July 24, 2018
SMCLC Tells Miramar Hotel to Study No Condo Project in its EIR
TO: City of Santa Monica
(Roxanne Tanemori, firstname.lastname@example.org)
(Rachel Kwok, email@example.com)
FROM: Santa Monica Coalition for a Livable City (“SMCLC”)
RE: Scoping Comments for the Miramar Hotel Project DEIR
The Santa Monica Coalition for a Livable City (“SMCLC”) submits these comments as to the scope of the Draft Environmental Impact Report (“DEIR”) for the proposed Miramar Hotel project. SMCLC, as well as large numbers of residents and businesses in the City, have great concerns about the proposed demolition of the hotel on the site, to build a new luxury hotel with about the same number of rooms, dwarfed by 60 luxury condos and greatly expanded commercial uses. The proposed project would overwhelm the existing hotel in size and scope.
In the Downtown Community Plan (“DCP”), the zoning for Ocean Avenue was intentionally kept low with greater height and density permitted for the Downtown core. There is little support, among residents (or justification) for the City to have “spot zoned” the Miramar Hotel site, allowing far greater height and density than the rest of Ocean Avenue in order to build a massive commercial/condo development. For these reasons, we believe the DEIR should include an alternative project that conforms to the height and density required for the rest of Ocean Avenue.
On the main site, the developer proposes to demolish the Miramar Hotel in order to construct a 500,000-square foot project, roughly the size of Santa Monica Place which sits on 10 acres. This project would sit on only 4.5 acres, creating substantially greater massing and impact within a much smaller site. The new development would be twice the size of the existing hotel, due mainly to the 60 condos and more intensive retail uses. The existing hotel has 301 rooms; the new hotel would have 312 rooms. That’s only 11 additional hotel rooms as part of a 500,000-square foot project!
We strongly believe this project would not be approved if it were subject to a public vote, among other reasons, because providing 60 luxury units for the super-rich at heights of 130 feet does not provide a community benefit. Nor will the owners likely be stakeholders in our community if they are occasional visitors. And it’s hard to justify it as a good deal for the City’s coffers if there is no appreciable gain in the bed tax resulting from such an immense development. While an EIR doesn’t analyze economic impacts, it will be incumbent on the City to do so as this project goes forward.
We are also concerned with the significant increase in retail on the site, the greatly expanded spa and a much larger catering operation. As proposed, the project would add significant additional traffic to the area, including to residential Second Street and the residential neighborhood it abuts, exacerbating the growing traffic gridlock in Downtown and along Wilshire and Ocean. And, as proposed, the project may not provide sufficient parking to alleviate the current problem of overflow parking on adjacent neighborhood streets.
It is therefore incumbent that the DEIR study a full range of alternatives, including: (1) a project with significantly less height and density, condo and retail space; (2) a project with no condos; (3) a project that conforms to the maximum height and zoning for the rest of Ocean Avenue; (4) a “rehab” project that keeps the existing hotel footprint in reconfiguring the hotel rooms and sizes rather than demolishing the entire building for a de minimus gain in rooms); and (5) a traffic impact analysis as to each of the above alternatives, including the impacts of siting a new hotel entrance and driveways (a) on Second Street, or (b) on Wilshire as well as their respective mitigations.
The DEIR should not pose “alternatives” that do not reduce the project’s proposed heights, density, traffic and other impacts (or only minimally do so) and thereby impermissibly shortchange the required environmental analysis as SMCLC believes was the case with the EIR for the Hines project on the former Papermate site.