Letter to Planning Commission re: Housing Element Draft

September 23, 2021

Dear Santa Monica Planning Commissioners:

Santa Monica Forward wishes to share the following comments on the changes proposed in the “Addenda Sheet” attached to your September 24th agenda.

Change No. 1: SB9 already allows for demolition of owner-occupied homes. The no more than 25% restriction is only for structures occupied by renters within the past 3 years. Meaning, you can fully demolish a structure if it was owner occupied but you cannot if it was occupied by renters. We believe that is a sensible tenant protection and urge you to not allow more permissive demolition rules.

Change No. 6 No. 9,: While we agree with eliminating the even split between income levels (a policy crafted to undermine state density bonus law), we do not agree with the elimination of the 15% AHPP requirement. 15% is per Council direction in June. We do not believe it is appropriate to make this change now, just weeks before the adoption deadline, with no public input, and contrary to prior Council direction. Please reinstate the 15% AHPP requirement. AHPP is one of Santa Monica’s most powerful tools for creating affordable housing. Moreover, we do not believe the Housing Element should have an escape clause on height and FAR. Reducing height and FAR would require a concurrent reduction in AHPP which, again, does not align with prior Council direction or the community’s needs. Please remember that these heights and FARs are from HR&A’s feasibility analysis which was released preliminary in March and fully in June. None of this is new, and the public has already had many opportunities to weigh in at the Planning Commission and City Council. To reverse course now, just before the deadline, and after months of consideration, public input, and review, would undermine the open and transparent process the city has followed since the beginning. That breeds distrust in city decision making and ultimately makes good policy harder to craft.

Change No. 12: This is a sensible change and we do not recall Council ever saying no to 200% AMI housing. Cross subsidizing lower-income housing with 200% AMI housing would likely lead to more low-income housing overall because now we will have a funding source to help pay for lower-income units. This is essentially what Vienna does - mixed-income social housing projects with the rent from higher income households helping to pay for lower-income households. Santa Monica Forward strongly supports.

Thank you for your consideration. Sincerely,

Abby Arnold and Carl Hansen Co-chairs, Santa Monica Forward