With the final decision about the Downtown Community Plan, which will govern changes to the downtown through 2030, scheduled for next Tuesday, housing advocates are concerned that some last-minute changes to the plan’s affordable housing requirements will ultimately undermine the goal of producing new housing in the area.

During discussion at the July 11 City Council meeting, City Council members advocated increasing affordable housing requirements. From 15 to 20 percent was the range recommended by city staff and the Planning Commission. Council upped the range of 20 to 30 percent, depending on the project size.

Leslie Lambert, a sitting Planning Commissioner and long-time affordable housing expert, wrote in an email to City Council earlier this week that she believed that new proposed requirements will essentially kill any significant housing growth downtown.

The proposed affordability requirements. Via the city of Santa Monica website.

“The worst case scenario is that we will see no new housing being proposed, which is what San Francisco is facing with its new 25 [percent] inclusionary requirement for projects over 24 units,” she wrote, detailing San Francisco’s Measure C which voters passed there in 2016.

According to the new proposed downtown Santa Monica standards, in projects 40 to 50 feet tall, 20 percent of the units would have to be subsidized. Then for every two feet of height beyond 50 feet, another percent of affordable units is required. At 60 feet, the developer would have to include 25 percent subsidized units and at 70 feet, 30 percent.

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So, at best, the affordability requirements will act as a de facto height limit. If San Francisco is a model, it’s likely that projects 60 feet or taller (that’s about four stories of housing and one floor of retail) won’t be proposed. Not only is this hard to swallow given the severity of the local and regional housing shortage, but it’s also disappointing from an environmental point of view, since Downtown Santa Monica is one of the most transit-rich areas of Santa Monica and as such density there goes much further toward reducing greenhouse gas emissions.

The pivot came at the 11th hour of a lengthy community process, as long-time observer and former Planning Commissioner Frank Gruber noted in his column about the July 11 meeting.

“[T]he debate over the very most contentious and significant issue—the amount of affordable housing to require for-profit developers to build—was based on a new financial analysis that had been assembled in admitted haste over the previous weekend in response to a recommendation from the Housing Commission to expand the required amount of affordable housing to 30 percent in some circumstances, a percentage more than what any other jurisdiction in California requires,” Gruber wrote about the July 11 City Council meeting.

“This analysis, by the City’s regular consultant, Paul Silvern, had not been released to the public for comment or even given to the councilmembers prior to the meeting. The first they heard of it was Silvern’s oral presentation Tuesday night,” wrote Gruber.

As of press time, the analysis was still not available to the public, though city officials said it would be released as part of the staff report for the July 25 meeting. (UPDATE: The staff report, and the feasibility analysis has been published here).

Santa Monica’s Downtown Community Plan has undergone some significant changes in the past few months. In April, city officials released an aggressively slow growth draft of the downtown plan, which was criticized as an inadequate response not only to the regional housing shortage but also to the growing crisis of global climate change.

After plenty of community input and a month of Planning Commission hearings, a revised version of the plan was released. The new version sought to streamline housing up to 60,000 square feet, though city staff thought the final draft could allow for streamline housing projects up to 90,000 square feet.

However, that number was outright rejected by Councilmember Kevin McKeown, who made the motion on July 11 to limit the streamlined process for projects up to 75,000 square feet while dramatically increasing the affordability requirements.

Downtown Santa Monica remains one of the last places in the city where new housing growth can occur without displacing existing housing and the residents that live within. The city’s updated Land Use and Circulation Element (LUCE), approved in 2010, aimed to guide much-needed housing growth to the city’s commercial boulevards, the downtown, and the formerly industrial area north of Olympic Boulevard and east of 26th Street.

Since then, however, the City Council voted narrowly to downzone the city’s boulevards, which has had a major chilling effect on housing growth there. Similarly, the collapse of the Bergamot Transit Village project on the site of the former Papermate factory in 2014 has stalled other housing projects in the area.

Lambert made the point that increasing affordability requirements is an empty gesture if the program won’t work. She, and others, believe that there will be little to no new housing production downtown under the proposed standards. In a city and a region already struggling with a major housing scarcity problem, that’s not good news.