Santa Monica Forward submitted this letter to the Planning Commission on March 9, stating our position on the most recent draft of the Downtown Community Plan.  SMF believes that increased housing opportunities for all income and age groups, enhanced mobility strategies, and neighborhood-serving amenities must be supported to create a downtown community that works for everyone.

Dear Commissioners,

Santa Monica Forward would like to commend the hard work of city staff that went into creating the draft Downtown Community Plan. Overall, this plan presents an excellent vision for our city’s future with a strong emphasis on creating a multimodal urban

Downtown that is accessible to all members of our community and preserving our Downtown’s myriad historic assets. We understand that it is no easy feat to synthesize the many concerns of our diverse community.

However, Santa Monica Forward urges the Planning Commission to recommend changes to the draft Downtown Community Plan that would encourage and incentivize the production of housing, both market rate and affordable. In its current form, the draft

DCP represents a significant step backwards from the housing incentives established under the 1988 Zoning Ordinance, 1996 Bayside District Specific Plan and the 1993 residential density bonus ordinance.

Downtown Santa Monica presents a unique opportunity to create a better environment to protect the diversity of our city and make it more affordable for young adults and new families.

As the city’s youngest and still growing neighborhood, the policy considerations that govern the City’s more established neighborhoods (preservation of the status quo and discouraging redevelopment of existing buildings), simply do not make sense for the

Downtown. The recent downzoning of the City’s boulevards means that the Downtown is one of the few areas of the City that still has the potential to provide much needed housing.

If we truly care about stemming displacement, preserving our existing neighborhoods, getting people out of their cars, and helping to reduce our carbon footprint, it is vital that the DCP actively and aggressively encourage housing growth in our downtown core. By sharply reducing the potential for new housing, the current draft DCP represents a step backward.

The DCP Allows Less Housing Compared to the Bayside District Specific Plan

The DCP should make it easier, not harder, to build what we need most in our community. We urge the Planning Commission to reconsider proposed decreases as compared to the 1988 Zoning Ordinance, 1996 Bayside District Specific Plan, and the 1993 residential density bonus ordinance in allowable residential densities that would only put further restraints on housing construction in our downtown.

As the draft DCP points out, its predecessor, the Bayside District Specific Plan, along with the City’s residential density bonus ordinance adopted in 1993, established strong “incentives for residential uses to encourage housing development for a mixed-use Downtown (see City Ordinance No. 1687, parts 4 and 5). As a result, the number of

Downtown residential units doubled…to approximately 2,800 units,” according to page six of the draft DCP.

The BDSP and density bonus ordinance achieved this housing growth by discounting residential floor area by 50 percent in the calculation of FAR. It was that real created the environment that allowed for the budding mixed-use, walkable community that Downtown is today.

By eliminating this 50 percent discount and effectively reducing maximum residential densities through much of the Downtown, the draft DCP sharply reduces the amount of housing that it will be possible to build.

Many of the mixed-use and 100 percent affordable housing projects in the Downtown could not be built under the draft DCP’s proposed standards.

There are at least half a dozen mixed-use, mixed income, and 100 percent affordable housing projects that were built in what will become the DCP’s Neighborhood Village district that couldn’t get approved under the proposed standards because there are above the maximum FAR of 3.25. In total these projects contributed approximately 253 units to the Downtown.

It’s also worth noting that the half dozen projects we found were processed with a much more streamlined administrative approval process, meaning they got built much faster than they would have if they had had gone through the lengthy and expensive discretionary approval process.

Given the urgency of our community’s need for housing at all affordability levels, the draft DCP’s FAR standards should be increased throughout the Downtown in order to continue to allow the kind of mixed-use and 100 percent affordable housing projects that have begun to transform Downtown from an aging commercial district into a vibrant, 21st century urban neighborhood.

Building Market Rate Housing Will Stem Displacement

Santa Monica’s population has only grown from 88,314 to 92,472 from 1980 to 2014.

Yet, in those 34 years, rents and home prices have skyrocketed and traffic has gotten increasingly worse. The majority of the people who make our city work – servers, hospitality workers, police officers, firefighters, teachers – are forced to commute great distances by car because of decades of minimal housing growth.

We continue to ignore the mounting body of evidence that restrictive zoning is accelerating our housing affordability crisis at our own peril and – perhaps more importantly – the peril of future generations that will inherit a Santa Monica even less accessible than it is today, unless we make substantive changes to our housing policies.

In a report released last year titled “California’s High Housing Costs: Causes and

Consequences, the Legislative Analyst’s Office argued that if California’s coastal cities were to remain affordable to low and middle-income households, that the California legislature needed to promote strategies to create new housing and increased density in those cities, such as Santa Monica.

Given the enormity of the state’s housing crisis, the Legislative Analyst’s Office has advised the legislature to look beyond affordable housing programs and to “expand efforts to encourage private housing development” in order to help low-income

Californians. Page 16 of report spells this argument out.

In a follow up report released February 9, 2016, called “Perspectives on Helping

Low-income Californians Afford Housing,” the Legislative Analyst’s Office presented evidence that in communities where market rate housing growth was higher, housing costs for low-income households were kept lower, helping to mitigate displacement.

The report presents evidence that a lack of supply drives high housing costs and that building new housing adds to the supply of naturally affordable market rate housing as higher income renters move out of older housing stock and into newer construction.

Santa Monica Forward urges the Planning Commission to use the DCP as an opportunity to secure affordable housing opportunities for future generations of Santa Monica residents.

Building Market Rate Housing Can Promote Economic Equality

In the face of a dire regional housing crisis, it is irresponsible to make it harder for our community to respond to the growing need for new housing in jobsrich cities like our own. Doing so means that we are actively contributing to the growing divide between rich and poor that is plaguing our nation.

In the past year, President Obama has sought advice on how the United States, one of most inequitable advanced economies in the world, can once again be a place of opportunity for all.

A recent presentation by Jason Furman, the chair of the White House Council of

Economic Advisers, a group selected by President Obama to analyze and interpret economic developments and advise him on issues of national economic importance, illustrated that throughout the country, restrictive local housing policies have been widening the gap between rich and poor by increasingly making it harder for middle and low-income workers to access homes near quality jobs. That presentation, “Barriers to Shared Growth,” is attached. Furman’s findings were recently echoed by New York

Times columnist and distinguished economist Paul Krugman in his column, “Inequality and the City”

Santa Monica Is Well Placed to Address the Housing Crisis By Encouraging the Development of Housing Downtown

The lack of affordable housing is a massive problem but it is not Santa Monica’s alone.

It is truly a regional and statewide problem. This problem took decades to create, and it will likely not be solved in one generation nor by one community plan.

However, the severity of the crisis does not mean that we can’t do anything about it. On the contrary, the severity of the crisis demands we act now, lest our children inherit an even worse problem. In Santa Monica, where we require 30 percent of all new housing to be deed restricted affordable, all new housing growth has the double advantage of not only helping to keep rents in older housing stock from rising more quickly but also of creating a net gain of units accessible to low and moderate-income tenants.

We must begin all discussions of the current crisis with a frank assessment of its root causes. We no longer have the luxury of pretending that we can maintain a nominal growth position and simultaneously support an affordable Santa Monica. The ideas are incompatible and irreconcilable.

Judy Abdo & Juan Matute on behalf of Santa Monica Forward