Tonight the Planning Commission will discuss the parameters for the environmental analysis for the Downtown Specific Plan (DSP). I previously wrote, when the issue came to the City Council last week, that the council should set parameters to cover a wide range of heights and densities, so that, consistent with the purpose of the California Environmental Quality Act (CEQA), the council, as the decision-maker, will have all the information it needs. (The council tabled any action on the question until August 13 because it only had four members present.)

Since the Planning Commission will consider and vote on the DSP before the City Council does, the same reasoning holds for the commission. The commissioners should have more information, not less.

One of the common criticisms of the development review process in Santa Monica that the anti-development community makes, at times with justification, is that individual projects are evaluated before the City has completed overall plans for a given area. In the downtown area, developers have proposed projects in advance of adoption of the DSP, but neither the Planning Commission nor the City Council can make decisions on those developments until after the DSP is adopted. This is a good thing; but if the staff’s recommendations are followed, and the Environmental Impact Report (EIR) for the DSP only studies heights up to 130 feet, then any proposals to build higher than that will be evaluated later, on a one-off basis. That would be a bad thing.

While any major development will have its own EIR, many of the issues, particularly aesthetic issues (environmental analysis includes aesthetics), implicated by higher heights need to be evaluated with respect to the whole district. That’s where the EIR for the DSP has a whole comes in.

Only if the DSP’s EIR evaluates what a series of new towers would look like will the commission and the council, let alone the public, have a chance to evaluate the implications of changing 30 years of policy to allow taller buildings. This is not an issue that should be considered on a site-by-site basis, as it is the skyline of the district as a whole that needs to be considered. Once taller heights are evaluated (in the EIR and otherwise), the commission and ultimately the council can make decisions how to “sculpt” that skyline.

Another issue that has come up is whether to delay the DSP’s environmental review until after the commission and the council approve a draft DSP. Again, what I have heard over the years, often from the anti-development community but not only from them (and it’s certainly a point I agree with), is that it defeats the purpose of CEQA to have environmental review only after a plan a project has been tentatively approved. The complaint is often, with justification, that environmental review is then used to justify decisions previously made.

Making decisions, even tentative decisions, prior to environmental review puts the cart before the horse: the purpose of environmental analysis is to give decision-makers the information they need before they make decisions.

Knowledge is power. The staff’s proposal, unless modified, would reduce the commission’s and the council’s knowledge and their power. If the commission and the council don’t believe they have enough wisdom to make choices based on more knowledge, then I wonder why they want to sit on the dais in the first place.

I hope the Planning Commission and the City Council have enough self-respect to accept the staff’s invitation, contained in alternative proposals 2 and 3 in the staff report, to expand the scope of the EIR.

Thanks for reading.