ITEM 7-B

Council Mtg:  July 9, 1991

TO:       Mayor and City Council

FROM:     City Staff

SUBJECT:  Appeal  of  Two   Planning  Commission  Conditions   of
          Approval (No. 13 and No. 34) for Conditional Use Permit
          91-013  to  Permit  the  Construction  of  a  Five Unit
          Residential  Condominium  Project  at  1142  Eighteenth
          Street.

INTRODUCTION

Conditional Use  Permit 91-013  and Vesting  Tentative Tract  Map
50580  were approved on May 8, 1991 by the Planning Commission to
construct a two-story, five unit residential condominium  project
at  1142 Eighteenth Street.   The applicant has  appealed two CUP
conditions of approval (see  Attachment A):  1) Condition  No. 13
regarding compliance with the Transportation Management Plan, and
2) Inclusionary Unit Condition  No. 34 regarding compliance  with
the  inclusionary housing requirements of  the Housing Element of
the  General  Plan  of  the  City  of  Santa Monica.  This report
recommends  that the City Council, in a two part action; deny the
appeal  of  Condition  No.  34  regarding inclusionary housing as
approved by  the Planning  Commission, and  uphold the  appeal to
delete Condition No.  13 regarding the  Transportation Management
Plan.

BACKGROUND

The Planning  Commission approved  Conditional Use  Permit 91-013
and Vesting Tentative  Tract Map 50580  on May 8,  1991 to permit
the  construction   of  a   two  story,   five  unit  residential
condominium project at 1142 Eighteenth Street (Attachment B).  On
May  7,  1991,  staff  received  a  letter  from  the applicant's
representative  contesting the conditions  (Attachment C).  Staff
evaluated the applicant's request (Attachment D) and the Planning
Commission  maintained  the  inclusionary  housing  condition  as
proposed,  and   made  minor   modifications  to   the  remaining
conditions in question (Attachment E).

Applicant's Appeal

The applicant has appealed  Planning Commission Condition No.  13
and No. 34  (see  Attachment  C).   Staff  is  recommending  that
Condition  No.  13  be  deleted  as  residential projects are not
included  in  the   proposed   fee   structure   of   the   Draft
Transportation Management Plan.

The  applicant's  representative  contends  that  revision of the
City's Housing Element is necessary to include a 30% inclusionary
housing requirement in place of the 15% requirement referenced in
the  existing  Housing  Element  to  comply  with  the  Element's
Inclusionary Housing Program.   The representative also  contends
that the adoption  of Ordinance  No. 1519  failed to  satisfy the
procedures  set  forth  in  state  housing  laws (Government Code
Section 9121.6, et sec.) for  proper  amendment  of  the  Housing
Element.  The applicant's representative also requested that  the
inclusionary  housing condition be amended to comply with Program
12 as constituted in Resolution  No. 7385 and with Ordinance  No.
1448  which the  representative contends  "...properly implements
Program 12 in its present  form.", (see Attachment C).  Based  on
this  contention,  the  applicant's  representative is requesting
that  Condition No.  34 be  amended to  require the  developer to
provide 15% of the five  proposed units, or one affordable  unit,
or to comply with the  in-lieu  fee  schedule  as  set  forth  in
Ordinance No. 1448.

The City Attorney has indicated that both Ordinance No. 1448  and
No.  1519  are   lawful  and   consistent  with   State  planning
regulations.  Unless  amended, both  the Planning  Commission and
Council  are  obligated  to  comply  with  both  ordinances.   In
addition, under provisions of State planning law, charter  cities
such as  Santa Monica  are not  required to  maintain consistency
between the general plan and zoning, and even if such consistency
were  required, the inclusionary requirements are not part of the
Zoning Ordinance.   Furthermore, the  City is  in the  process of
amending  the Housing Element.  These amendments will address the
Program 12 inclusionary housing issue.

BUDGET/FINANCIAL IMPACT

There is a difference in the inclusionary housing fees based upon
the  applicable   ordinance.   Ordinances  1519   and  1448  have
different respective in-lieu fees  of $15.65 and $5.07  per gross
square foot.   Both are adjusted monthly  based upon the Consumer
Price Index  (CPI) fluctuations.   Based upon  8,000 square feet,
the  Ordinance 1519 fees are estimated at $125,200, and Ordinance
1448  fees  are  estimated  at  $40,560.   The difference in fees
between both ordinances is $84,640.

RECOMMENDATION

It is respectfully  recommended that the  City Council: deny  the
appeal of Condition No.  34  regarding  inclusionary  housing  as
approved by  the Planning  Commission, and  uphold the  appeal to
delete Condition  No. 13 regarding  the Transportation Management
Plan.

ATTACHMENTS

A.     Appeal of  Condition Nos.  13 and  34 of  CUP 91-013 dated
       5/21/91.
B.     CUP 91-013/VTTM  50580, 5/8/91  Planning Commission  Staff
       Report
C.     Appeal Letter  from Lawrence  & Harding,  Inc. received on
       5/7/91.
D.     Supplemental  Staff  Report  to  Planning Commission dated
       5/8/91
E.     Draft Statement of Official Action
F.     Applicant's Request for Continuance
G.     Staff Response to Continuance

Prepared by:  D. Kenyon Webster, Planning Manager
              Bruce Ambo, Associate Planner
              Planning Division
              Land Use and Transportation Management Department