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)