On October 10, 2022, the state’s Housing and Community Development Department certified Culver City’s Housing Element Update (“HEU”). But it's not too late to do something about it!
It is important that you VOTE before or on November 8. We endorsed Dan O'Brien and Denice Renteria, who have made a commitment to involve the community on important decisions such as housing, mobility, homelessness, and more.
Q: Why does this matter?
A: The next council majority will be making future decisions about zoning, regulatory, and housing matters. If Alex Fisch and Freddy Puza are elected they will control the process along with Yasmine-Imani McMorrin.
Q: What does the state want?
A: The state wants more housing units. However, this council majority’s plans provide 223% over what the state calls for. The State’s requirements could be easily met without changing the zoning for residential neighborhoods, and more importantly not eliminating State protections against speculation, renter protections, and owner occupancy requirements.
Q: Which homes are most likely to disappear under the current plan?
A: Older homes, properties that have not been recently developed, and affordable rental properties. Based on economics, no affordable housing units would be built on expensive residential land. It doesn't pencil out for the builder. Say goodbye to the original houses, the quadplexes built for studio workers, the working class homes that sprouted in Culver’s neighborhoods. State Bill 9 (SB9) allows a duplex and up to two ADUs to replace all single family homes in Culver City, but it contains significant renter protections and speculator restrictions which would be wiped out by the Council elimination of R1/single family zoning.
In multi-family neighborhoods the quaint small duplexes, triplexes, and quadplexes will be targeted by real estate speculators and developers who want to turn a quick profit.
Q: Who will make these zoning and regulatory changes?
A: The majority of the members on council.
This is one of the reasons why this election is so important. The state recently passed SB9 which allows duplexes and up to 2 ADU on every single family lot. However the current council wants to allow even more dense housing than the state is asking for. In addition, SB9 has significant protections to discourage speculation and developer including prohibiting redevelopment of a property rented in the last three years, an occupancy requirement for splitting a lot, as well as ecological and historical building considerations.
Zoning and regulatory changes take time. Therefore, these zoning changes and regulatory amendments will be decided by future councils after November 8, 2022.
Q: What you can do?
A: Vote on Nov. 8.
It’s time to vote for people who will reach out to the entire community, people who will make decisions based on facts not ideology, people whose concentration is on what Culver City and its residents need to live safely, active solutions to deal with homelessness and intelligent decisions about housing rights and regulations.
Too much time has been wasted by the council majority on planning to change residential areas when they should have been laser focused on assisting construction where the inclusion of affordable housing actually makes sense.
VOTE FOR DAN O’BRIEN AND DENICE RENTERIA BEFORE NOVEMBER 8
It is important that you VOTE before or on November 8. We endorsed Dan O'Brien and Denice Renteria, who have made a commitment to involve the community on important decisions such as housing, mobility, homelessness, and more.
Q: Why does this matter?
A: The next council majority will be making future decisions about zoning, regulatory, and housing matters. If Alex Fisch and Freddy Puza are elected they will control the process along with Yasmine-Imani McMorrin.
- From the beginning of the HEU drafting the City Council Majority of Alex Fisch, Daniel Lee, and Yasmine-Imani McMorrin have been pushing harder and harder to allow more housing to be built in Culver City. They used an untested and unproven concept called “incremental infill.”
- In single-family neighborhoods under incremental infill they want to go from 8.7 units per acre to 35 units/acre. This allows for four units to replace every single family home.
- In the duplex, triplex, quadplex neighborhoods referred to as R2, R3, or R4 they want to increase the density from the current average of 15-30 dwelling units per acre to 50 du/acre. This would allow 6-8 housing units on every current R2-R4 lot. Homes which are built on expensive land are unlikely to be even moderately affordable.
Q: What does the state want?
A: The state wants more housing units. However, this council majority’s plans provide 223% over what the state calls for. The State’s requirements could be easily met without changing the zoning for residential neighborhoods, and more importantly not eliminating State protections against speculation, renter protections, and owner occupancy requirements.
- The state required that all cities in California had to draft an HEU that would promote and allow development of new housing units in response to the hugely increased demand for housing in the state. These dwelling units include houses, apartments, condos, or Auxiliary Dwelling Units (ADU) . There are a huge number of luxury or expensively priced units being built throughout the state but there is a rapidly dwindling number of affordable housing units.
- Every 8 years a California city has to pass a “housing element” which will be a binding roadmap over the next 8 years. Zoning changes and other regulations are supposed to allow developers, builders, and residents to build even more housing units on every property from residential to commercial.
- The City had to meet its Regional Housing Needs Assessment (RHNA) numbers. Culver City was assigned 3,341 housing units of which there were supposed to be 712 lower income, 560 moderate, and 1,069 above moderately priced units. According to the HEU using current zoning, the state’s allowance of ADU, and other measures Culver City was only short by 165 units.
- This deficiency of 165 lower income units could have been easily met with tweaks allowing residential units to be built in currently commercial areas, the approval of mixed use buildings (shopping below, housing above), and more housing density near transit hubs.
- However our Council Majority: Fisch, Lee, McMorrin wanted to go much further than the state asked for. Under their new “build as many housing units everywhere” philosophy they approved an HEU that provides 223% more housing than required.
- Now that the HCD has approved their latest HEU draft, the city is obligated to come up with zoning changes, ordinance, and regulations that will allow this massive amount of housing growth.
- In order to fulfill their overzealous increased density idea, they will have to amend the zoning code. In single-family neighborhoods the zoning would change from R1 to R4, meaning that this would allow up to four units to be built on any single family lot. In R2-4 neighborhoods, the designation would change to allowing 6 to 8 units on every lot.
Q: Which homes are most likely to disappear under the current plan?
A: Older homes, properties that have not been recently developed, and affordable rental properties. Based on economics, no affordable housing units would be built on expensive residential land. It doesn't pencil out for the builder. Say goodbye to the original houses, the quadplexes built for studio workers, the working class homes that sprouted in Culver’s neighborhoods. State Bill 9 (SB9) allows a duplex and up to two ADUs to replace all single family homes in Culver City, but it contains significant renter protections and speculator restrictions which would be wiped out by the Council elimination of R1/single family zoning.
In multi-family neighborhoods the quaint small duplexes, triplexes, and quadplexes will be targeted by real estate speculators and developers who want to turn a quick profit.
Q: Who will make these zoning and regulatory changes?
A: The majority of the members on council.
This is one of the reasons why this election is so important. The state recently passed SB9 which allows duplexes and up to 2 ADU on every single family lot. However the current council wants to allow even more dense housing than the state is asking for. In addition, SB9 has significant protections to discourage speculation and developer including prohibiting redevelopment of a property rented in the last three years, an occupancy requirement for splitting a lot, as well as ecological and historical building considerations.
Zoning and regulatory changes take time. Therefore, these zoning changes and regulatory amendments will be decided by future councils after November 8, 2022.
Q: What you can do?
A: Vote on Nov. 8.
It’s time to vote for people who will reach out to the entire community, people who will make decisions based on facts not ideology, people whose concentration is on what Culver City and its residents need to live safely, active solutions to deal with homelessness and intelligent decisions about housing rights and regulations.
Too much time has been wasted by the council majority on planning to change residential areas when they should have been laser focused on assisting construction where the inclusion of affordable housing actually makes sense.
VOTE FOR DAN O’BRIEN AND DENICE RENTERIA BEFORE NOVEMBER 8
What Happened: January 30, 2022
The City Council adopted the Housing Element, but your voice STILL matters. If the state certifies the flawed document, the zoning changes that allow 4-plexes on single-family lots will become permanent.
What Happened:
Monday, January 24, the City Council voted 3-2 to adopt the Housing Element (Goran Eriksson and Vice Mayor Albert Vera voted no). Mayor Daniel Lee made his comments and then cut off all debate and discussion before anyone else could weigh in. This was after he suggested continuing the meeting on another day…, but Alex Fisch demanded an immediate vote. Here’s a recap of what happened….
What’s Happening Now:
There’s a 7 day public review period for the Housing Element and Site Inventory. That period ends February 4th. Next, the city submits the Housing Element to the State. The Housing & Community Development (“HCD”) Department has 60 days to review and respond.
What Happens Next:
HCD decides if the Housing Element & Site Inventory are legally compliant.
What You Can Do:
If the Housing Element is certified by HCD, the zoning change that allows four-plexes on single-family lots will become permanent.
Further reading:
What Happened:
Monday, January 24, the City Council voted 3-2 to adopt the Housing Element (Goran Eriksson and Vice Mayor Albert Vera voted no). Mayor Daniel Lee made his comments and then cut off all debate and discussion before anyone else could weigh in. This was after he suggested continuing the meeting on another day…, but Alex Fisch demanded an immediate vote. Here’s a recap of what happened….
What’s Happening Now:
There’s a 7 day public review period for the Housing Element and Site Inventory. That period ends February 4th. Next, the city submits the Housing Element to the State. The Housing & Community Development (“HCD”) Department has 60 days to review and respond.
What Happens Next:
HCD decides if the Housing Element & Site Inventory are legally compliant.
What You Can Do:
- Send this email to HCD telling them that the Housing Element is deeply flawed.
- Send an email to City Council telling them that cutting off and effectively gagging Eriksson and Vera was wrong
- Review the Site Inventory, check with your neighbors and friends. Send letters to HCD telling them if you have no plans to replace your home/business with multi-family housing
If the Housing Element is certified by HCD, the zoning change that allows four-plexes on single-family lots will become permanent.
Further reading:
What the letter says:
To: [email protected], [email protected]
Dear Mr. McDougall and Mr. Danino,
Upzoning is unnecessary and should be taken out of Culver City’s Housing Element (“HE”). The Housing Element makes it clear that converting single-family R1 lots to allowing 4-units per lot R4 (“upzoning”) is not required to meet the state’s requirements. Upzoning should be stripped out of the Housing Element because it represents a solely political and ideological overreach. I urge you to reject Culver City’s Housing Element.
Here’s Why:
The Housing Element will control what zoning the city will have to implement. There is no objectively supportable reason to change single-family zoning other than a politically motivated idea to create more and more density and more and more housing that has no direct connection to affordability.
In conclusion, since the upzoning will not answer the state requirements it should be stripped completely from the Housing Element.
NAME
CONTACT INFORMATION
Dear Mr. McDougall and Mr. Danino,
Upzoning is unnecessary and should be taken out of Culver City’s Housing Element (“HE”). The Housing Element makes it clear that converting single-family R1 lots to allowing 4-units per lot R4 (“upzoning”) is not required to meet the state’s requirements. Upzoning should be stripped out of the Housing Element because it represents a solely political and ideological overreach. I urge you to reject Culver City’s Housing Element.
Here’s Why:
- Using current zoning, builders could supposedly create all but 201 lower-income units (HE, Table 32). This shortfall could be easily met by other means, such as encouraging more mixed-use projects.
- Upzoning is based on a new and unsupported theory called “incremental infill.”
- Based on real calculations, incremental infill will not result in lower-income units being built in single-family areas.
- Upzoning residential properties only leads to the creation of market-rate housing.
- The Housing Element requires zoning changes with a 120% buffer equivalent to 4,040 new housing units in the next 8 years. (HE, Table 32). This shows that the planners are including zoning and regulatory changes which will force future city councils to allow significantly more development than the city needs or possibly can sustain. The State’s Housing & Community Development Department (“HCD”) guidelines say only 15-30% buffer is needed.
- Under current City zoning and regulations, there is more than enough capacity to meet state requirements for low, moderate, and market-rate housing without incremental infill
- Incremental infill is projected to create only 135 housing units, equivalent to 68 duplexes or 45 triplexes or 34 quadplexes. There is no urgent “need” to change the property rights of over 5,000 homeowners for such a low expected yield (HE, Table 32).
- Upzoning will lead to higher property values, further pricing out new home buyers and renters.
- The City Council’s approval of zoning to allow residential in commercial areas will meet the needs of housing for all income levels, and by providing more housing will alleviate the affordable housing crunch in Culver City. There is no objectively justifiable need to rezone residential areas.
- The City has already allowed a wider variety of business uses in mixed-use projects encouraging more development.
- Owners of shopping centers have already expressed their interest in adding housing units which also means that there is no urgent need for upzoning.
The Housing Element will control what zoning the city will have to implement. There is no objectively supportable reason to change single-family zoning other than a politically motivated idea to create more and more density and more and more housing that has no direct connection to affordability.
In conclusion, since the upzoning will not answer the state requirements it should be stripped completely from the Housing Element.
NAME
CONTACT INFORMATION
What's Happening January 24, 2022
Please write an email, or better yet, attend the online meeting and make public comments.
SEND A LETTER TO CITY COUNCIL
Background Talking Points Key Takeaways Summary of the State's Findings
SEND A LETTER TO CITY COUNCIL
Background Talking Points Key Takeaways Summary of the State's Findings
WHAT: CULVER CITY CITY COUNCIL MEETING
|
Send an email to City Council |
Background
Culver City submitted the draft Housing Element to California's Housing and Community Development (HCD). HCD sent a letter back to the city and told them to correct the many errors. Culver City has until February 11 to send it in. The City plans to send it in by January.
The timeline goes like this:
The City must provide the new draft to the public and consider comments before submitting a new draft to HCD.
YOU CAN READ THE HCD FINDINGS HERE
Sign up to attend the meeting here
What Can You Do?
Come and speak at the meeting! If you can't speak, send an email to council ASAP (emails below)
The timeline goes like this:
- December 10, 2021: CC - Discuss updates on the Housing Element and related CEQA findings
- January 6, 2021: PC Adoption Hearing - Recommend the City Council adopt the 2021-2029 Housing Element and related CEQA findings
- January 24, 2022: CC Final Adoption Hearing - Adopt the 2021-2029 Housing Element and related CEQA findings
The City must provide the new draft to the public and consider comments before submitting a new draft to HCD.
YOU CAN READ THE HCD FINDINGS HERE
Sign up to attend the meeting here
What Can You Do?
Come and speak at the meeting! If you can't speak, send an email to council ASAP (emails below)
Talking Points/What to say
To:
[email protected],.[email protected], [email protected], [email protected], [email protected], [email protected], [email protected], , [email protected]
—------------------------------------------------------------------------------------------------------
Regarding the January 24th City Council Meeting, I call on you to reject the 3rd draft of Culver City’s Housing Element and Site Inventory Update, and reject the Housing Element Negative Declaration.
Residential upzoning will not provide affordable housing or improve economic or social equity. The RHNA requirements can be met without incremental infill, especially since only 135 housing units are expected to be built over 8 years. Affordable housing is not possible on lots under half an acre. The consequences of missing the state deadline are discretionary and mitigated if the City Council works with HCD in good faith.
Discarding an environmental impact review is reckless and unsupportable. There is no local data demonstrating that existing single-family homes create more greenhouse gasses and negative environmental impact than building new apartment buildings allowed by the Housing Element.
Specifically:
To:
[email protected],.[email protected], [email protected], [email protected], [email protected], [email protected], [email protected], , [email protected]
—------------------------------------------------------------------------------------------------------
Regarding the January 24th City Council Meeting, I call on you to reject the 3rd draft of Culver City’s Housing Element and Site Inventory Update, and reject the Housing Element Negative Declaration.
Residential upzoning will not provide affordable housing or improve economic or social equity. The RHNA requirements can be met without incremental infill, especially since only 135 housing units are expected to be built over 8 years. Affordable housing is not possible on lots under half an acre. The consequences of missing the state deadline are discretionary and mitigated if the City Council works with HCD in good faith.
Discarding an environmental impact review is reckless and unsupportable. There is no local data demonstrating that existing single-family homes create more greenhouse gasses and negative environmental impact than building new apartment buildings allowed by the Housing Element.
Specifically:
- I do not support adopting a Housing Element based on incremental infill. As has been stated by planning commissioners, consultants and the city’s own staff, incremental infill will not provide low income and affordable housing as required by law.
- I do not support adopting a Housing Element which will lead to a proliferation of market rate replacement housing in residential areas, especially when Culver City has been tasked with providing affordable housing.
- I do not support the replacement of single-family homes with by-right fourplexes. By right takes away discretionary review surrounding individual site issues or concerns.
- I do not support Culver City going further than the state in creating density. The state already allows duplexes and Auxiliary Dwelling Units.
- I support streamlining the ADU process.
- I support an independent study of housing expectations under SB 9, SB 10, and the State’s ADU regulations as an essential first step before any single-family residential zone changes are proposed.
- I support changing the zoning and regulations that will allow residential projects in commercial and transportation related areas.
- I support allowing 100% residential buildings in current commercial and industrial zones.
- I support changing the regulations to allow 100% residential where mixed-use is allowed.
- I support allowing a wider variety of businesses to inhabit mixed-use projects.
- I support community workshops, mailers, flyers, email notices as mandatory to explain the issues and potential solutions to the public.
- I support working with property owners and developers to realistically plan and build projects with affordable housing.
- The City Council has a duty not to adopt the 3rd draft HEU which has not been found compliant with State law and does not meet the actual needs of the city.
Thank you,
Name,
Address
Email Address
Say it in an email:
Our Key Takeaways from the State's Findings:
- The city has to correct its mistakes and send it back to the state.
- The state was very unhappy with the lack of community involvement and outreach by the city and council members. As you know, we have been begging the council to let residents know about their plans to upzone all of Culver City.
- The city MUST show the newest draft to the public and give us enough time to make comments. It must also take the comments seriously and incorporate them where appropriate.
- There were 29 stated errors.
- The State also directed the City to address the public comments it received in any future drafts.
- None of the low-income or moderate housing units will be built in residential areas under incremental infill. Since city staff calculates that only 135 housing units will result in 8 years, and HE assumptions are not proven, there is no basis for changing R1 zoning to meet RHNA goals.
- HE fails to show there is sufficient water and sewer capacity to meet building goals
- If the city cannot demonstrate that enough properties will be redeveloped, (incremental infill) then it has to look elsewhere at larger parcels or prove the likelihood of consolidating parcels.
- The City failed to respond to hundreds of public comments on both drafts of the HE.
- Site inventory errors fail to show the realistic potential for the development of multi-family units
- Culver City's HE Included sites contrary to HCD guidelines.
- Culver City double-counted ADU and incremental infill sites (HCD said that they can't do that).
- Culver City Failed to promote an open public process and insufficient outreach.
- Culver City Failed to establish property owner interest or intent in redevelopment.
- The new Housing Element document must be given proper public review, at least 30 days for comments starting in January 2022.
- Culver City Failed to show that incremental infill will achieve what the city claims especially when it involves low to moderately priced housing.
- Housing Element has too many factual errors and unsupported assumptions.
- It would be negligent and irresponsible for the City Council to approve a housing element unless it is substantially changed and modified.
Our Summary of HCD's Findings
Thank you to Culver City Neighbors United's Jamie Wallace for her hard work on this! HCD's Findings are here if you want to read along
All of these comments and conclusions are based on the HCD determination letter (“HCD Ltr”) saying that the Housing Element (“HE'') and Site Inventory submitted by the City was not in compliance with California state law. It is also based on staff reports prepared for both City Council and Planning Commission meetings, as well as during meeting comments made by City Council members and Planning Commission members.
In part Housing and Community Development (HCD) found the following problems with the draft Housing Element:
Key: blue text designates direct quotes
In part Housing and Community Development (HCD) found the following problems with the draft Housing Element:
Key: blue text designates direct quotes
Assumptions:
In the HE the city repeatedly fails to establish or support its assumptions about:
In the HE the city repeatedly fails to establish or support its assumptions about:
- Future development or redevelopment. The city made assumptions but never offered substantive proof of property owner interest in redeveloping their property. (HCD Ltr. p 2) This was further brought into question in the 200 plus requests to HCD to have property withdrawn from the Site Inventory.
- The number of likely ADU units to be built. Commissioner Sayles doubts the city projection of 400 ADU, saying that a more realistic projection is around 100 units. (Nov. 30, Plan. Commission, Mtg). *Note the HE double counts ADU and potential residential infill housing units, see below
- Realistic Capacity the HE “provided assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions.” (HCD Ltr. p. 2)
- The HE must prove “suitability of non vacant sites'.' The HE must supply support “to demonstrate the potential for additional development.” In Section A3. the HCD says:
- “The analysis must also consider factors including the extent to which existing uses may constitute an impediment to additional residential development and will likely discontinue in the planning period.” This means that the city must prove likelihood of property being recycled to residential or mixed-use.
- “The City’s past experience with converting existing use”
- “An analysis of any existing leases or other contracts that would perpetuate the existing use or prevent development of the site for additional residential development…”
The HE must ascertain the likelihood of continued and existing uses especially in commercial areas where there is no accounting for property improvements, long leases, environmental challenges (gas station) and in the residential area inappropriate site inclusion (Upper Crest and Blair HIlls) - “Development trends, market conditions, and regulatory or other incentives….to encourage additional residential development on these sites.” The city repeatedly made projections that did not coincide with previous construction or construct costs and market trends.
- The HE must consider “newly established leases, new commercial development and several environmental constraints.” (HCD Ltr. p 2-3)
- Relying on “non vacant sites to accommodate more than 50 percent of the RHNA for lower income households. For your information, the HE must demonstrate existing uses are not an impediment to additional residential development." (HCD.) Letter p. 3 This means that current property owner intent to keep or recycle their property is essential and the City did nothing to measure this.
- Ascertaining the likelihood of continued and existing uses especially in commercial areas where there is no accounting for property improvements, long leases, environmental challenges (gas station) and in the residential area inappropriate site inclusion (Upper Crest). This means that the site inventory failed to properly look at the properties it was declaring could be recycled. Those commercial properties included those with long term leases, recent and expensive renovation and improvement, and long-time city businesses like Johnnies or Tito’s.
Public Participation and Notice:
Government Code states: “Local governments shall make a diligent effort to achieve public participation of all economic segments of the community. “
In response to the city’s limited outreach efforts the city “must describe what comments were received and how they were incorporated. Particularly, HCD received many valuable comments related to the HE reviews and encourages the City to re-evaluate these comments and incorporate revisions where appropriate.” (HCD p 8)
The City must increase outreach to lower income and special needs households.
In other words, the City should not just ignore comments, and needs to properly respond to them. There is no indication that the overwhelming public comment against upzoning and demanding an environmental impact review has been incorporated into any draft of the HE or site inventory.
According to Staff, 342 comments and letters were sent to HCD, many describing a lack of transparency in making the draft element available for public comment. (HE p. 8)
Government Code states: “Local governments shall make a diligent effort to achieve public participation of all economic segments of the community. “
In response to the city’s limited outreach efforts the city “must describe what comments were received and how they were incorporated. Particularly, HCD received many valuable comments related to the HE reviews and encourages the City to re-evaluate these comments and incorporate revisions where appropriate.” (HCD p 8)
The City must increase outreach to lower income and special needs households.
In other words, the City should not just ignore comments, and needs to properly respond to them. There is no indication that the overwhelming public comment against upzoning and demanding an environmental impact review has been incorporated into any draft of the HE or site inventory.
According to Staff, 342 comments and letters were sent to HCD, many describing a lack of transparency in making the draft element available for public comment. (HE p. 8)
- “If the city did not provide an opportunity for the public to review and comment on the draft submitted to HCD in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage public participation in the development of the element,”
- “The availability of the document to the public and opportunity for public comment prior to submitting any revisions to HCD is essential to the public process and HCD review.”
- The city MUST "proactively" make “future revisions available to the public, including any commenters, prior to submitting any revision to HCD and diligently consider and address comments, including revising the document where appropriate.”
- HCD’s future review will consider the extent to which the City actually documents how the City solicited, considered, and addressed public comments in the element.
Site Inventory errors:
(Site inventory is used to "prove" that the appropriate number of housing units could realistically and feasibly be built to meet the RHNA income requirements in the next 8 years)
(Site inventory is used to "prove" that the appropriate number of housing units could realistically and feasibly be built to meet the RHNA income requirements in the next 8 years)
- The Housing Element (HE) and site inventory involves incomplete and unsupported analysis which leads to the HE being out of compliance with state law.
- Lower income units for RHNA: HE relies on "non-vacant" or already occupied sites for over 50% of these lower income units:
"For your information, the HE must demonstrate existing uses are not an impediment to additional residential development." (HE Det. Letter p. 3)
HCD PRESUMES that unless the GPU (General Plan Update) planners make a finding "based on substantial evidence" that the current usage (homes, businesses, gas stations, long term leased properties) WILL be turned into additional residential development; that redevelopment is unlikely to happen. (HE Det. Ltr. p 3)
In other words, they have to show proof that most properties are likely to be torn down and replaced with multi-family.
To figure out if properties are likely to be developed, the city should use reliable methods like a survey of a random sample of owners to determine if they are likely to be redeveloped. - HE double counts properties identified for incremental infill AND ADUs. HCD says that the city must adjust its projections of how many properties will be recycled (turned into multi-family) for either the number of expected ADU (City claims 400, Pl. Commissioner Dana Sayles doubts that's a realistic projection, thinks around 100) or units from incremental infill/recycling.
According to the Planning Commission staff report: based on the market (cost of construction, cost of land, desire of property owners) ONLY 135 additional housing units will be built by "incremental infill." (Staff Report to Pl. Commis. 1/24/21 p. 8).
It is clear from statements by Mayor Fisch and Planning Commissioner Sayles that none of these incremental infill housing units will be or are expected to be affordable.
There are approximately 5,200 single family, R1 zoned properties in the city. Does it really make sense to change the property rights of all of these people to create a “chance” to build 100-135 units? When nothing that will be built will be affordable, and where there is plenty of market rate housing available, this makes no sense.
Upzoning has consistently led to increased land values, and where the property is expensive no affordable housing, only market rate housing which there is plenty of already in Culver City and surrounding area. Look at Vancouver where most people are priced out of owning homes or condos. - HCD, GPU, and Planning Commission think between 100 to 135 total housing units might be built with the elimination of R1 out of the 1250 properties they use to prove that incremental infill makes sense. Even the staff report notes that average single family home value of over $1.46 million is an "impediment" to recycling single family zoned properties because it's more profitable to build a larger single family home on both R1 and R2 lots.
- The properties of all people who asked for their property to be removed from the site inventory, must be removed.
- For commercial properties, the new draft analysis must consider existing leases and contracts or improvements that make these properties unlikely to be torn down and recycled into multi-family housing.( HCD p 3)
- Larger single homes are already replacing units on R2 lots.
Staff also notes that the trend in R2 is not to build multi-family but for them to be replaced by large single family homes. Same is true in R1, more likely to have a large home replace a current home than an owner to build an ADU. - The site inventory must include a list of land “suitable and available for residential development.” (including vacant sites of which there are few) that have a “realistic and demonstrated potential for redevelopment to meet the RHNA requirements.” (HCD p 2)
The HE fails to show a feasible and realistic potential for redevelopment. - The HE when identifying sites likely for redevelopment must “also provide support for those assumptions.”
- The HE includes many “small sites” under .5 acre. These sites are not eligible to be counted toward lower income units unless the planners can prove that other small sites were successfully developed in the last 8 years. Or that consolidation of sites is likely to occur. If not proven, cannot be used to meet below market rate units for RHNA. This applies especially to currently single family home zoned sites which are unlikely to be consolidated
- Failure to prove that there are enough large sites (over .5 acre) to accommodate lower income units.
Infrastructure:
The HE “must also demonstrate sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing needed” by the community” (HCD p. 4)
The HE “must also demonstrate sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing needed” by the community” (HCD p. 4)
Design guidelines:
According to HCD, the HE should include some analysis of how to create “compatibility with the character of surrounding development, including a discussion of design guidelines.” (HCD p 5)
The city needs to set up some design guidelines and standards, which the planning commission keeps saying are needed so we don’t end up with large ugly boxes.
Staff Suggestions:
In the Staff reports for both the City Council and Planning Commission, the staff recommends that the city look at the following options: (Planning Commission suggests more options)
According to HCD, the HE should include some analysis of how to create “compatibility with the character of surrounding development, including a discussion of design guidelines.” (HCD p 5)
The city needs to set up some design guidelines and standards, which the planning commission keeps saying are needed so we don’t end up with large ugly boxes.
Staff Suggestions:
In the Staff reports for both the City Council and Planning Commission, the staff recommends that the city look at the following options: (Planning Commission suggests more options)
- “HCD requested that the City consider additional solutions to encourage housing production to meet RHNA if the market demand for converting R1 property to multi-family development through incremental infill is overstated in the HE or if the ADU construction rate does not meet expectations.”
The Staff notes that the median sales price is now $1,460,000 and that this high price makes it unlikely that the property will be recycled to multifamily “‘since it may be more profitable to redevelop the site as a single-family home.”
The Staff notes that in R2 more large single family homes are being built instead of multi-family - “Recalculate the number of properties expected to be recycled in R1 based on market considerations …and adjust the number of potential redevelopment sites…to 135 additional units as a result of infill development.” Based on 1,246 cites, a rate of 109 market feasible units per 1,000 properties.
- That the city should “Examine additional housing sites that could be expected to be developed at existing underperforming shopping centers…” (Staff report 12/7/20) This is based on current financial trends and decline of brick and mortar shopping. Three Planning commissioners supported this, and two others asked for more information on design standards to maximize shopping center development
- Streamline permitting in mixed-use development and submit affordable mixed-use housing developments to ministerial review. (more streamlined and simple)
- “Consider methods to promote the recycling of shopping centers for new mixed-use development through adaptive reuse, outreach programs to shopping center owners to encourage redevelopment and adding zoning incentives through density.” Option 5 was supported by all Planning Commissioners.