As most of you know the Southern California Association of Governments (SCAG) is now forcing Santa Monica to permit 8873 new housing units (of which about 6000 need to be affordable) in the next 8 years (2022-2029). Buttressed by all kinds of interlocking laws and severe financial penalties, SCAG is coercing the City to accept this constitutionally illegal unfunded mandate. This would be an incredible budget busting 20% increase in our resident population, with its attendant increase in water, power, traffic gridlock, sewer, fire/police, schools and park demand, not to mention the financial cost of permitting all those units.
The City Council is belatedly holding a study session to try to respond to this on Dec 15 at 5:30 pm and to prepare a new housing element for those next eight years. The housing element is normally a forward-looking planning tool the City uses to achieve its housing goals. However, it has now become, with SCAG’s blackmail, an unsustainable urban cancer that the City Council has to figure out how to treat.
In reality the City does not have a housing problem. It permits annually about twice the amount of housing it needs to absorb its natural growth, but it cannot produce enough AFFORDABLE housing for the full spectrum of its current residents’ incomes. This affordability crisis, no matter how you solve it, eventually requires a substantial cash subsidy of some sort. Since SCAG provides no funding for its required 6000 affordable units, the entire SCAG edifice collapses into a useless unattainable mirage.
Because of SCAG’s numbers lack of reality, at its study session, the Council should get real and try to understand how we got into this nightmare and how to get out of it. They should be able to answer twenty questions to its residents who will be bearing the burden of this onslaught:
- Why did the City waste a year when this was first publicly raised in December 2019 in preparing a response to these unattainable numbers?
- When our City’s SCAG allocation suddenly mysteriously jumped 88% (4229 units) in December of 2019, why did the City not respond? Who should have generated a response to this red flag? How can we reverse this arbitrary manipulation?
3.Why did the Council accept that Santa Monica was being treated substantially differently in its requirements than other cities (with similar transit/job availability) in proportion to its population: Santa Monica 9.57%, Culver City 8.5%, Long Beach 5.34%?
- Knowing this number was unattainable, why did the City let the official appeal deadline, at the end of October 2020, lapse without filing an appeal knowing full well that other Cities were appealing and that if they were successful, their reductions would be added to our numbers?
- Why has the City not joined the 50 other cities fighting for local control when we saw the overinflated numbers headed our way?
- The natural growth of the City (births minus deaths) is approximately 1111 units in the next 8 years if we ignore the depopulating effects of Covid-19. But why should we accept a growth rate 8 times our natural expansion if it even occurs? How does piling on more people make the City more affordable for our existing housing cost overburdened residents? And shouldn’t those overburdened resident’s needs come first?
- By the end 2021, the end of the last 8-year cycle, the City will have permitted about 3250 units or about twice the previous SCAG requirement of about 1674 units. Why should our city suddenly have to absorb about 5 times our last allocation?
- If the hypothetical purpose is to increase the amount of housing why cannot the excess/deficit created in previous cycles be carried over to the next SCAG cycle. If not, isn’t this an unfair punishment and simply an encouragement for all Cities to under permit?
- The SCAG numbers do not require the units to be actually built, just permitted. So not a single unit need be added to the City’s housing stock according to SCAG. Assuming each unit costs about $600,000 to build and that permitting costs run 10% of the unit cost, just the permitting process will cost about $530,000,000 (the entire City budget for one year) for units that will not be built for decades. Who will pay for these upfront costs when the market, cannot with all its vacancies, even absorb the current stock?
- The 6000 affordable units will cost a nominal $3.6 billion dollars to build. SCAG has no funding mechanism. With its great affordable housing program Santa Monica thankfully built about 544 affordable units over the last 6 years or 90 affordable units a year. SCAG wants to raise our production by a factor 8 (750 units/year). What is the credibility of such a goal? Show me one California City that has built its way to affordability?
- Because SCAG has no ownership requirement or funding mechanism are not we just permitting/ building for a permanent underclass of renters who will never accumulate enough capital to become owners? The new housing element should favor new housing models of share ownership.
- How many units will be credibly demolished to build 8874 units? The number of those demolished units needs to be added to the 8874 to create the net number that needs permitting.
- The SCAG numbers are a forced up-zone for the entire City creating excess profits for existing landowners at the expense of the feasibility of future housing production. By making land more expensive won’t this up zoning only make it harder for our current affordable housing providers competing with more well-heeled developers? How will the City prevent such gouging as what happened at the City trailer park project?
- Why should the City accept SCAG’s narrow rules defining what is a suitable site for new housing, such as the artificially low (600) Accessory Dwelling Units limit that could be placed on our 9000 single family sites? Why should the City accept any SCAG constraints on what is a suitable site?
- Freddie Mac believes, based on vacancies (pre Covid-19) but still using SCAG’s own fake methodology, that our real need is about 2078 new units or less than a quarter of the SCAG numbers. How will the City adjust its housing element for the effect of Covid-19? And how will SCAG adjust its numbers for a depopulating state that lost 650,000 people this year?
- The school population is shrinking because we have not permitted/built enough affordable 3-bedroom apartments. Wouldn’t it be better to build more multi bedroom apartments instead of so many single bedroom apartments effectively demanded by SCAG? SCAG’s numbers should be emphasizing useful quality instead of quantity. SCAG again takes away local control by forcing the direction of development away from what our City really needs.
- Haven’t the last 50 State housing mandates for height bonuses, for density bonuses, for affordability exemptions, for automatic approvals, etc. etc. already taken away enough local control, that the SCAG numbers will only be the final nail in our City’s coffin?
- How do the unfunded SCAG’s numbers, which drive up land and construction costs, address our homeless crisis?
- Has the City prepared a cost benefit analysis of legally resisting the unfunded mandate compared to kowtowing to SCAG with its exponential infrastructure costs? If not when can we have it?
- State law requires housing projects of 500 units or more identify new water resources with a 20-year supply. To meet SCAG’s numbers between one and 17 new aquifers need to be identified. Where is any new water to be found? In two years our water independence from outside sources must be achieved: how far back does this SCAG invasion set us? The same question could be asked for the entire overloaded City infrastructure. Can you say gridlock?
As you can see SCAG’s bogus numbers are an unjustifiable unprovoked assault on our City. SCAG’s numbers are an idolatrous worship at the fake god of infinite growth that will both eviscerate our City’s beachside character and its urgent sustainability/resilience necessities. Wearing the fig leaf of “affordability”, to hide SCAG’s real beneficiaries, the City is being forced to sacrifice itself for the benefit of developers, real estate interests and construction unions.
This is a “give unto Caesar what is Caesar’s” moment for our City. The City Council should, in its accountability obligation, answer these resident questions and figure out how to resist Caesar while simultaneously giving its residents what it really needs: a realistic credible housing element. In our post truth world, we do not need more fakery.
Please attend the December 15th zoom meeting and tell the City Council to get SCAG’s boot off our neck.
by Mario Fonda-Bonardi, AIA Planning Commissioner for SMa.r.t.
(Santa Monica Architects for a Responsible Tomorrow)
Ron Goldman, Architect FAIA; Dan Jansenson, Architect, Building & Fire-Life Safety Commissioner; Robert H. Taylor, Architect AIA: Thane Roberts, Architect; Sam Tolkin, Architect; Marc Verville accountant ret.
For previous articles see www.santamonicaarch.wordpress.com/writings