Answering questions about Santa Monica’s LUVE initiative

LUVE Initiative

By now, most of you may have heard of the LUVE initiative. LUVE stands for Land Use Voter Empowerment. It is a citywide initiative started by Residocracy to allow residents to vote on major city development issues and projects. Signatures are now being collected to place it on the November ballot. This initiative is in direct response to several recent controversial development projects that have been approved or are being processed without much resident buy-in or approval.

Naturally, in anything as complex as a citywide initiative that is designed to give residents a say in how their city is being developed, there are many details that need explanation. Understanding the initiative is critical to its success, so this week’s SMa.r.t. column is a list of answers to your frequently asked questions:

Does the initiative prohibit every project higher than two stories?

No. Projects higher than 32 feet (two or sometimes three stories) would go through a more extensive permit process, including approval by the voters. Voters could approve a project that is higher than 32 feet (the City’s predominant baseline height), or they could reject it. There are important exemptions to this requirement, as detailed below.

What are the details of this new extended permit process?

The new permit process for projects higher than 32 feet would be called a Major Development Review Permit. Such projects would be initially reviewed the same way they are today by the Architectural Review Board, the Planning Commission and the City Council. Then, after approval by City Council, the projects would need to be approved by voters either in a special election or in the general election.

Are there exemptions to this new permit process?

Yes. Projects that would be exempt from the new Major Development Review Permit process include: 100 percent affordable housing projects of 50 units or fewer; projects that exceed the 32-foot height limit only because of state-required height and density bonuses for affordable housing; projects that include on-site affordable housing in compliance with the City’s Affordable Housing Production Program; and single-family homes.

These projects would simply need to comply with the zoning code, so if a 100-percent affordable housing project (of 50 units or fewer) were designed to be higher than two stories, it would be approved as long as it complied with the height allowed in the zoning code — no voter approval needed.

Will every commercial project above two stories require a special election?

Every commercial project higher than 32 feet would be submitted for voter approval at an election unless it fits the list of exemptions in the initiative. City Council would decide whether a project that requires voter approval would go to a special election, or alternatively, would be put on the next election’s ballot.

Who would pay for a special election if the City Council chooses that option?

The project’s developer would pay for that special election.

How about market-rate housing projects? Would those require voter approval?

Those projects would require approval only if they exceed 32 feet in height and don’t fit the list of exceptions in the initiative. A project could be exempt for a number of reasons. For example, a project higher than two stories (or 32 feet) could avoid voter approval if the reason it exceeds that height is only because of height and density bonuses required by the state for affordable housing. A project could have market-rate housing that brings its basic height to 32 feet, and then be allowed extra height for inclusion of affordable housing (as specified by state law).

Is voter approval needed just for projects that are higher than 32 feet?

No. Two additional items would also require approval by the voters:

1. All major amendments to various city land-use plans that control how and where development takes place. For example major changes to the LUCE (Land Use and Circulation Element), the Zoning Ordinance, the Districting Map, Neighborhood Area Plans and Specific Plans (except for an Airport Land Specific Plan allowing only park and open space use) would need to be approved by the voters. Major changes include, among others, increases to the number of housing units that could be built on a given site, increases to height limits, changes to the size of commercial projects that would be allowed, and repeals of any planning policy documents.

2. All Development Agreements would need voter approval except as noted below. A Development Agreement is a contract between the City and a developer, in which the city agrees to approve a project under certain conditions. Development Agreements are used to build taller or bigger projects than otherwise allowed by law.

Which Development Agreements would be exempt from approval by voters?

Development Agreements that would not require voter approval include: 100-percent affordable and moderate-income housing projects; 100-percent senior housing projects; projects in the Coastal Zone that comply with the height and density limitations in the Local Coastal Program when adopted (the Local Coastal Program must be certified for these projects to be exempt); projects on sites listed in the City’s Housing Element (which is part of the City’s General Plan), with minimum residential percentages and maximum floor-area ratios as specified in the Housing Element. There are 77 such sites throughout the city, and they are listed in the initiative. This requirement would last until 2021, or until a new Housing Element is adopted

Development Agreements for all other types of projects would require approval by the voters.

Would the proposed project at 5th Street and Broadway be required to obtain voter approval?

No. This 8-story, 302,000-square-foot project has been already been approved by the Planning Commission, so it is likely that it would approved by the City Council before the Initiative passes. However, once the initiative passes, projects such as that one would need voter approval.

Would the proposed 12-story project at 5th and Arizona be required to obtain voter approval?

Yes. This oversize project would need to be approved by the voters. In fact, the initiative is designed specifically to deal with such controversial projects by giving residents final say in these over-scaled developments.

Why is the initiative so complicated?

The initiative is complicated because it has to be consistent with state laws, City codes and regulations already in place. In addition, it is designed to withstand the expected legal challenges. Each clause or exception is designed to make sure it functions in a robust and equitable way. However, it is really quite simple in its effect, which is to make the City as a whole more responsive to the wishes of its residents by giving them a direct say in choosing which large projects can invade our City.

SMa.r.t. (Santa Monica Architects for a Responsible Tomorrow) Sam Tolkin, Architect; Dan Jansenson, Architect; Mario Fonda-Bonardi, AIA, Planning Commissioner; Ron Goldman, FAIA; Thane Roberts, AIA; Bob Taylor, AIA; Phil Brock, Chair, Recreation & Parks Commission.

6 reasons to support Santa Monica’s LUVE initiative

Land Use Voter Empowerment

Some of you may have heard of the LUVE initiative. We support this measure, which aims to protect Santa Monica from overdevelopment, keep traffic from getting worse, preserve resources and protect the widely loved character of the town. This SMa.r.t. column explains what it is and why we support it.

LUVE stands for Land Use Voter Empowerment. It is a city-wide initiative started by Residocracy to allow residents to vote on major city development issues and projects. Signatures are now being collected to place it on the November ballot. This initiative is in direct response to several recent controversial projects that have been approved or are being processed without much resident buy-in or approval. Examples:

  • The Hines Papermate project, approved last year by City Council after 7 years of indecisiveness and pleas from L.A. City and L.A. County to avoid creating monumental traffic issues. In place of the “village” envisioned by the city’s Land Use and Circulation Element (LUCE) planning document, the residents were served up a 7,000-car gridlocked behemoth. The City Council, which had previously approved the project enthusiastically, reversed course and killed it after Residocracy gathered over 13,000 signatures to place this project on the ballot.
  • The Ocean Avenue Project, also known as “the Frank Gehry Hotel.” A large, 22-story hotel tower right in front of the beach at the corner of Santa Monica Boulevard and Ocean Avenue, set within a 340,000-square-foot project that includes retail stores and condominiums. The tower has raised important questions about the turning of Santa Monica into Miami Beach and the blocking of ocean views by private developments along the coast. The significant community benefit from this development agreement — low-income housing units — can be counted on one hand.
  • The Plaza at Santa Monica, a massive, 12-story, half-million-square-foot project in the center of the city, across from the old Post Office, and in the heart of a district slated to receive millions of square feet in additional development. Only 15 percent of the site would be open space, but even worse, this leviathan would be built on resident-owned land. As an example of an alternative approach, back in October our colleague Ron Goldman sketched out a much more modest proposal that would keep 65 percent of the site open to function as a city square while maintaining the same nominal 50 units of affordable housing as the original.

LUVE is an attempt by the residents to have a say in how the City is developed instead of trying to stop unpopular projects after they have secured approvals from pliant City officials and commissions. Because it speaks directly to issues of development and political power, profits and political contributions, it has generated a lot of controversy. There has already started an avalanche of misinformation about LUVE that this article will try to clarify. This is a brief explanation of its major provisions:

  1. The initiative encourages small-scale, low-rise housing, business and retail. It applies to most projects over 32 feet high, with exceptions provided, such as affordable and senior housing. Thirty-two feet is the planned base height in our General Plan for most of our city. It can accommodate two, and in some cases three, stories. Our City, through the public process of creating the LUCE is predominantly envisioned as a low-rise beach town. Thus, LUVE allows residents to weigh in on projects that are clearly above our City’s baseline height on larger projects.
  2. Most of the zones in our zoning code provide incentives to encourage development that is higher than the base height and density. In exchange for extra height and density, the developer provides certain community benefits. These benefits might include extra housing, extra fees, extra sustainability requirements or fees for specific mitigations. However, the value of those community benefits compared to the cost to the residents of that extra mass, extra disruption, extra schools, water and infrastructure demands and extra height are never subjected to a popular vote to see if the “deal” offered by developers is worth it to the residents. LUVE allows residents in effect “to sit at the table” and have a direct say in how big and impactful projects could be. Voter approval would be needed for these Development Agreements that have been so disruptive in the past and show no signs of letting up.
  3. Housing is always a consideration in our high-priced, high-demand City, so LUVE specifically exempts low- and moderate-income and senior housing projects, which can be as high as the underlying zoning, up to seven stories. In fact, it specifically exempts parcels which are identified in the Housing Element which are capable of meeting our housing needs.
  4. Higher density or special use properties, such as in the Downtown or Civic Center areas, require the creation of Specific Plans, Neighborhood Area Plans or zone changes. So voters would also weigh in on major amendments to the city’s land-use plans, such as LUCE, the Zoning Ordinance, Neighborhood Area Plans and others, which can have such an impact on everyone’s quality of life.
  5. The initiative is similar to those already approved in a number of California cities, so asking the people to vote on their city’s future is not a risky proposal. Those cities have suffered no ill effects of limiting heights and development by requiring citizen buy-in.
  6. Finally, this initiative has a sunset clause of 20 years. Perhaps the willingness of the citizens to participate in the development of their City wanes or starts having unintended consequences after 20 years. Or the conditions of development change so materially that the initiative is no longer needed or is no longer popular. If so, LUVE wisely has a final date after which it no longer applies unless renewed, as required by state law.

We expect LUVE to have several beneficial effects. The initiative will help dampen the speculation in commercial property values that has been encouraged by the City’s policies for the past few years. This will help smaller, local mom-and-pop businesses remain in the city, help preserve some of the historic older buildings in town and encourage less costly construction of housing projects for those folks needing it most. By slowing somewhat the construction feeding-frenzy we are experiencing, this initiative will give some breathing room for the city to adapt more flexibly to new circumstances such as the continuing drought, the arrival of the Expo Line, the need to upgrade infrastructure, the need for buildings that generate most of their own energy, etc. — all tasks that require appropriate, timely responses but that become immeasurably harder when the City is swamped with runaway development. Finally, it sends a clear signal to all that any large development must have significant real benefits to the majority to be approved.

We feel residents should have a direct say in how their City evolves. And they can do that by signing the LUVE petition, getting it on the ballot and then voting for it in the next elections. That’s what we recommend and endorse.

SMa.r.t (Santa Monica Architects for a Responsible Tomorrow)

Downtown Santa Monica and the ‘Community Plan’ that isn’t

Downtown Community Plan

The City’s focus on maintaining the character of our environment has recently shifted from the neighborhoods, to the Downtown. “Storm clouds” are gathering with an impending clash between residents, developers and City staff over the future of our City’s core. In 2010, the Land Use and Circulation Element (LUCE) was approved. Its implementation has taken much longer – over five years. A new City Zoning Code was only enacted recently and the new Downtown Planning code has yet to be approved, six years after the LUCE. It is now being pushed for a fast-track vote by midyear. The question is not whether this is possible but if it is prudent.

While the lack of an updated Planning Code has created a vacuum that has fueled “Development Agreements” (DA’s), a rush to fill this gap could worsen matters if the current Downtown Community Plan (DCP) is approved. As it happens, last-minute changes in the DCP would allow higher and larger projects as well as the removal of both residents and City Council from the approval process for projects over 100,000 square feet.

If this is allowed, it is likely that the number of oversized projects downtown would increase, forever diminishing the area’s ambiance and character. As it is currently proposed, a developer’s path to approval would be faster and would avoid the public review as is currently required. The last time the public felt betrayed by their lack of input for a new project at the old Papermate site, the residents revolted and launched a referendum to stop the development. Let’s hope that we have learned the lesson that it is counterproductive to ignore public opinion. The recently launched LUVE initiative is a warning that residents will not stand idly by if City government fails to heed their concerns.

While the majority of our City now has an updated Planning Code, the downtown area will be the last to have a definitive set of rules to guide its future development. These regulations will either define our City as a small, unique beach town or allow its transformation into another large commercial center with no soul. Is this how we want to be seen by those who visit and live here? The new code is intended to “codify’ the goals and parameters laid out in the Downtown Specific Plan (DSP). At the eleventh hour, the DSP was revised and renamed the Downtown Community Plan (DCP). Although the City’s claims that the two plans are “nearly the same” may be true, their few differences are significant. Most notable is the removal of public input from projects less than 100,000 square feet. Other changes will be an increase in allowable heights, even though the LUCE recommended height reduction.

Previously, new projects less than 7,500 square feet under the DSP were exempt from community review. Under the new DCP, the bar for community review has been raised to 100,000 square feet — a 13-fold increase. Since most lots in the downtown area measure 50′ x 150′ (7,500 square feet total), this provision would encourage higher structures as well as lot consolidation resulting in the construction of more massive projects. This would be allowed with NO community or City Council review. The likely consequence of such a change would be the demolition of historic buildings and their replacement with large “box stores” and/or commercial office buildings. These building types are often lacking in character and are out of scale with our current downtown that is mostly comprised of one and two-story buildings, all much smaller than 100,000 square feet.

The City’s assumption of parity between these two versions of the Downtown Plan has emboldened them to submit the updated DCP with an old Environmental Impact Report (EIR) written for the original DSP. This is a problem. The EIR for the original DSP made the assumption that the entire Downtown area was a “Transit Area” defined by CEQA as within a half-mile radius from a transit station. This designation is important. In a ‘Transit Area’, some negative impacts are not considered “significant” and thereby do not require mitigation. These include such impacts as diminished sunlight, view, and aesthetic considerations, to name a few. In fact, 15 to 20 percent of the downtown’s northern portion may be outside of this half-mile radius. If so, all of Wilshire Boulevard and the northern portions of Ocean Avenue and Lincoln Boulevard would be exempt from the requirements of CEQA as a “Transit Area.” At the very least, aesthetic issues, access to light and preservation of views should be considered along this major corridor with a high-density residential community on its northern boundary designated in the EIR as a “sensitive area.”

If the new DCP plan is “fast-tracked” through the approval process, it will likely diminish the community’s ability to review and comment on the proposed changes. In addition, although the two plans have few, but substantive differences, the City should not be able to submit the revised DCP plan using the EIR intended for an earlier DSP that contained different requirements. Although few in number, the proposed changes will have significant impact on the scale and character of our City: increased heights, mass, traffic, infrastructure and the diminished importance of solar access, availability of water, and scenic view corridors. A new EIR must be commissioned.

If changes are to be included in the new DCP, they should be ones that support rather than diminish two attributes of our City that both residents and visitors alike cherish — small beach town character and sustainability. A further review of the new DCP might also enable the inclusion of some additional features to enhance our downtown area: 1) a comprehensive pedestrian network including “paseos” through buildings for access from alley parking structures; 2) an urban park at the City-owned site at 4th and Arizona; 3) Improved parking, better vehicular access, public transit lanes; 4) parks and green space with public art such as that on the popular Third Street Promenade; 5) more amenities, shops, schools and services for the growing number of downtown residents.

While we welcome the rapid implementation of the DCP, it is too important a document to rush, to allow be incomplete or to fail to address the issues that are most important to residents. It must undergo a thorough community review and participatory process to ensure that the community’s concerns are addressed and their priorities met. The stakes are too high to do otherwise. To do so could invite even further delays and public acrimony.

Thane Roberts, AIA, Architect, for SMa.r.t. (Santa Monica Architects for a Responsible Tomorrow)

Six Questions about the Downtown Plan

Downtown Community Plan

The City of Santa Monica is currently engaged in finalizing its Downtown Community Plan (DCP). This Specific Plan is generally bounded by Lincoln Blvd., the 10 freeway, Ocean Avenue and Wilshire Blvd and is supposed to govern development in this area till 2030.

SMart (Santa Monica Architects for a responsible tomorrow) recognizes that different factions will advocate for their own visions for Downtown. That said, and regardless of which vision one may support, certain fundamental questions need to be answered by whatever plan is finally adopted:

• How many Residential Units should be added downtown during the next 14 years?

Let’s say for sake of argument there was some documented specific “need” for downtown growth. Until that is produced, we only have the drive of “market forces” to benchmark our growth as reflected by the City Council’s approval over the last 3 years of about 100 units a year in the downtown area. The DCP staff envisions, adding 2500 units over the next 14 years; or a rate of growth 178 units per year (a 78 % increase over the current rate) packing the downtown with about three quarters of the about 239 units that represent our fair share of regional annual growth. Is this over concentration wise given that our Boulevards with their current zoning have at least three times the growth capacity as the downtown?

2. How will this growth affect the character of the downtown?

The DCP makes a strong case for preserving its “our town” character “ yet the proposed growth, with heights up to 130’ and the expected 600, 000 to a million square feet of added retail and office area (equivalent to two new Santa Monica Places) would fundamentally alter the experience of downtown. Height is a good barometer of the character of a place since it affects shading, views, sunlight for photo-voltaics, street safety, energy self sufficiency and the relative pressure to demolish historical buildings. Height also relates to the number of floors which impacts all mobility loads (people, cars, buses, bikes), the tax base, housing, and business opportunities. Since over 60% of the downtown area is either empty lots or one and two story buildings, our current downtown has a very low rise feeling even with a number of tall buildings all built at an earlier less environmentally sensitive time.

The low rise buildings and open lots provide “breathing space” to the downtown urban fabric helping to maintain a human pedestrian scale. For example the Third Street Promenade is primarily experienced as a low rise two story environment in spite of its wide range of building heights. The proposed plan has maximum heights of 84’ over 2/3s of downtown. The other 1/3 averages 66’ with a few parcels allowed to go to 130’. If we ignore those ultra high parcels, our downtown will have an average allowable height of 78’ which translates to 96’, since buildings are allowed to exceed the building heights by 18’ for penthouses parapets, elevator shafts, etc. Is an effective 96’ height limit beneficial to the character we want to preserve for our downtown?

• How does the Downtown Community Plan help in preserving older buildings?

The effective height limit of 96’ translates to 7 or more stories. No developer tears down a two story building to put up a three story building. But once the allowed stories increase by two or more above what exists, the pressure to develop that parcel becomes irresistible. Therefore, this plan threatens the vast majority of the older one to two story buildings that provide most of “our town’s” character. While the Plan does provide minor breaks for Historic Buildings and advocates increasing the Historic Resources Inventory for possible landmarking, the new height limits crush any preservation effort since they incentivize massive demolition efforts on the majority of parcels. Are the DCP’s preservation incentives strong enough to preserve the 53 potentially viable important historic buildings? While historic buildings are not evenly distributed in the downtown, please note that if all these preservation efforts are successful only about three buildings would be preserved every 4 blocks.

4. Does the DCP incentivize reducing the City’s need for water?

Our City has a goal of reducing water use (or creating a new supply) by about 32% to reach self-sufficiency by 2020. From 2005 to 2013 residential use declined 6% (while the population increased 7%) and the commercial water use (about 1/3 of the City’s demand) increased 12%. In other words the commercial usage increase has cancelled out all the strenuous water conservation efforts of residents. This trend is not likely to change. Travis Page, the City’s DCP planner, expects the downtown population to increase by about 3750 (2500 new units X 1.5 persons/unit) or about 4% while the City’s overall job growth is projected between 2% and 5%. Since multifamily residents typically use less water than single family residents (fewer lawns and back yards), we can probably expect a 4% residential water growth and a 3.5% commercial increase for a blended consumption increase of 3.8% over the next 14 years. This doesn’t sound like much, until you realize that we are trying to cut consumption (or raise production) about 8% a year for the next four years in a row. Not during the depths of the recession nor in the historic drought, when the governor called for a 20% water use reduction, have we ever achieved anywhere near these kinds of targets. So the question is how are the downtown businesses and residents going to cut water use to the point that it makes that kind of difference for the whole City? As the growing “edge” of our City they will have to do more than their share.

5. Will the DCP’s mobility plan really increase mobility downtown?

Everyone knows that the traffic downtown is abysmal. The residential population is expected to almost double from 4016(2010) to 7766 while worker population would increase from about 19416 to as high as 23,884 (e.g. a potential 23% increase). The EXPO line, possible increased bus/bike usage, might help mitigate these additional demands, but we really don’t have the lane and sidewalk widths to handle them. TDMs (transportation demand management) which are a series of measures such as carpools, free bus passes etc. that can help reduce peak hour loads, have been implemented for a decade and have yet to show they are up to the task. The downtown EIR (Environmental Impact Report) predicts that, even under the best of circumstances, of the 48 intersection conditions studied (16 intersections at AM, PM, and weekends), 38 (79%) will be rated at Level of Service D or lower, compared 65% now. While the EIR struggles mightily, studying one way streets, lane closures, bus lanes etc., no clear solution emerges to really solve this problem. We have the 10 Freeway, the EXPO line, and 4 major boulevards dumping cars, buses, bikes, and pedestrians into a downtown already gridlocked. Something has to give, yet what we see is a DCP that suggests a solution by increasing and concentrating even more transit demand.

6. Finally where is Downtown’s Center?

Santa Monica Plaza (5th and Arizona) is proposed as Santa Monica’s Center. This 130’ high mish mash of housing, hotel, etc. does not include a big enough open space to be the center of our beachfront town. We have already built essentially the identical building on the North East corner of 4th and Wilshire, and its incapable of a flagship role. This new Plaza needs to be a real Plaza, a sizable urban open space, like St Mark’s Square in Venice, not a height busting monument. The discussion of this center, including the demolition of parking structure #3 for an Arclight Theater needs more community buy-in before millions of public dollars are spent.

These are six simple questions that the DCP needs to address.
Santa Monica Architects for a Responsible Tomorrow
Sam Tolkin, Architect; Dan Jansenson, Architect; Mario Fonda-Bonardi, AIA, Planning Commissioner; Ron Goldman, FAIA; Thane Roberts, AIA;; Bob. Taylor, AIA; Armen Melkonian, Environmental Engineer; Phil Brock, Chair, Recreation & Parks Commission

New Plan, Old Concerns

Downtown Specific Plan

The draft of the new Downtown Community Plan has now been made available to the public for input. This draft is the result of years of effort, re-writing and reconfiguring. Now, after the arrival of our new City Manager, an attempt has been made to simplify the plan and reduce its size to something more manageable and easier to understand.

At first glance it appears to be a worthy effort, with many excellent improvements. However, questions persist about many of the Plan’s details, and about how well some of its specific proposals align with concerns expressed in our community. Here are a few of them.

1. The Plan would allow certain projects containing up to 100,000 square feet to attain approval through the Planning Commission and then City staff, and not by City Council. This process, called Development Review, includes public review and approval by the Planning Commission, and then by the staff of the Planning Department, without any additional community input at all. A project of this type would be nearly double the size of City Hall. Imagine multiple City Hall-sized projects in the downtown area approved only by the Planning Commission and City staff without any additional review!

In the past, large projects were subjected to a process that included an agreement with the developer to add so-called “community benefits” in exchange for additional height and size. These Development Agreements have been harshly criticized for allowing excessively large buildings with relatively meager community benefits. California law allows these Development Agreements to be challenged by citizens through the ballot box, via the referendum process. That’s what happened with the Hines project. However, under the draft Downtown Community Plan, projects up to 100,000 square feet would not be subject to a Development Agreement, except for the seven “Opportunity Sites”. Residents would be blocked from challenging them via the referendum process.

The City and many residents have said that they would prefer to phase out Development Agreements in order to help clarify the rules for the benefit of both developers and residents, and to avoid “back-room” deals. However this large a project, double that of City Hall, should be not be approved before going through City Council, at the very least.

2. The Plan allows the height of many new buildings in the Downtown area to be more than triple that of most existing properties. And yet a continuing theme in the Downtown Community Plan is the intent to maintain the character and charm of the downtown district. For example, the introductory chapter cites the “quality and charm of its buildings”, and the second chapter suggests that we “maintain the ‘Our Town’ character of Downtown Santa Monica” and “preserve and enhance Downtown Santa Monica’s charm and character by requiring new development to contribute high standards of architecture, urban design and landscaping.” How can the City hope to maintain the character of the downtown area while allowing new buildings to be three times as tall as most existing ones?

3. The accuracy of certain parts of the Draft Community Plan is questionable. For example, the plan states that the majority of the existing buildings in our downtown are 3 and 4 stories, when the actual number is less than 30% (as confirmed by a windshield survey conducted by our colleague Ron Goldman). The Plan also says that the City is not a major landowner in the Downtown area, and yet it owns several very large properties, including the Big Blue Bus yards, the 4th/5th & Arizona site across from the old Post Office (and now the subject of a controversial and huge new project), and the site for the proposed new ArcLight movie theaters (which will replace a soon-to-be demolished parking structure, near the Promenade). These spots could be suitable for cultural facilities, including museums and theaters, which are listed as important community benefits. Instead the city is processing plans for hotels, movie theaters and other uses on these city-owned properties. Is this the best use for city-owned properties in the Downtown area?

Will the large number of new residents expected to live in the Downtown area have children? If so, as the Plan states, they will likely be attending school at Roosevelt Elementary and Lincoln Middle School – not exactly within walking distance. We wonder how those children will get to school every day.

4. The Plan rightly suggests that alleys are important for added pedestrian access, but it proposes no building setbacks for those canyon-like areas. Consider that recently completed developments hover 60-70 feet above those relatively narrow passageways. It is hard to see the charm and character of those near-tunnels as they provide entryways to the pedestrian-oriented Promenade and areas alongside it.

Other open-space suggestions in the Plan cover the importance of sidewalk setbacks, parklets and mid-block “paseos”. However many of these are suggested simply as community benefits to be negotiated with developers. There is no specific plan to implement these improvements through zoning. The City controls and determines the zoning rules in this area (one purpose, after all, of the Downtown Community Plan), so why not ensure the viability of these types of spaces by requiring them outright?

5. The infrastructure component of the plan needs to have internal contradictions and inaccurate information revised. As we’ve written here before (on January 23, 2016 and December 5, 2015), the Plan counts on habit-changing water-use policies to “expand the capacity of the water system.” Habit-changing water conservation policies should be taken only to conserve water, and not to provide increased capacity for development, especially when the new habits that result from those policies may change along with the weather. The Plan anticipates an increase in demand for sewer capacity, and that always comes with increased demand for water (on the principle of “what goes in must go out”). As we stated earlier, at some point we must acknowledge that more users will require more water, no matter what habit-changing conservation measures the city takes. That water will have to come from somewhere.

Finally, the proposed Downtown Community Plan allows for the existing building area in the Downtown district to more than double, but it never discusses or identifies how much development is needed, nor identifies the reasons it is necessary. Many residents have been asking for an explanation. Why is so much extra development needed in our city’s downtown? The Downtown Community Plan is the place for this explanation, and it is sorely needed.

Ron Goldman and Dan Jansenson for Santa Monica Architects for a Responsible Tomorrow.