7/8/2013 SMMCN Letter to Council on Downtown Plan EIR

The Santa Monica Mid City Neighbors Board has sent the following letter to the City Council, City Manager and City Planning Director

TO: City Council members, Rod Gould, City Manager and David Martin,  Director of Planning and Community Development  
FROM: Santa Monica Mid City Neighbors Board of Directors
SUBJECT: July 9th City Council Agenda Item 8A, DSP PEIR

We, the Board of Directors of Santa Monica Mid City Neighbors, urge the City Council NOT to go forward with a PEIR on the Downtown Specific Plan at this time for the following reasons:

1)  It is premature to move forward on a PEIR before the city has gone through the process of drafting a Downtown Specific Plan.  To do so puts the cart before the horse and raises serious questions about the good faith of the city’s process.

2)  While we appreciate that planning staff now proposes specific height limits between 120-135 feet for "opportunity sites”, those limits are still too high. Other coastal communities such as Santa Barbara, Venice and Malibu have much lower limits than even our current 84-foot maximum.  We should not exceed that 84 foot limit, even at "opportunity sites", to "preserve the successful existing character" of the city as mentioned in the staff report.

3)  IF the PEIR is approved by Council, it should study retaining the current heights and densities Downtown.  

4)  The LUCE defines three tiers of development, not four.  Tier Three projects (Including "opportunity sites") should be limited to 84 feet, and not the 120-135 feet proposed in the staff report, and certainly not the 195-320 feet proposed in three Ocean Avenue hotel projects.

5)   Tier Three projects up to 84 feet should NOT be entitled through a Development Review Permit, but only approved after the stricter Development Agreement process that allows more public input.

6)    We are opposed to Alternative Action #2.  Developers who propose hotel projects that exceed the height limits in the staff report should be required to pay for their own EIR's.

7)    Hotel projects should not be allowed density bonuses as mentioned in Alternative Action #3. What study suggests that hotel guests generate fewer car  trips?  Certainly, hotels host and hold a number of big events that generate traffic, like the recent Chamber of Commerce Installation Dinner at the Miramar.  We doubt the hundreds of attendees rode the Big Blue Bus to get there.

8)    The mixed-use criteria proposed for projects on Lincoln Boulevard will severely impact nearby Mid City and Pico neighborhoods.  Circulation and traffic congestion needs to be addressed in the DSP before any EIR is done.

In conclusion, we ask the Council to follow established public planning processes  and hold off approval of a PEIR for the DSP until AFTER the city has at least a draft of the Downtown Specific Plan.  We also ask the Council to preserve the existing levels of height and density because most of Downtown has never been developed above 84 feet and is already highly successful, and already higher than other coastal communities in Southern California.  Furthermore, we think development decisions on height and density should NOT be predicated on the notion put forth by some that potential future budget shortfalls will result unless the Council approves projects above the current 84-foot threshold.  For example, supporters of the Miramar project say it would add $5 million to city revenues.  That's just 1% of our overall budget.  The recently approved two-year budget achieved almost 3.5% worth of cuts and fee increases with little lost in the way of  services.  To build our way out of a possible budget shortfall that could be addressed through other means is not good fiscal management.

We respectfully request that City Council address these concerns before proceeding with the PEIR.

Sincerely,

The Santa Monica Mid City Neighbors Board of Directors