August 22, 2011
RE: Item 8-B, SMCLC's Objections and Comments Relating to the Hines Project
for August 23, 2011 City Council Hearing
Dear Members of the Santa Monica City Council,
The Santa Monica Coalition for a Livable City ("SMCLC") strongly opposes approval of the current "float-up" design for Hines' Bergamot Transit Village ("Papermate Project") and any authorization for the city to enter into any negotiations for a Development Agreement at this time.
It's clear from the staff report that Hines is dragging its feet on making the requested changes that the staff and the Council requested since March and wants to push ahead now with preliminary approvals based on rough sketches in spite of ongoing resistance to suitable sidewalk sizes, streets, parking locations and most significantly, the mass, scale and mix of its buildings.
Unfortunately, the project is still poorly conceived as a suburban office superblock not a "village." Building 550,000 square feet of commercial and retail space, plus 220,000 square feet of residential – for a total of 770,000 square feet -- on the already grossly over congested 26th Street and Olympic Blvd corridor would have irreversible consequences for the neighboring area and the entire Westside, particularly as far as traffic is concerned.
This impact will be felt throughout our city streets and this failure of urban planning (if this project were approved) would be visibly, and shockingly obvious every morning as the lines at the 26th Street exit of the 10 Freeway get even longer and this entire area of our city becomes more congested.
The percentage of residential to commercial development is shockingly below the LUCE targets as well as the targets established under the HUD Grant for the Master Plan for the entire 140 acres of industrial land that include the Hines project, the Bergamot Transit Village, and the Mixed Use Creative District. LUCE is in its infant stage, yet these plans flout the LUCE in a significant manner that would defeat its goals.
In addition, the current proposal is still not close to a neighborhood-oriented design. It's monolithic and too big for its site and its surroundings even taking into account that the project has been reduced by 190,000 square feet to about 770,000 square feet. This reduction is inadequate. We're all sophisticated enough, after all of the development proposals that have been presented over the years, to recognize that developers invariably propose way too much square footage, then offer some reduction, and then claim to have listened to residents when the project being proposed is still way too big.
Community leaders asked Hines to do a 3-D rendering of the site per these sketches in relation to its surrounding structures. It hasn't done so. Had it been done, it would have been patently obvious that its design is closer in scope to the massive Water Garden and Yahoo Center, not to smaller scale neighborhood buildings a bit further out.
The timing of the Council's consideration of the Project is also premature from a good planning point of view because its massive scope and impact is being considered outside of the Master Plan. The city has partnered with HUD to develop such a Master Plan for the entire 140-acre industrial area, including this very site. Any consideration of a project of this size needs to await such a Plan, including addressing infrastructure and other multiple factors that need to be evaluated for the entire area. To approve this large project outside of the Master Plan, before the Plan is even ready, would defeat the purpose of the Plan and constitute poor planning policy.
The many serious flaws in the proposed Project are significantly compounded by the ability of Hines to develop or not develop the Project over an almost 20-year period and to develop or not develop it in whole or in any part, all at its sole discretion. This obviously makes any of the traffic, economic, environmental or other assessments even more speculative than they already are. In the area encompassed by the upcoming Master Plan, in the city as a whole, and for our surrounding neighborhood communities, the ongoing possibility, over 20 years, that 770,000 additional square feet can be developed at any time, as of right, with no apparent ability by the city to alter course, would have to be taken as a fact with respect to all future development proposals in the area. The city would, in essence, be granting Hines a "free development card" for 20 years and shift the consequences onto the city. A lot could change over these decades, yet Hines would hold its special privilege, its vested card over other smaller, and perhaps better planned projects with greater community benefits and fewer burdens. Approval of such a plan now would be poor city planning in the extreme.
It bears remembering that in 2007 when Hines purchased the Papermate property, it understood that its project would have to be attuned to its neighborhood, its surroundings, and the existing traffic congestion. Indeed, Hines senior vice-president, Colin Shepherd, told the Los Angeles Times that Hines hoped to build two-to-four story office buildings totaling about 300,000 square feet. (8/27/07 LA Times)
SMCLC urges the City Council not to approve this proposal, to tell Hines its current project size, bulk, design and mix is unacceptable, and to await the draft of the Master Plan for the area and the release of the draft Environmental Impact Report for critical planning information before reviewing a Hines proposal again.
Enclosed is the SMCLC Letter and Exhibits from the initial float-up to Council on March 22, 2011, which we incorporate here into the record in full, containing other comments and objections, including objections to the economic assessment that Hines has belatedly produced.
March 22, 2011, SMCLC Letter to Council Objecting to the Hines Project as then Proposed
Exhibit A Area Development Map
Exhibit B HUD & DOT Monetary Award
Exhibit C Bergamot - MUC Area Plan - Location Map
Exhibit D SMCLC letter re: Papermate DEIR 12-13-10
Rod Gould, City Manager
David Martin, Interim Planning Director
Marsha Moutrie, City Attorney
Neighborhood Association Leaders