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Open Letter To The Planning Commission and City Council:

The Santa Monica Coalition for a Livable City (SMCLC) has reviewed the staff report of the Draft Alternatives for the Land Use Element of the General Plan.

We believe the report lacks fundamental information required for you to make an informed decision and does not adequately describe land-use alternatives and their impacts in an understandable way.  We have the following comments and recommendations.

I.    This Process is Deeply Flawed Because the Alternatives Suggested Do Not Even Attempt to Reflect the Repeated Views of Residents or Those of the Planning Commission:

The City conducted an initial public outreach process with the sole aim of determining what ideas residents supported for their  neighborhoods and the City as a whole.  The Planning Commission then reviewed and commented upon them.  These ideas should be incorporated now into the analysis of each proposed alternative to determine which, if any of these alternatives should be chosen.  Instead, they have simply been attached as a list for future discussion after certain alternatives are chosen thereby minimizing the importance of this valuable input. 

A perfect illustration of the serious problems that arise when no such integration is even attempted is the assumption that Santa Monica Place will be developed to extraordinary density, regardless of alternative, which is both contrary to the expressed views of residents and unsupported by current development plans of the mall’s owner.

II. The One-Paragraph Discussion of the So-Called “Status Quo” Alternative Is Vague and Insufficient and Needs To Be Explained in Greater Detail:

The paragraph, as written, assumes that “if no changes are made to existing policies and development activity continues at its current pace this will not significantly change the existing environment compared to today.

This statement is accurate only if new developments were required to conform to existing heights and lower intensity of land use prevalent in Santa Monica rather than conforming to the greater limits permitted by the zoning code or density bonus allowances. Thus, down zoning would be required to achieve the “status quo.”

 We believe this is what residents have expressed repeatedly in community workshops and surveys.  Residents stated that they wanted to retain the overall present height and scale of their city, and that they were deeply concerned that more growth at the current pace would dramatically increase traffic gridlock, negatively change the character of the city, and significantly reduce the quality of their lives.  Therefore, preserving the “status quo” as residents expressed it, would require down zoning, not allowing increased heights of five to eight stories downtown and up to five stories along corridors.

It appears that staff has defined the “status quo” as intensified building at the greater heights and densities.  The staff’s statement of “ensuring that new development is consistent with the existing profile” then means the latest, “tallest” profiles. Given this definition, the existing environment of our City will change significantly and this alternative needs to be analyzed in the same detail as the rest of the alternatives.  It also needs to be more accurately referred to as the “current zoning” alternative to avoid ongoing confusion in the public debate on this point and in staff reports which misleadingly call it the “status quo.”

III. This Draft Report Lacks The Basic Information Required to Make an Informed Decision:

In our view, what the authors of this report think of as details to be fleshed out later are really fundamental to the discussion at this stage in order to choose responsibly between the proposed alternatives (or to suggest other, new alternatives).  There is simply no way to know how much growth is being proposed under any of the alternatives and no attempt to raise or explain the corresponding traffic impacts.

Key unstated assumptions and/or vital information include:  No goals for population growth, built environment growth, traffic growth; No mapping/discussion of base, existing level of development, the development capacity currently permitted and the extent to which it could increase the population and built environment without implementing any of these alternatives; No quantities discussed as desirable goals for square footage, heights or density, road capacity, or air quality.

The maps that illustrate the alternatives do not quantify the color codes. How many people, cars and square feet of building are represented by yellow?  By red?

 No discussion of the related traffic impacts correlated with the alternatives – emphasis on cycling and walking as transportation options;

The erroneous assumption that increased residential and commercial density is needed in order to justify mass transit; and  the noticeable absence of land dedicated to parks, green space and recreation.

Significantly, much of what is missing here corresponds to what residents and the Planning Commission viewed as fundamental elements of a revised General Plan.   The failure to discuss or incorporate these key issues renders the report largely useless.  Instead of providing content, this report is littered with unsupported, generalized statements such as “an appropriate number of housing units,”  “quality walking experiences,” “non-motorized transportation,” and “strong neighborhoods.”   Rather, we need to understand and be clear about what are the underlying development goals that are being satisfied under these alternatives, what are the impact trade-offs, and in what ways have the residents’ views been taken into account in preparing the alternatives?

For all these reasons, we urge the Planning Commission and the City Council to lead a public discussion of the policy questions and to direct city staff to clearly and explicitly provide quantities and time frames underlying its assumptions and then direct the staff to revise and rigorously examine these alternatives and correlate them with the elements discussed above.  The report should be written in clear language, amply supported by facts.

Sincerely,

Santa Monica Coalition for a Livable City

cc:  City Council members

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