This post originally appeared on The Healthy City Local.

After, in words taken from the staff report, “nearly six years in development” (not too much longer than it takes to get approval to build an apartment building!), Santa Monica’s Downtown Community Plan (DCP) is finally approaching finality: the Santa Monica City Council will hear public testimony at a special meeting Monday night, debate the DCP Tuesday night, and vote on it in two weeks.

I wrote five blogs on the DCP in May when the Planning Commission was reviewing it, and I will try to focus my reporting now on the changes in the prior draft the planning and other commissions, and staff, now recommend, and what they are leaving to the council to decide.

There’s bad news and good news.

To start with a little bit of bad news, it appears that not even one board or commission recommended including in the DCP’s history section mention of Arcadia Bandini de Baker as one of the founders of Santa Monica. Maybe the Commission on the Status of Women should review the DCP, too.

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But enough with identity politics. I’ll get right into some good news. The DCP is still fundamentally flawed, but it will be less fundamentally flawed if the council follows the Planning Commission’s recommendations, and even less so if the council builds on them in ways that staff is now suggesting.

To recap what I wrote in May, the DCP represents a retreat from extremely successful policies the City adopted in the 1990s, policies that gave residential development big financial advantages over commercial development. Inexplicably, for a plan that its backers call a “housing plan,” the DCP drastically reduces the edge residential development has over commercial in terms of allowed square footage (“FAR”), while increasing even more drastically the relative cost of residential development over commercial development. While the City has financial modeling that purports to show that residential development under the DCP will be feasible, there’s no analysis that shows that developers will in fact build residential development, when it will be much simpler and less costly to build suburban-style commercial projects like low-rise offices or retail.

The Planning Commission made an effort to address this issue. The commissioners did not make recommendations relating to the substantive issues of the relative costs and benefits of developing housing versus commercial, other than some incentives for 100% affordable projects, but they did recommend simplifying the approval process for all housing developments up to certain size limits. The commission recommended that any housing project on up to two standard lots (meaning up to 15,000 square feet of land) be subject only to administrative approval. Similarly, in the “Transit Adjacent” zone where Tier 3 projects are still allowed, they recommended increasing the threshold for requiring a development agreement from 60,000 to 90,000 square feet.

These recommendations by the Planning Commission are significant, not the least because they have encouraged planning staff to do some planning of their own. On pages 49 and 50 of the staff report, where staff gives its recommendations to the City Council, staff recommends that the council consider additional incentives for housing development.

It’s taken “nearly six years,” but it was heartwarming to see in the staff report recognition that making it administratively easier to build housing would be “similar to the procedural incentives that were formerly in place for Downtown in the 1990s that resulted in the production of approximately 2,500 housing units.” (Let me add, because it’s important, that if these downtown properties had been developed for commercial uses, which, given Silicon Beach would likely have happened, this would have resulted in more than one million square feet of commercial, mainly office, development. Development that would have generated orders of magnitude more traffic, particularly rush hour traffic, than the apartments that were built at the double-FAR granted to residential development.)

I’d be shouting hallelujah to the rooftops, but for the fact that the DCP still contains policies that dramatically favor commercial development over housing, policies that the Housing Commission, believe it or not, wants to make even worse, by piling more affordable housing requirements onto market-rate housing.

The DCP will never be as favorable to housing as the 1990s zoning (which, by way, produced a lot of affordable housing). The staff report makes the unfounded claim that the DCP is different, and presumably better, than the 1990s zoning because the DCP has development standards that will make projects “complement Downtown’s existing character” (for my skepticism about that, see this blog) as well as make downtown vibrant, walkable and welcoming to a diverse population. The problem with this rationale is that the 1990s rules have been proven to produce these results—it’s only wishful speculation that the DCP will do the same.

Part of Downtown’s existing character that the DCP would have complemented.

The Planning Commission also did good work adding incentives for 100% affordable projects, but only in some zones downtown. The incentives should apply throughout downtown. Even more important, incentives should extend to market-rate projects, too. The plan could encourage housing for all income levels and in particular onsite inclusionary housing by the simple measure of not counting the square footage of onsite affordable units against FAR limitations. If developers are saving government from having to provide the public good of affordable housing, why not at least give them free air to build it in? (You could still have a maximum cap on FAR.)

Regarding the zones downtown, the DCP has too many of them. Downtown is not big and there are not as many differences within downtown as the DCP would have you believe. In the six-minute walk I take most days of the week from my office to my dad’s apartment for lunch, I pass retail, offices and apartments, all mixed up. This is good. The DCP overcomplicates what downtown Santa Monica is all about. It’s full of distinctions without differences. It micromanages.

Hopefully the City Council will take into account the recommendations from Downtown Santa Monica, Inc. (DTSM), the City-created entity that manages downtown. Who knows downtown better than DTSM? No one, and DTSM’s recommendations, on pages 31-32 of the staff report, include equalizing (more or less) the development standards among the “Neighborhood Village” (NV) and “Bayside Conservation” (BC) districts and the Transit Adjacent (TA) district. In the staff report the staff opens up the possibility of increasing height and FAR standards, presumably in the NV and BC, but except for a few pros and cons doesn’t provide the council with much in the way of analysis.

DTSM also knows the retail situation, and knows that it makes sense to allow small offices on the ground floors of mid-block apartment buildings. Other than on the boulevards, I don’t see any reason to favor retail over offices in ground floors. DTSM also makes a small but important point, which is that it makes sense to allow retailers to easily redesign frontages.

Thanks for reading.