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Ironies of LUCE  

By Frank Gruber

June 07, 2010 --Last week the Santa Monica Planning Commission completed its review of the draft of the new land use and circulation elements (LUCE) of Santa Monica's general plan prepared by the City's planning staff and consultants. From a citywide perspective, the most important changes the commission recommended were certain increases in maximum heights to allow more architectural flexibility and an increase in the percentage of residential development required in part of the city's old industrial district.

When plan goes to the City Council, which will begin its review of the draft Thursday evening, the issues attracting the most attention will also likely be building heights and the commercial/residential mix in the old industrial areas.

It's not surprising that the staff's draft is attracting relatively little controversy. It's a document that is intelligent in many ways, not the least politically. It channels nearly all development in the city into commercial districts, protecting residential neighborhoods, and conditions most development on the provision of "public benefits", which will require continuing discretionary review.

What's ironic about the plan is that although anti-growth activists opposed the LUCE process for most of the six years it took to develop the plan, recently they realized that the staff was delivering what it had promised -- a conservative plan that provided for needed growth, but paid attention to their anxieties about traffic and the character of the city. Now the NIMBYs are calling themselves the plan's proponents and protectors.

They have attacked, for instance, the adjustments the Planning Commission made to height limits, wrongly claiming that they would allow for more development and calling these changes an assault on the plan. (In fact, as passed by the commission, the small increases in height need to be accompanied by proportionate decreases in allowed "floor-to-area-ratio" (F.A.R.). These reductions are not necessary and the City Council should not require them.)

I guess it's also ironic -- to make a personal observation -- that although I have for the most part championed the plan over its six years of public process, I now find myself opposed to significant elements of it -- and not because they are too restrictive of development.

My opposition has to do with the amounts of commercial development allowed or required in the two districts that will be the focus of much of the city's development over the next 20 years. The districts are the "Bergamot Transit Village" surrounding the future Expo stop on Olympic and the "Mixed Use Creative District" between the Bergamot district and the city's eastern border.

Under the draft plan, both of these districts are to be developed so that they are 60 percent commercial. (If you're looking at a draft of the plan, be advised that there are two monumental typographical errors in it -- the figures are reversed, so that the draft says that the districts should be 60 percent residential. But staff has made it clear that the numbers should be 60 percent commercial and 40 percent residential.)

The Planning Commission, to its credit, recommends changing the plan so that it requires at least 50 percent residential development in the Mixed Use Creative District.

I have previously written (often) about why Santa Monica does not need more office development, regardless whether the resulting jobs are called "creative". The City allowed vastly more office development than was expected under the 1984 land use element. While the new plan does not encourage as much commercial development as the 1984 plan did, when the new plan says that it "reduces the amount of regional commercial growth permitted under the 1984 plan" (page 2.1-3), it misses the point.


The problem with the 1984 plan was not the plan, but how it was ignored. The plan predicted 4.5 million square feet of offices, but the City Council almost immediately authorized twice that. Even if no offices are built under the new plan, in 20 years we will still be digesting the extra 4.5 million square feet allowed in the late '80s.

To explain a need for more office development that doesn't exist, planning staff has made a series of arguments that (I am sorry to say) do not make sense.

One is that the 60 percent commercial development figure in the plan for these two districts includes existing industrial development, so that the "new" development will have a higher percentage of residential than the ultimate total. But this argument doesn't take into account the increased amount of development the new plan allows. At the Papermate site, to give an example, the increase in F.A.R. under the new plan, from 1.0 to a potential 3.5, would allow a tripling of the existing square footage of industrial if the new development is allowed to be 60 percent commercial.

The City does not owe property owners in those districts any increase in the right to develop industrial or commercial uses. Any increase in F.A.R. should go to housing.

This argument by staff also ignores the fact that adjacent to these districts are large developments -- such as the Water Garden and Colorado Place -- that are exclusively commercial (and huge).

Staff and the City's consultants have made the argument that more offices will mean more riders on the Expo, as if the purpose of planning development in Santa Monica is to maximize ticket sales on a transit line. They have supplemented this argument with the claim that it would be a good regional solution to build less housing in Santa Monica and more along the Expo line in places like Crenshaw.

But why? Since there is an over-concentration of jobs on the Westside, the better regional solution would be to encourage more job growth along Expo, and build more housing here, where the jobs are. The rest of the region is not clamoring for Santa Monica to attract more jobs.

Staff has argued that the plan allows for considerable residential development along the city's boulevards, but many observers, including myself, are skeptical that under the plan's standards much development (residential or commercial) will occur along the boulevards. I hope that the City Council will liberalize the boulevard standards, but in any case the best place to require housing is on the industrial lands, where larger parcels allow for design flexibility.

It's hardly worth mentioning that based on some made-to-measure economic analysis from the City's consultants, staff has promoted the illusion that the "creative arts" are a crucial industry in Santa Monica that should be nurtured more than any other.

It's difficult to look at all this and not conclude that the reason staff is pushing commercial development is to bolster the City's fiscal condition. Yes, commercial development generates taxes and the financial health of the City is important. Santa Monica, however, already collects more taxes per capita than nearly all other California cities. There also are better means, more consistent with the city's history and resources, to generate tax-producing commercial development. As illustrated by the proposed hotel at 710 Wilshire, hotel development can create significant tax revenues per square foot.

I hope the City Council takes the Planning Commission's action on the commercial/residential ratio issue as a starting point, and further reduces the amount of commercial development permitted in these two districts.

And that's ironic.

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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