May 12, 2020

Dear Supporter of SMCLC:

Here is the letter we sent to the Planning Commission this morning objecting to any amendment of the Downtown Community Plan to process Tier 3 housing projects greater than 90,000 square feet under a “streamlined” development review permit.

RE: Agenda Item: 8-A (Eliminating DA review for Tier 3 housing projects exceeding 90,000 square feet

Dear Planning Commissioners,

As our Planning Commissioners, residents rely on you to reject knee-jerk responses for fast fixes and instead, to provide thoughtful, factual analysis, and demand the same from City staff. Unfortunately, this staff report gives you nothing you need to decide whether this is a good idea or a terrible one. In the many housing discussions that both you and the City Council have entertained, no one has studied eliminating Development Agreements for the largest housing projects exceeding 90,000 square feet. Further, we believe that this proposal will have unintended consequences and erode public trust.

In response to what was basically a “shout-out” from a councilmember during a study session, you are now being asked to change the Development Agreement approval process for Tier 3 housing projects to a “streamlined” development review permit.

One line in the very short staff report says it all: “This change would be intended to encourage the development of larger housing projects as the current requirement of a Development Agreement for projects greater than 90,000 square feet may be viewed as a disincentive for property owners to maximize housing developments.” (Emphasis added).

Those are two speculative and subjective thoughts unconstrained by any factual analysis.

Maybe property owners (developers) will do what you hope, and maybe they won’t unless they can make more money. Maybe all this idea will accomplish is to create a wave of land speculation downtown as developers and REITs don’t build the housing you want, but instead wait for a new, more favorable post-pandemic, post-financial crisis world. In a couple of years, nothing in developer time, the speculators you will create tonight will press for new development standards (in order to have their projects “pencil out”) that – no surprise – will feature mostly market rate and luxury housing with barely a nod to affordable housing. There is nothing in this proposal that would prohibit that from happening. In fact, it’s inevitable. And when it does happen, you will have facilitated it along with the predictable and disastrous up-scaling and gentrification.

“Streamlining” the development process also provides a kind of “punch list” for both staff and the developers; it’s a cookie cutter approach instead of being responsive to the actual needs and impacts of specific project sites and their surroundings.

The current pandemic and financial crisis will inevitably result in a top down review of downtown land-use assumptions (the levels of retail, office, hotels and yes, housing) that our city planners have used to guide our future. Is this the best time to be considering a “quick fix”?

While the public – residents – are busy quarantining from this life-and-death pandemic, the city should not be deputizing staff to push through what would become the biggest housing developments in our city.

This proposal is misguided and cannot be justified. It should be rejected.


Diana Gordon Co-Chair, Santa Monica Coalition for a Livable City (“SMCLC”)

Cc: City Council City Manager Lane Dilg Planning Director David Martin Planning Division Manager Jing Yeo Community Groups