moderate” level of growth, does that number include the thousands of new residents who are to be expected as a result of demographic changes and build-outs within existing zoning?  Does it take into account the allowed 50 percent density bonuses called for by state law? We would like to see adequate consideration given to the following: a. A zero population growth option where the city is zoned to allow no new increase in density whatsoever and existing allowable building heights are decreased. b. A true moderate population growth option where the existing zoning and building heights are generally kept in place and density is allowed to increase at about the rate that SCAG estimates. 2. Adequate consideration to the devastating impact that doubling or tripling allowable densities along existing one and two story commercial corridors would have on the existing locally-owned, small businesses, given that those businesses would be displaced and new developments of this scale have historically been dominated by chain businesses. In detail, our reservations about what is contained in the report are these: 1. The report erroneously assumes that the answer to the problems created by the growth of the last 20 years is more growth over the next 20 years. Our jobs/housing imbalance, traffic congestion, and other quality of life concerns (all arising from growth in offices, regional shopping and tourism) have had serious consequences during a period in which the city’s population remained stable and the housing stock has increased modestly. Yet the report suggests the opportunity to address these woes lies in building as much as 14,500 housing units with a “moderate” forecast of 8,800 units being added to the second densest city in LA County, with a correspondingly large increase in population. Meanwhile the addition of a mere 2,600 units outside of our city borders in Phase Two of Playa Vista was opposed by the Santa Monica City Council. The report notes on p. 3-49 that the California Dept. of Finance estimates there were 49,297 dwelling units in Santa Monica in 2004, up less than 2000 units from the 47,753 counted in the 1990 census. 3 percent more housing was added during 15 years of explosive growth with irreversible social and environmental costs and the solution is to add 18-29 percent more units? Yes, we should add housing but a 3-5 percent increase seems more sensible, per SCAG’s prediction of a 3.9 percent jump in housing demand over the next 20 years. The Emerging Themes report noted that residents feel “Santa Monica’s growth should be modest.” To our minds, an increase in the range of 8800 to 14,500 units is not in any way modest. In fact, the report fails to consider that housing demand might actually be accommodated by our existing stock through in increase in our currently low occupancy rate and/or through very modest redevelopment which takes advantage of the state’s 50% density bonus. Meanwhile, Opportunities and Challenges barely explores answers to the true causes of our city’s ills, such as capping the growth of office space; converting existing office space to residential use; greater incentives for shared ridership, shuttle parking and public transit use by employees; or curbing the growth of tourism and regional shopping. This should be the focus of the LUCE revisions, to address the problems caused by the growth of the last 20 years, rather than an unsustainable solution of growing our way out of the problems of growth. 2. In fact, residents stated clearly during the Emerging Themes phases that they were opposed to any changes in the scale and small, beach town ambiance of Santa Monica. Nonetheless, the report mistakenly pronounces that residents want existing height limits maintained. Actually, what residents want is the perpetuation of existing as-built conditions, not the greater heights and densities already allowed in many areas. For OPA, nowhere is this clearer than on Main Street. Here it is essential, as well as throughout the city, to preserve the existing scale of our streets and buildings and to put an end to the overly large new developments which threaten the character of neighborhoods and commercial corridors. We ask you: how does increasing our housing stock by 18 to 29 percent, without contemplating the effects of the possible concurrent increase in retail, jobs and tourism, jibe with community sentiment in favor of modest growth and preservation of as-built scale? 3. Smart Growth: the solution or a planning fad? The report implies that all this growth can be accommodated without straining our already overburdened infrastructure because it will be smart growth in the form of mixed-use, transit oriented development. We are skeptical, not so much about the precepts of smart growth, but more about how they will be applied here. We believe caution and restraint are in order as smart growth is the planning trend du jour, developed to combat urban sprawl rather than the built-out conditions in Santa Monica. Please remember that at one point it was fashionable to widen Ocean Park Boulevard to accommodate more cars and to allow for tall towers built after the demolition of historic bungalows and cottages, decisions with serious negative impacts on Ocean Park. Likewise, Santa Monica Place was once the cutting edge of mall design and became obsolete shortly thereafter. So we urge you to be circumspect about the latest rage and its irrevocable consequences and to consider that Playa Vista, with its live, work and play design, was sold as smart growth, yet was opposed by the Council for very good reasons. Moreover, smart growth should not be used solely to rationalize growth in the Earthquake Redevelopment Area as a means to enhance city revenues, especially since the City will derive ample tax increment funds from the transfer of residential properties in this RDA without any upzoning and growth in our commercial corridors. We feel fiscal policy should not drive land use policy. Instead, sustainability, quality of life, social justice and other factors should determine land use policy, in concert with a prudent fiscal analysis. We are also troubled that the report never studied the downtown mixed-used developments to see how many occupants actually work in Santa Monica or looked citywide at who works and lives in Santa Monica and what factors played a role in this desirable confluence. How can we assume smart growth will actually lessen the jobs/ housing imbalance? Is there any proof of a correlation between net migration into new mixed-use developments and employment within the city? 4. Beware the perils of transit-oriented development. Shouldn’t light rail and rapid buses first be given the chance to reduce existing congestion before the city allows for transit-oriented development? We think so, especially since we have questions about the TOD strategies outlined in Opportunities and Challenges.  Why not develop our public transportation infrastructure and then assess our success and our infrastructure’s ability to handle growth in the next General Plan Update? For instance, SCAG’s two percent solution calls for focusing most of our regional growth in the two percent of the land which is near transit nodes (i.e. places with transit heading in many directions.) Santa Monica is a transit edge, the terminus for lines headed mostly to the east, and therefore may not be appropriate or effective for TOD. And while light rail is likely to come to Santa Monica and would work well as the focus for some TOD, we believe the zoning ordinance should not be altered to add density downtown or at Bergamot Station until the plans and money for Expo rail are guaranteed. We’re even more skeptical about the benefits of developing along BRT corridors. Even with dedicated bus lines, it’s unlikely renters and owners of new market rate housing on commercial corridors will ride the bus rather than hop into the Lexus or BMW. In our region, the trend has been that only those who can’t afford cars ride the bus to and from work. And the report has no studies which prove that TOD increases transit ridership while evidence throughout LA County suggests higher gas prices and worsening traffic still don’t stimulate use of transit, as there’s simply not enough transit to make ridership cost-effective or convenient compared to autos. 5. Mixed used planning has thus far failed downtown. In its haste to encourage redevelopment downtown, City Hall ceded too much control to real estate interests, resulting in poor design and quality of new buildings; a dearth of units of a size suitable for families; retail spaces which are often vacant and fail to reduce car trips; and projects which are simply too big and dense. This model should not be applied elsewhere in the city. Additionally, City Hall has failed to consider the impact of mixed-used developments on the human ecology of Santa Monica: middle income housing is demolished and replaced with market rate and low income units, a trend which will lead to the exodus of the middle class and a city solely for the affluent and working poor. We’d prefer that the LUCE revisions should instead follow the principle of “Same Neighbors, Better Neighborhoods.” 6. Don’t rush into “smart” transit-oriented, mixed-use development on all the corridors without proof of its efficacy. Instead, we think it would be prudent to use Lincoln from Wilshire to the city border as a pilot project for this redevelopment strategy and to evaluate the results after a number of years. Such a case study of Lincoln would promote neighborhood-serving, transit-oriented, mixed use redevelopment of modest height and density with measures to improve walkability and to turn the street into an active social space, as has been done in West Hollywood. 7. The report often examines environmental sustainability but doesn’t consider economic sustainability. We’re distressed to see so many big projects, financed by out-of-town investors, siphon capital out of our city while small, locally-owned businesses suffer from the rising rents and dislocation caused the redevelopment of recent years. We think the City instead needs an economic development plan that keeps capital and ownership in the hands of local businesses and residents, rather than allowing our city to be “colonized” by outside investors and corporations. And if, as the report states, there is a limited future increase in retail demand and since residents have clearly expressed a desire for more local, walkable and neighborhood-serving retail to reduce car trips, why should the city add any more centralized chain stores and regional shopping meccas? 8. If there is to be growth in our city, particularly along the commercial corridors, it should be modest. In addition, it should also follow these principles: a) Allowable densities elsewhere in the city should be decreased to offset corridor growth, resulting in only a minor increase in density citywide. b) The impacts of the state’s new 50 percent density bonus should be incorporated into the LUCE revisions. With this bonus, there may well be no need to increase the currently allowed densities along the commercial corridors and downzoning may actually be necessary to maintain the current scale of buildings. c) Allowable densities and heights should be reduced throughout the city and bonuses should created to allow any redevelopment to achieve the current as-built heights and densities (per community desires). These incentives would include: 1. Historic preservation. 2. Protection or enabling of locally-owned, neighborhood serving businesses. 3. Green building design and other reductions in environmental footprint. 4. On site, inclusionary affordable housing. 5. Multi-modal street improvements, such as street lights, bus shelters, benches, bike lanes, textured sidewalks, subterranean parking, undergrounding of utilities, etc. d) We’d also like to see zoning changes to preserve community gardens and to create genuine living spaces for artists rather than the live/work spaces built today which most artists can’t afford; and the rezoning of the beach lots as parks or part of the Pier so that their uses and management can be overseen by the Recreation and Parks Commission and the Pier Restoration Corporation. In conclusion, OPA believes that: 1. Growth is not the answer to the problems created by growth. 2. Even what the report calls a “moderate” increase in density is incompatible with the desire of residents to preserve the scale and character of Santa Monica as it exists today. 3. Smart Growth via transit-oriented, mixed-use development should not be used for a massive redevelopment of our commercial corridors or as a means to expand City revenues; it should be applied judiciously, incrementally and at a modest scale and the results examined at regular intervals; and its focus should be on revitalizing commercial corridors into walkable, neighborhood-serving social spaces of the current as-built scale. 4. Revisions to the LUCE should be guided by economic as well as environmental sustainability, modest growth, adaptive reuse and preservation and the principle of “Same Neighbors, Better Neighborhoods.” We urge you to direct staff and their consultants to shape a future for Santa Monica which reflects these goals. Respectfully submitted,The Board of the Ocean Park Association