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LUCE: First Look at a First Draft

By Frank Gruber

December 7, 2009-- The process of adopting new land use and circulation elements (LUCE) for Santa Monica's general plan began in 2004 and was intended to last two years. The process now is in its sixth, but a milestone has been reached. Two weeks ago Santa Monica's Planning Department released a draft of the LUCE.

Not a summary of public input, not a "framework," but an actual text.

The end may not be in sight, but it's glimmering in the distance.

The delay had one good effect. In the past three years the plans for the Expo light rail have become much more definite, and the LUCE now takes those plans into account.

The Planning Commission will now review the draft before sending it to the City Council for final review and adoption. But although the commission is holding a special meeting on the draft Wednesday evening, real deliberations will have to wait until the City releases a draft Environmental Impact Statement. That will not be until January at the earliest.

I have started reading the draft. It's long - hundreds of pages - much longer than the 1984 plan it replaces. Frankly, there's a lot of rhetoric in the draft before it gets to the substance. Rhetoric is not necessarily bad; I don't mean to equate rhetoric with "rhetorical." I mean rhetoric in the sense of discussion and intellectual argument - of making a point.

The rhetoric has a purpose, but it's odd to see statements analyzing the LUCE in the LUCE, such as, on page 2.1-2: "The LUCE has a profound communal purpose. It looks beyond the cityscape of buildings and streets to the vibrant network of human relationships that are cities' very reason for being."

Opponents of the plan will ridicule the narrative in the LUCE as propaganda, but the narrative is there precisely because people have to be reminded that quality of life is not a function of adding up square feet and traffic counts.

The broadest concept embodied in the draft is sustainability. Sustainability is what current urban thinking is about, and it's a concept that includes both the quality of human life, social and economic, and the health of the environment.

I like "sustainable urbanism" as a term to describe the goals of urban development better than "smart growth", a term that has been used in recent years, because it's more descriptive. The two words, "sustainable" and "urbanism", describe exactly what the idea is, while "smart growth" always seemed vague and a little condescending, as in, "if you disagree with this, you're not smart."

The LUCE draft is unapologetic about being a document about a city. There's no pretence about Santa Monica being a suburb, false thinking that helped bring about the suburban-style office parks that create the traffic people hate. Nor does the LUCE rely on technologies for its sustainability (as is the case with building-oriented programs like LEED), but on the inherent efficiency of the urban form.

No doubt, given the realities of local politics, the activists over at the Santa Monica Coalition for a Livable City who brought us last year's RIFT initiative will attack the LUCE for the growth it encourages in about 5 percent of the city's area. The LUCE bills itself, however, as a conservation plan and in this case there is truth in advertising. It will be hard to build much in the other 95 percent.

The LUCE responds to political realities, not only with rhetoric but also with policies, and some of those policies are problematic. At the heart of the LUCE's plans for the next 20 years is the idea of converting underused industrial lands along the route of Expo into relatively dense neighborhoods. Because the drafters of LUCE know that no-growthers will always attack any new building over two stories as "Manhattanization," the LUCE says that to justify those higher stories developers will have to provide "community benefits."

This will turn nearly any project, no matter how good it is on its own merits, into a discretionary process - either a development agreement or something resembling a development agreement.

While this might make sense for large projects - such as the new neighborhoods - discretionary review will be overkill for smaller projects, such as the development of housing over retail on boulevards, another goal of the LUCE.

As I have written before, (The_Most_Beneficial_Benefit), the community benefit that matters most is housing, and the benefits are not restricted to affordable housing. At this time Santa Monica needs housing of all kinds.

But the LUCE does not always make it easy to build housing. Under its provisions, for instance, one can build on a boulevard a two-story, 32-foot high building by right. To build merely another three feet of height - three feet that will be hardly noticeable from the street but which will enable a three-story building, of which two stories would be housing - one must go through a discretionary process.

The problem is that discretionary processes discourage people from building housing because they add too much in costs and uncertainty. This is especially true if environmental review is required, and it usually is, even in urban in-fill situations.

Yet along our boulevards, a building with one floor of commercial and two floors of housing is better for the city in every respect than a building with one floor of commercial and only one floor of housing - no matter if the housing is dedicated affordable or market rate. (Housing along boulevards is not typically luxury housing in any case.)

The LUCE will already incentivize the building of 100 percent affordable housing by nonprofits like Community Corp. This is good, because nonprofits are experts in affordable housing and dedicated to maintaining its affordability. But it's counter-productive to disincentivize private developers from building housing on land that would otherwise be developed with commercial uses by requiring them to build a few units of affordable housing.

Santa Monica has an overriding law passed by the voters that 30 percent of the housing built in the city must be affordable. The City can use that law to deny permits for market-rate only housing if not enough affordable has been built citywide in an established timeframe to equal 30 percent.

The City could also require pre-set conditions for receiving the density bonus; it could, for example, make the bonus available by right to rental housing as opposed to condominiums, because rental housing in Santa Monica is generally workforce housing even if it is not technically "affordable."

By making the good stuff discretionary, the LUCE will mean that we won't get it.

More to come as the process continues (and I read more of the draft).

* * *

If you're reading this column you probably have more than a passing interesting the politics of Santa Monica in particular and local politics in general. In that case, I'd like to invite you to a talk I'm giving at the Santa Monica Main Library about Santa Monica politics this Thursday evening, at 7:00. I'll give a short history of Santa Monica politics, read some passages from my book Urban Worrier: Making Politics Personal, then there will be a discussion, hopefully "lively."
For more details, click here for the Library's calendar.

Frank J. Gruber is the author of Urban Worrier: Making Politics Personal, available at Hennessey + Ingalls and Angel City books in Santa Monica, at City Image Press, and on

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