110513-_-GRAPHThe Housing Element (HE) is one of the required parts of the city’s General Plan. As we look at City Hall’s proposed HE for 2014-21, agendized for the Planning Commission on Wednesday, Nov. 6, and practically unknown to residents, I’m disturbed by the little exposure residents have had to this document.

Although public comment is mandated, that public comment came from approximately 76 people — members of boards and commissions (listed in the Housing Element as sources of public input) in a city of 60,997 registered voters. City staff will claim those commission meetings were “open to the public,” but there was little notification to the public of when housing presentations were going to be made.

The Neighborhood Council, a group of neighborhood leaders who represent the large neighborhoods in the city, was one of the groups given a presentation, and the intimation in the HE was that the residents of all neighborhoods were benefiting from that one presentation. This is not true. There was no commitment from the Neighborhood Council to recreate that presentation, so outreach was limited.

Live coverage of Planning Commission hearings on City TV does not always begin at the start of the meeting, so potential viewers may give up and miss important presentations.

There were no well-publicized repeated public meetings in large spaces, as was the process for the Land Use & Circulation Element (LUCE), the Bergamot Area Plan, and the Downtown Specific Plan.

The document itself became available on the Planning & Community Development Department website. The document is 198 pages in length, and the negative declaration document is 49 pages long. It describes the thought process that allows City Hall to claim that the new HE (relating to all those large buildings in the Bergamot Area Plan and in the Downtown Specific Plan) will have no negative impacts on the environment, (which everyone in Santa Monica knows is total nonsense). Through the use of vocabulary proprietary to negative declarations production and approval, writers of negative impact documents can turn “Yes” on its head and have it come out “No.” The use of the phrase “overriding considerations” is typical.

The HE, in the eyes of some, is equal in importance to the LUCE. Once approved by the City Council and the state Department of Housing and Community Development, it becomes the housing production bible for the years 2014-21, as LUCE is the development bible. It is a key to the development process in Santa Monica.

The games intrinsic to its creation are worth noting, particularly the graph of household income to number of units designated for that income group. According to the City Council in their last look at this document, Santa Monica is 156 units short of the estimated need for extremely low, very low, and low income units.

City Hall recently adopted new income and rent limits based on the state’s published area median income (AMI) of $64,800. Tables 4 and 5 from the document accompanying item 5-A at the Sept. 11, 2011 Planning Commission meeting reflect this.

According to SCAG (Southern California Association of Governments), we’re tasked with building 1,674 units, 214 of those extremely low-income, 214 very low-income units, and 263 low-income units.

Since SCAG is charged with allocating the perceived housing needs by the state, for this area (Beverly Hills, Culver City, Santa Monica, West Hollywood, West Los Angeles) and since SCAG allocates 86 percent of the needed housing units in the Westside cities to Santa Monica, the goal for the next HE period (2014-21) has been raised 250 percent from the previous period (2008–14). But in the previous period, we exceeded our goal by 233 percent.

According to Liz Bar-El, planner in charge of the Housing Element, there is no benefit in exceeding the goal, and no penalty for missing the goal. Thus, City Hall has dropped the housing goal to 1,346 units. The number of very-low income housing units has been lowered by 156 units, and the number of above median income units has been raised by 80 units. The City Council has given direction to staff to focus on finding money for building the extremely low, very low, and low-income units assigned to Santa Monica.

When statistics show that many employees in the Bergamot area will need below market rate rents to live in the area, it is distressing that Hines would seek to fulfill its affordable housing obligations to the benefit of 180 percent area median income (AMI) households, and that staff’s response is to focus on the 150 percent area median income households, rename the focus “Workforce Housing,” and designate it “affordable” in the benefits column, as if this was a benefit to the city.

This is not acceptable. Benefits to residents earning 150 percent to 180 percent of area median income are not benefits that should qualify for additional height and density bonuses through a development agreement. I’m guessing that will bring a chorus of agreement, as will the statement that this HE document has been seriously under-presented to the public. It also unfortunately lacks a serious focus on preserving existing affordable housing.

Comments are welcome, but the document has already been forwarded to Sacramento, so it’s unlikely that any serious changes will be made.


Ellen Brennan, 19-year resident and former member and chair of the Pier Restoration Corp. board, authored this column.

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