The DCP on its final stage

After, in words taken from the staff report, “nearly six years in development” (not too much longer than it takes to get approval to build an apartment building!), Santa Monica’s Downtown Community Plan (DCP) is finally approaching finality: the Santa Monica City Council will hear public testimony at a special meeting Monday night, debate the DCP Tuesday night, and vote on it in two weeks.

I wrote five blogs on the DCP in May when the Planning Commission was reviewing it, and I will try to focus my reporting now on the changes in the prior draft the planning and other commissions, and staff, now recommend, and what they are leaving to the council to decide.

There’s bad news and good news.

To start with a little bit of bad news, it appears that not even one board or commission recommended including in the DCP’s history section mention of Arcadia Bandini de Baker as one of the founders of Santa Monica. Maybe the Commission on the Status of Women should review the DCP, too.

But enough with identity politics. I’ll get right into some good news. The DCP is still fundamentally flawed, but it will be less fundamentally flawed if the council follows the Planning Commission’s recommendations, and even less so if the council builds on them in ways that staff is now suggesting.

To recap what I wrote in May, the DCP represents a retreat from extremely successful policies the City adopted in the 1990s, policies that gave residential development big financial advantages over commercial development. Inexplicably, for a plan that its backers call a “housing plan,” the DCP drastically reduces the edge residential development has over commercial in terms of allowed square footage (“FAR”), while increasing even more drastically the relative cost of residential development over commercial development. While the City has financial modeling that purports to show that residential development under the DCP will be feasible, there’s no analysis that shows that developers will in fact build residential development, when it will be much simpler and less costly to build suburban-style commercial projects like low-rise offices or retail.

The Planning Commission made an effort to address this issue. The commissioners did not make recommendations relating to the substantive issues of the relative costs and benefits of developing housing versus commercial, other than some incentives for 100% affordable projects, but they did recommend simplifying the approval process for all housing developments up to certain size limits. The commission recommended that any housing project on up to two standard lots (meaning up to 15,000 square feet of land) be subject only to administrative approval. Similarly, in the “Transit Adjacent” zone where Tier 3 projects are still allowed, they recommended increasing the threshold for requiring a development agreement from 60,000 to 90,000 square feet.

These recommendations by the Planning Commission are significant, not the least because they have encouraged planning staff to do some planning of their own. On pages 49 and 50 of the staff report, where staff gives its recommendations to the City Council, staff recommends that the council consider additional incentives for housing development.

It’s taken “nearly six years,” but it was heartwarming to see in the staff report recognition that making it administratively easier to build housing would be “similar to the procedural incentives that were formerly in place for Downtown in the 1990s that resulted in the production of approximately 2,500 housing units.” (Let me add, because it’s important, that if these downtown properties had been developed for commercial uses, which, given Silicon Beach would likely have happened, this would have resulted in more than one million square feet of commercial, mainly office, development. Development that would have generated orders of magnitude more traffic, particularly rush hour traffic, than the apartments that were built at the double-FAR granted to residential development.)

I’d be shouting hallelujah to the rooftops, but for the fact that the DCP still contains policies that dramatically favor commercial development over housing, policies that the Housing Commission, believe it or not, wants to make even worse, by piling more affordable housing requirements onto market-rate housing.

The DCP will never be as favorable to housing as the 1990s zoning (which, by way, produced a lot of affordable housing). The staff report makes the unfounded claim that the DCP is different, and presumably better, than the 1990s zoning because the DCP has development standards that will make projects “complement Downtown’s existing character” (for my skepticism about that, see this blog) as well as make downtown vibrant, walkable and welcoming to a diverse population. The problem with this rationale is that the 1990s rules have been proven to produce these results—it’s only wishful speculation that the DCP will do the same.


Part of Downtown’s existing character that the DCP would have complemented.

The Planning Commission also did good work adding incentives for 100% affordable projects, but only in some zones downtown. The incentives should apply throughout downtown. Even more important, incentives should extend to market-rate projects, too. The plan could encourage housing for all income levels and in particular onsite inclusionary housing by the simple measure of not counting the square footage of onsite affordable units against FAR limitations. If developers are saving government from having to provide the public good of affordable housing, why not at least give them free air to build it in? (You could still have a maximum cap on FAR.)

Regarding the zones downtown, the DCP has too many of them. Downtown is not big and there are not as many differences within downtown as the DCP would have you believe. In the six-minute walk I take most days of the week from my office to my dad’s apartment for lunch, I pass retail, offices and apartments, all mixed up. This is good. The DCP overcomplicates what downtown Santa Monica is all about. It’s full of distinctions without differences. It micromanages.

Hopefully the City Council will take into account the recommendations from Downtown Santa Monica, Inc. (DTSM), the City-created entity that manages downtown. Who knows downtown better than DTSM? No one, and DTSM’s recommendations, on pages 31-32 of the staff report, include equalizing (more or less) the development standards among the “Neighborhood Village” (NV) and “Bayside Conservation” (BC) districts and the Transit Adjacent (TA) district. In the staff report the staff opens up the possibility of increasing height and FAR standards, presumably in the NV and BC, but except for a few pros and cons doesn’t provide the council with much in the way of analysis.

DTSM also knows the retail situation, and knows that it makes sense to allow small offices on the ground floors of mid-block apartment buildings. Other than on the boulevards, I don’t see any reason to favor retail over offices in ground floors. DTSM also makes a small but important point, which is that it makes sense to allow retailers to easily redesign frontages.

Thanks for reading.

The DCP and the lingering impacts of the Great Recession

The question I ended my post with on Saturday was why would Santa Monica enact a Downtown Community Plan (DCP) that makes it easier to build commercial development than housing? Keep in mind that this is taking place during a local, regional and statewide housing crisis, and following a period of 30 years during which something like nine million square feet of commercial development were built in the city, but only a couple of thousand units of housing were built to house the many thousands of new employees.

But first, before getting into that, consider what’s happened in the rest of the city since the enactment of the LUCE in 2010 and the new zoning ordinance in 2015. That history gives a preview of what will happen downtown if the City Council enacts the DCP as currently drafted. The LUCE and the zoning also turn out to favor commercial development, and, sure enough, properties expected to be developed with housing in industrial areas and along the boulevards are instead being developed, or re-used, as one- or two-story commercial projects.

The two biggest examples are in the old industrial area. One is the “Pen Factory” being developed on the Paper Mate site. There the developer Hines had proposed to build 499 apartments to go along with 400,000 square feet of offices and other commercial development. This was too much office, and not enough housing for the big site, but Hines had followed the LUCE standards in developing its plan.

Council Member Kevin McKeown opposed the Hines project and supported the Residocracy referendum that ultimately killed it. He said that Hines would come back and negotiate a better project. McKeown’s intentions were sincere, and I had hoped that he’d be right, given that during the LUCE process he was one of the few who argued against planning staff that the LUCE’s development standards for the Bergamot area called for too much commercial development and not enough housing.

But after the City Council revoked the project’s approval, Hines didn’t renegotiate. They sold the project to new developers who are converting the factory into about 215,000 square feet of offices. Gone are 499 units of housing, along with all other benefits the City negotiated for, including new streets and a sidewalk on Olympic Boulevard. This fiasco would never have happened if the LUCE had not favored office development in the area in the first place—the developer would have had to build housing and would have planned accordingly.

Less well known, but equally a disaster, is what’s happening, or not happening, with the nearly three-acre property on the 2800 block of Colorado known as the Roberts Center. Under a development agreement that site was going to be developed with 231 housing units and only about 60,000 square feet of commercial. The project would have been coordinated with projects on either side of it so that, among other things, Pennsylvania Avenue could be extended through them, breaking up a super block, and helping traffic flow in the area. Now the property owner has abandoned the DA process and is simply rehabbing the existing buildings for new commercial uses. Again, no housing and no community benefits.

Since enactment of the zoning ordinance in 2015, the same thing is happening on the boulevards. Developers are downscaling and building commercial. Properties at Wilshire and Berkeley, and the old Jerry’s Liquor site, that were intended to be sites for apartments will instead become two-story mini-malls, featuring restaurants that will generate more traffic than the apartments would have. The developers needed no special approvals for these projects as they were subject only to administrative approval.

Downtown, where a few projects, under pre-DCP standards, are moving forward after City Council approvals, we can nonetheless see the future in the two-story commercial building recently completed at Fourth and Broadway. On this site there was going to be a mixed-use, primarily residential building, and a plan was approved. But when the developer had to change those plans, to add parking, the project came under new fees charged by the City. The developer opted to build a two-story commercial building, which was also only subject to administrative approval.


The commercial building at 4th & Broadway built instead of housing.

The City, with the analysis from HR&A Advisors that I discussed in my previous post, has tried to show that housing development under the DCP will be feasible, but the City didn’t ask HR&A to compare the costs, risks, and profitability of residential development against those of commercial. Nor does the DCP take into account how few developers are willing to attempt developing housing in Santa Monica.

Housing development is not for the faint of heart. Two individuals, Craig Jones and Neil Shekhter, are responsible for most of the housing built in downtown Santa Monica over the past 20 years. It’s telling that they both ultimately got into trouble with their lenders. It’s a risky business. Unlike Jones and Shekhter, most developers and (especially) their lenders avoid risks. Given Silicon Beach there’s no risk now and plenty of gain in building one- and two-story retail and/or office buildings, which fly under Tier 1 and only need administrative approvals. It’s these projects that the DCP makes easy—precisely the projects that the rhetoric in the DCP says we don’t want.

So, back to my question, why have Santa Monica’s planners pushed a pro-commercial development plan for downtown? (By the way—I don’t doubt their sincerity. They believe they’ve come up with a “housing plan.” That’s part of what makes this so aggravating.)

It’s not simply a surrender by the planners to the don’t-change-anything crowd, although no one likes being yelled at. It’s true that the anti’s don’t want any more housing built, but housing is their target because housing is what has been primarily built since Santa Monica shut down major office development in the ’90s. (And hotels, but they don’t like them either.)

No, the reasons are deeper and go back to the City’s response to the Great Recession, and the disastrous final years of the LUCE process. Up until the recession hit in 2008 the LUCE was moving towards being a sensible plan that left the neighborhoods alone, continued the slowdown on office development, and concentrated considerable housing development in three commercial zones: downtown, the boulevards, and the old industrial areas near Bergamot Station.

But the recession created a financial crisis for the City. Suddenly I started noticing a big change in the City’s attitude towards the LUCE. The narrative was now all about how Santa Monica was a creative city, and our creative businesses were so important and wonderful, and how good it would be to have more of them. What do you know, but the planners started telling us that new development around Bergamot should be 60 percent commercial, mostly “creative office.”

Why this change? It was obvious, and not really hidden: residents cost the City money for the services they need, while commercial projects pay more taxes to the City than they consume in services. Imagine City Hall as a big cash register. Let L.A. build the housing along the Expo line, and provide the services. Santa Monica will provide the jobs and collect the taxes.

It was around then that the double FAR for housing downtown got thrown out. For five years the planners have been drafting this anti-housing DCP without explaining what was wrong with the old development standards and administrative approval processes that actually got a lot of housing built, creating the downtown they say they admire and want to build upon.

Thanks for reading.


In the wee hours . . . wisdom?

I’m inclined to consider it a missed opportunity for comprehensive planning, but the fact that both developers and the anti-development faction in Santa Monica politics seem happy with the City Council’s decision last week to limit environmental review of the Downtown Specific Plan to building heights not exceeding 84 feet might be a sign of clear-sighted wisdom on the council’s part.

What the council did was limit the scope of the EIR to 84 feet, but made it clear, and no one on the dais objected to this, that developers had the right to seek amendments to the DSP if they could show that their taller projects would be worth it to the city to approve.

I suspect that this suits the druthers of any given developer, who would rather argue the merits of his or her specific project than get caught up in an abstract (and emotional) discussion about building heights in general, and those of the anti-development community, who wouldn’t like it if (and note I said if) environmental review showed that taller buildings didn’t themselves create much in the way of environmental impacts, and then that shifted momentum in favor of heights before the issues of aesthetics and values could be discussed.

My initial reaction is that the council’s decision precludes the kind of comprehensive discussion we should have about a decision to allow taller buildings, but I can see two reasons (at least) why I could be wrong:

One is that maybe comprehensive planning is overrated. The most beautiful, livable and joyful cities of the world became such more often because of the accretion of many individual decisions rather than by the imposition of plans (although over time successive plans are themselves discrete decisions), and so perhaps focusing the review process on individual projects will be a good thing.

The other is that the crucial decisions about height are not evaluated in an environmental impact report (EIR), particularly one for a general plan. Consider the three criteria that Council Member Kevin McKeown has articulated as relevant to a decision about height: aesthetics, impact on the street level, and community values. None of these criteria, except possibly aesthetics in a cursory manner, would be part of the EIR for the DSP.

So maybe I’m wrong about the comprehensive environmental review — but I still say we should have a community discussion about the aesthetics of height and the values issues implicated by height that is independent of any given project.

Regardless how wise the council members were or might have been Tuesday night, they were admirable in how they handled the matter. There they were in the wee hours after hearing hours of conflicting and often passionate testimony, including accusations of some of them being corrupt, and they coolly and sensibly considered the matter before them.

Consider the surprising ways the discussion went. Gleam Davis, one of the council members unfairly vilified as a tool of developers by some members of the anti-development community, made the motion to limit environmental review to 84 feet. Terry O’Day, also a target, seconded the motion. Ted Winterer, one of the favorites of the anti-development side, proposed an amendment to extend an FAR bonus to projects that provide traffic mitigations, and anti-development stalwart Kevin McKeown forcefully reminded everyone (including those in the anti-development camp who don’t believe we need anything) that we “need housing.”

It was great. And what makes me even more happy? I don’t have to write about building heights for a while.

Thanks for reading.

To Study or Not to Study

Tuesday night’s City Council meeting is going to be the latest big meeting on development standards in Santa Monica. The topic will be the scope of the environmental review for the Downtown Specific Plan (DSP).

Planning staff, in the staff report, takes a conservative approach, recommending that the Environmental Impact Report (EIR) cover only small changes to existing standards for both building heights and the amount of permitted development. Nonetheless, by including in the report two alternative actions that the council could take, staff has invited the council to expand the scope of the EIR to study the impacts of taller heights proposed in current pending projects and possible density bonuses for uses that generate fewer car trips.

Because the purpose of environmental review under the California Environmental Quality Act (CEQA) is to give decision-makers more information, not less, to inform their decision-making, the council should accept this invitation and expand the scope of the EIR.

Having said that, my instinct is that much of the staff’s conservatism is warranted, at least for most of downtown.

Regarding density, staff analyzed the current levels of development downtown and found that because of the density bonus for housing adopted in the ’90s to encourage residential development in commercial zones downtown, development in downtown Santa Monica often exceeds an floor-area-ratio (FAR) of 3.0 (meaning that on the average a given parcel of land could be 100% covered with a three-story building) and can approach an FAR of 4.0. (Because of requirements for light and air, and sometimes for setbacks, buildings in real life always require more stories than the theoretical average number of stories allowed under a given FAR.)

In general, consistent with what the reality has been over the past nearly 20 years, staff recommends FARs of between 2.5 and 4.0, but recommends dropping most of the density bonus for housing, intending that housing can be incentivized by other means (some of which are required by state law).

While an FAR as high as 4.0 should be rare in downtown (an FAR over 3.0 is difficult to work with on the small parcels that characterize most of downtown Santa Monica), where higher densities (within the range) might make sense would be on the western (Ocean Avenue) and southern (freeway) edges, because the density that you would be putting in those locations would not be “reflected” by density “across the street.” I don’t mean that you could double the density, but there could be more — but that would require more height to get appropriate light and air for the building and avoid boxy massing.

Which brings up the height issue. Given how controversial the three hotel/condo towers proposed for west of Second Street have been, I can understand the staff’s reticence about studying heights that high in the EIR, but not to study them would be ignoring the elephant in the room. It’s not, however, only (or even primarily) the environmental impacts that need analysis; aesthetic impacts are even more important. For height, we need an “AIR” – “Aesthetics Impact Report.”

And a “Meaning Impact Report” — we also need to analyze how higher heights affect the “meaning” Santa Monica has or the meaning — or values — that we want Santa Monica to have. Santa Monica has never been only a resort — we were once equally famous for the aircraft built here — but the beach and its attractions (both natural and human-made) have been an important part of our identity as a world famous place. Unusual for resorts, for a long time we’ve also been the edge of a metropolis. But how urban do we want that edge to be?

That’s a debate worth having, and one we need to have before the City Council makes its final decision about heights. To have that debate, and to make that decision, the community and the council need to see appropriate visualizations and models.

It’s hard to resist dipping a toe into the substance of that debate. Planning staff claims that there is less support for taller buildings west of Second Street than east of it, but that’s not what I’ve heard. Admittedly, I don’t have a scientific sample (nor does staff), but what I’ve heard frequently is that given that there are already many tall buildings along Ocean Avenue, that’s where new towers (if any are to be allowed) should go. Also, skinny tall buildings overlooking Palisades Park (densities being equal) will block breezes and views less than squat short ones.

We should be more conservative with the 20 or so blocks east of Second Street and north of Colorado. There are few buildings above six stories there and tall buildings would stand out more. In this I am being influenced by what Stefanos Polyzoides said at the forum Mike Feinstein and I hosted June 22, namely that towers are best when they are clustered, rather than scattered about. The five- and six-story height limits have worked well on what have become primarily residential blocks on Fifth, Sixth, and Seventh.

See you Tuesday night — and thanks for reading.

Elevated Thinking?

Last week I wrote a post about the political conflict over the issue of the height in downtown Santa Monica, focusing on the fight between the Miramar and Huntley Hotels and the motion three councilmembers brought forward to table consideration of projects taller than 84 feet until after the adoption of the Downtown Specific Plan.

But I didn’t say much about the issue itself. As I have written before, I am still making up my mind about height. I’d like to explain why I am still undecided.

Thirty years ago Santa Monica made a momentous decision to restrict heights. Since the days of the Arcadia Hotel Santa Monicans had built large buildings on the beach; today, when people profess nostalgia for an unchanging “sleepy beach town,” it’s important to recall that the decision to restrict heights represented big change.

I was not involved in politics then, but it’s a decision that I’ve always thought was a good one. The city made it in response to a series of towers, both downtown and in Ocean Park, that were built in the ’60s and ’70s. For the most part these towers were unattractive and projected an exclusionary gestalt offensive to many. The decision to lower heights also had the side benefit of spreading the demand for development around downtown Santa Monica to more properties, helping to create the more balanced downtown that we now have.

My own views in general about skyscrapers for a long time have been that other than in exceptional locations the best form for most urban centers was the form that cities took before elevators – capping out at five or six stories, with courtyards and good connections to the street. While I love modern architecture, I agree with the consensus that developed in the light of the writings of Jane Jacobs and Robert Venturi and Denise Scott Brown that the modernists’ concept of the “tower in a park” had been a failure.

Then a few years ago I took a trip to Vancouver (my wife had a conference there – it wasn’t as if I was looking for a new perspective) and saw how in that beautiful city on the water they were building “skinny” high-rises, mostly for residential purposes, that worked well with their streets. I began to reconsider my position about height. But for any given place, such as downtown Santa Monica, I haven’t made up my mind. Every place is different.

What Santa Monica needs and deserves is a robust community discussion about the issue. A generation has passed since Santa Monica restricted heights, and while the momentous decisions of the past have weight, they aren’t necessarily binding on the future. Change happens. Still, the burden of proof is on the proponents of more height – they need to explain why towers today won’t create the problems that towers in the ’60s and ’70s created. At the same time, the proponents of the status quo have to give reasons for opposing height that go beyond “we decided this back then,” or “developers are greedy.”

Personally, I want to hear all sides, but I also want to see models and graphics to give an idea of what tall buildings would look like from different angles, including from the beach. I haven’t seen those yet.

Having expressed all that angst, I will venture a few thoughts about the three specific hotel/condo projects that developers have proposed.

The Miramar was the first proposed project, and being first didn’t help them or anyone else. To be fair, let me remind everyone that the Miramar’s initial proposal did not include heights much above the height of their current 12-story tower (although the design presented other problems). It was only when the City Council at the float up hearing, ironically in response to ideas from an opponent of the project, suggested that the council would be open to a taller, skinnier tower (to help preserve the views of neighbors), that the Miramar devised a taller plan.

In my view the architecture for the proposed tower was uninspired, but in any case the Miramar has had a hard row to hoe because it has neighbors on two sides. Still, the amount of building proposed for the Miramar (a floor-to-area-ratio of less than three) is not so much as to preclude a good design. Even with lot coverage of only 50%, the average height of development will be only six stories. It seems to me that with a good architect and good urban design, the Miramar should be able to come up with a plan that its neighbors (at least those with open minds) wouldn’t object to.

I suspect that if the other two projects, the hotel designed by Frank Gehry and the new hotel proposed for the site of the old Holiday Inn, had come up before the Miramar did, there would be a lot less controversy about them. Both of those projects have top-flight design architects (and that shows in the proposals), neither is in a residential neighborhood, and both make use of land that adds little to the downtown now – respectively, the parking lot at Second and Santa Monica and the godforsaken wedge of land between Colorado and the freeway.

But still these projects need to pass a fundamental question: are Santa Monicans okay today with tall towers downtown?

Thanks for reading.