SMCLC, in conjunction with two other resident groups, has sent the following letter to the Planning Commission regarding item 10A on the 11/14/07 Planning Commission meeting agenda. The letter concerns -- 2834 Colorado Ave. -- a conceptual proposal for a Development Agreement for a 3-story, 115,000 sq foot entertainment production company with 412 parking spaces accessed from Stewart/28th to replace an existing 1-story 32,000 square foot facility.

SMCLC and Neighborhood Groups object to discussions re: 2834 Colorado Avenue until General Plan and related Zoning completed

November 12, 2007

TO: Santa Monica Planning Commission


The Santa Monica Coalition for a Livable City (SMCLC) and the undersigned neighborhood groups have reviewed the staff report and strongly believe that this project should not be entitled to proceed during the LUCE update, let alone be approved, for the following reasons:

This Colorado Avenue proposed project is inconsistent with our 1984 General Plan and perfectly illustrates why residents in this community have banded together to urge the city to adopt a planning moratorium while the General Plan is being revised.

This project is a prime example of a project that should be placed "on hold" until the city and residents conclude their discussions about what commercial development is appropriate and where and how such development will impact our present, growing jobs/housing imbalance, increasing traffic congestion, and the quality of life in our city.

This is why SMCLC and all of the neighborhood groups previously met with the city and recently appeared before the Planning Commission to urge the City Council to impose a building moratorium on various areas of the city experiencing the greatest development pressures. We singled out the LMSD area in particular, as needing this protection and this project in the LMSD is exactly what residents did NOT want to see put on any development track until a master plan and related zoning for responsible development of the LMSD reflecting residents' views was adopted.

As proposed, this project‚s size, scale and potential traffic impacts are inconsistent with its neighborhood surroundings as well as our General Plan. The proposed project would replace an existing single-story 32,000 square foot facility with a three-story 115,200 square foot facility.

Despite this four-fold increase in density and 412 parking spaces, with ingress and egress proposed solely from Stewart Street, the developer surprisingly claims no traffic impacts as a key public benefit. "There will be no impact on traffic over existing uses of the site because the work schedules are flexible" in the entertainment industry. This is California dreaming belied by other entertainment facilities in the surrounding area.

No developer proposing a project of this magnitude in the midst of our LUCE update should receive a "float up" or any type of expedited preliminary application approval from the Planning Commission at this point in time. Nor should the developer be dictating an entitlement schedule in place by March 2008, with all development permits to be issued by December 2008 when no discussion with residents about the scope of the project and its alleged public benefits has occurred and only "extremely conceptual drawings" are being submitted, which are of little help in understanding the project's true impacts.

Any developer proposing a project of this size and expedited review should, at a minimum, be required to notify and meet with all potentially affected residents and businesses in the surrounding area and provide drawings that are sufficiently detailed so as to accurately describe the project. It is unreasonable and burdensome to make Santa Monica residents come before the Planning Commission or the City Council every few weeks until 2009 when our new General Plan may finally be adopted, in order to object to every proposed development project in the pipeline that would not pass muster under the old or the revised General Plan.

Going forward, SMCLC and the neighborhood groups will file written notices like this one with the city for inclusion in the public record as to each such project that it believes is inconsistent with the old General Plan and that likewise would be inconsistent with the new one.

SMCLC and the neighborhood groups object to discussion and/or approval of this project on the grounds that it is inconsistent with the 1984 General Plan, that it would likely not be approved under the General Plan revisions of the housing, land-use or circulation elements, and that approving this project in this interim period would constitute unplanned, piecemeal development by the city of Santa Monica in violation of local and state law.

SMCLC and the neighborhood groups object to this project because it is inconsistent with the goals and principles that residents have articulated during the LUCE process as to high-density projects that worsen the work/housing imbalance, and create additional traffic and circulation problems in an already highly congested area. This project is at odds with those goals.

SMCLC and the neighborhood groups further object to this project because its proposed size and scale make it subject to a development agreement. We believe that all such large-scale projects requiring development agreements now or in the future which exceed our zoning laws should be submitted to residents for a vote. Our city has failed residents too many times in approving development agreements over the past 25 years without sufficient or substantial public benefits that would justify the greater height, density and uses allowed. Equally egregious, our city has not monitored these large-scale projects for compliance with traffic, circulation, parking or other required environmental mitigations.

Because the city has failed to enforce development agreements as required by law, residents are justified in insisting that all such agreements be placed on the ballot for a vote, thereby engendering full discussion and disclosure of all of the public benefits and burdens.


The Santa Monica Coalition for a Livable City (SMCLC)

Friends of Sunset Park Board of Directors (FOSP)

Village Trailer Park Neighborhood Homeowners' Association (VTPNHA)

Lamont Ewell, City Manager
Eileen Fogarty, Planning Director
Maria Stewart, City Clerk