Re: Planning Commission Agenda 9-A
Dear Planning Commissioners:
This evening many significant amendments to the LUCE are being proposed
by city Planning staff in Agenda Item 9-A. A few of the changes recomm-
ended are modifications to the LUCE that were initiated by the community
with support from city staff and elected and appointed officials. These
community initiated changes resulted from an extensive public process and
do not seek to expand upon what the LUCE allows. However, many of the
proposed amendments slated for discussion this evening were not advanced
by the community and have not undergone any community process. Further-
more, many of these staff generated changes seek to significantly alter
the LUCE and to allow an intensification and expansion of development
in our city that is beyond what the community agreed to and beyond what
the City Council voted to support.
Amendments to the LUCE should be adopted only when necessary, such as to
correct an error or oversight, and should not be undertaken lightly. The
LUCE is a document that the community crafted to guide future land use
in Santa Monica, a document that sets the outer limit of what our city
will allow in its built environment in coming years.
As to the nine LUCE amendments proposed by staff, we ask the Planning
Commission to: Support the following amendments to the LUCE, items 4, 5
and 6 in the Staff Report, which went through a substantial community pro-
cess and are supported by city officials:
Eliminate both Activity Centers on Wilshire Blvd. as recommended by staff
and sought by the residents to preserve quality of life in the neighbor-
hoods. Activity Centers are essentially Tier 4 and are inappropriate in
an area that is not transit rich. The Subway-to-the-Sea originally envis-
ioned in the LUCE process is no longer anticipated to occur during the LUCE
Eliminate Tier 3 from the Mixed Use Blvd. (MUB) land use designation as rec-
ommended by staff and requested by the residents. In particular along Wil-
shire Blvd. adjacent to Wilmont and Northeast Neighbors, Tier 3 development
would be out of scale and inconsistent with the existing adjacent single
family and multi-family neighborhoods.
Eliminate Tier 3 from the Mixed Use Blvd. Low (MUBL) land use designation.
This will ensure appropriately scaled development that is compatible with
the character of the adjacent neighborhoods.
Reject the following proposed amendments to the LUCE, items 1, 2, 3, 7, 8,
and 9 in the Staff Report, which were recently generated by staff but have
not gone through a community process and are inconsistent with the LUCE
Maintain the LUCE language “Building Height Standards” to describe graphics
of building heights in section 2.1. The text comports with the graphics in
this section. Several local architects who have examined 2.1 in the LUCE
could find no justification for a change from “Standards” to “Guidelines.“
If the staff seeks to achieve more clarity, perhaps additional text could be
added to the graphics to indicate, for instance, that Figure 4 depicts Tier
1 and that Figure 5 depicts Tiers 2 and 3. Changing the overarching language
to “Guidelines” suggests that the limits are debatable or negotiable, which
was not the intention of the community when the LUCE was drafted. The LUCE
should not be altered in order to allow for interpretation.
Maintain LUCE text references to stepback standards that refer to the 2010
zoning ordinance. The 2010 zoning ordinance was a benchmark that was mean-
ingful to those who participated in the LUCE process and was referenced in
order to provide clarity as to what was acceptable in the LUCE process.This reference was included in order to provide clarity as to what was acceptable
and what was not. It must not be forgotten that these stepbacks were created intentionally and this language in the LUCE is not an error.
Maintain all references throughout the LUCE to “discretionary review” because
this term appears in the document 23 times and it is there for a reason.The
LUCE should define what has to be done by discretionary review and the zoning
should implement that vision. The LUCE should not be rewritten to become
consistent with the draft zoning. To remove or modify “discretionary review”
from the LUCE would be to engage in a wholesale overhaul of the document and
the safeguards the community wanted in its land use plan.
Do not recommend amending the LUCE chapter 2.1 – 41 to include “a 3-foot height
bonus above the 32-foot base height” for 100% affordable housing because a 32
foot height limit was the community mandate for Tier 1 projects in the LUCE and
this area. A real discussion needs to be had in the community about changing
the LUCE to add density, affordable or not. Such a community discussion would
need to address how such changes to the LUCE would increase the population and
how such increases would impact infrastructure and resources, such as water.
the addition of a 3-foot height bonus is beyond the scope of what the community agreed to.
Maintain the LUCE requirement that Tier 2 Residential Projects and Mixed-Use
projects be processed by Development Agreement because this allows community oversight of important projects and such oversight must be maintained as exp-
ressly written and envisioned in the LUCE.
Do not recommend amending the LUCE to allow market rate housing through a Condi-
tional Use Permit in either the Industrial Land Use or Office Campus areas.
Given the significant number of housing developments already in the pipeline,
there is no reason to amend the LUCE in order to open up new areas for housing development. Such changes to the LUCE would increase the population and would
impact infrastructure and resources, such as water.
Regarding the 31 parcels labeled “inconsistent” by staff, we ask the Commission
to postpone discussion of this matter until the community has an opportunity
to understand why such changes are being advanced and whether they are consis-
tent with the LUCE vision.
A majority of these proposed parcel changes would incentivize more intensive development by increasing development rights and are certain to have signifi-
cant impacts on the quality of life for residents of our city. Fifteen of the parcels identified in the report would be changed from Low Density Housing to
the denser development category of Mixed-Use Blvd.
A concentration of these parcels is located north of Colorado Ave. behind the commercial zone. Many of the parcels are currently designated R2 and are dir-
ectly adjacent to homes. To convert these parcels to MUB in order to expand
the Mixed-Use Blvd. along Colorado would be to intrude into an existing low
scale neighborhood rather than protect it. This change would incentivize the
removal of existing single-story buildings that act as transitions and buffers between the commercial street and dwellings, violating the LUCE promise to pre-
serve existing neighborhoods.
In the case of the parcels themselves, not only would their change to MUB encou-
rage intensification and impact nearby residents, but the change would also
impact the small businesses located there as well as their employees. Invari-
ably these workers and small businesses will be displaced, changing the char-
acter of the area and our city.
Below is a section of the map showing in black boxes the parcels that staff pro-
poses to change from R2 to Mixed-Use Blvd. adjacent to Colorado Blvd. as well as photographs of some of the existing businesses that serve as buffers to homes
north of Colorado Ave.
Duplex buffered by single story office building on an “inconsistent parcel” north
Small business on “inconsistent parcel” buffers single family home north of Colo-
This snapshot from a neighborhood is offered as an example of how many of the proposed parcel changes will densify our city at the expense of existing resi-
dents and small businesses. Planning staff has not provided a rationale for
changes such as these. It is not sufficient to label them “inconsistent.”
Discussion of the proposed changes to these 31 parcels should be postponed until
the community has had adequate time to have questions answered by staff and to discuss whether such revisions to the LUCE in terms of their collective impact on Santa Monica.
The Board of Northeast Neighbors
CC: Santa Monica City Council and Clerk
City Clerk – please include this document in its entirety in the public record
for this agenda item.