ITEM 7-A

Council Mtg:  April 28, 1992

TO:       Mayor and City Council

FROM:     City Staff

SUBJECT:  Appeal  of  a  Condition  of  Approval  of  a  Planning
          Commission  approval  of  Conditional Use Permit 91-015
          and Vesting Tentative Tract  Map  50523  to  allow  the
          construction  of  a  two-story,  five-unit  residential
          condominium project at 911 12th Street in the  R2  (NW)
          District.

          Applicant: Richard Chang & Henry Wu
          Appellant: Eileen Hecht, Applicants' representative

INTRODUCTION

This is an appeal of a Planning Commission condition of  approval
requiring   compliance   with   interim   Ordinance   1577  (CSS)
(Proposition R).  The City Council voted  5-2  to  continue  this
appeal  for  60  to 90 days at the hearing of February 4, 1992 to
wait for the ordinance implementing Proposition R to be in place.
Ordinance 1615 (CCS) relating to the inclusionary housing program
was adopted on March 3, 1992 and became effective  on  March  24,
1992.

This  report  recommends  that  the  City  Council  approve   the
applicant's  appeal  to  allow  the  project to be subject to the
provisions of Ordinance 1615 (CCS).

BACKGROUND

CUP  91-015  and  VTTM  50523  were  approved  by  the   Planning
Commission  on  December  4,  1991 to allow the construction of a
two-story, five-unit residential condominium project  (Attachment
B).   The  project  was  subject to the requirements of Ordinance
1577 (CCS) (an  interim  ordinance  implementing  Proposition  R)
requiring  a  miniumum  of  30%  of  the  units to be provided as
inclusionary   rental   units   on   site.     The    applicants'
representative  proposed  at  the  Planning Commission hearing of
December 4,  1991  that  Condition  #43  (the  inclusionary  unit
condition)  be  revised "...to allow the developer to comply with
any  subsequently  adopted...  (Proposition   R)   implementation
ordinance  adopted  prior  to final map approval of the project."
(Attachment E).  The Planning Commission, acting on the advice of
the City Attorney, did not incorporate such a condition.

Ordinance 1615 (CCS) adopted March 3, 1992 and  effective  as  of
March  24,  1992, changes the options for compliance with the 30%
inclusionary unit requirement for all new dwelling  units  to  be
constructed  at  one location by an applicant.  The new ordinance
provides that for any application that has  been  filed  but  not
approved  at  the  time  the  new ordinance became effective, the
applicant may elect to have the provisions of the  new  ordinance
[Section  9422  (b)]  apply  to  his/her  project (Attachment G).
Under Section 9132.4 (b), the conditions placed on the builder by
the  Planning  Commission, on appeal to the City Council, are not
considered effective  unless  and  until  approved  by  the  City
Council.

Required Notification

Pursuant to Municipal Code Section 9131.5,  notice  of  the  City
Council  meeting  was  mailed  to  all owners and residential and
commercial tenants of property located within a 500  foot  radius
of  the  project  at least ten consecutive calendar days prior to
the City Council meeting.  A copy of the notice is  contained  in
Attachment H.

ANALYSIS

The application for CUP 91-015 and VTTM 50523 was filed on  March
15, 1991.  Ordinance 1577 (CCS) was adopted on March 26, 1991 and
was retroactive to projects filed on or after March 6, 1991.  The
ordinance  requires that two (2) of the proposed five total units
be deed restricted as affordable rental units for the project.

The project was continued  at  the  applicant's  request  several
times  from  the initial Planning Commission hearing date of June
23, 1991.  The applicant wanted to wait for a permanent ordinance
implementing  Proposition  R  as  they  felt  that  they  had not
received sufficient notice of the applicability of Ordinance 1577
(CCS)  to their project (Attachment J, see letter dated 6/26/91).
In order to comply with the applicant's wishes, a ninety (90) day
extension  of  the  subdivision processing deadline was sought by
the Planning Commission and granted by the applicant  [Attachment
C,  (see  letter  dated  10/10/91) & D].  The Planning Commission
approved  the  project  on  12/4/91.   The  final  deadline   for
subdivision action was December 26, 1991 (Attachment C).

Ordinance 1615 (CCS),  adopted  on  March  3,  1992,  applies  to
applications  filed  but  not  approved at the time the Ordinance
became effective, which applies to this case.  The applicant  may
elect to have the provisions of Ordinance 1615 (CCS) apply to the
project.  As required by Proposition R, thirty percent  (30%)  of
the  total  number of new dwelling units to be constructed in any
project developed by  an  applicant  at  one  location  shall  be
affordable  to  households of low- or moderate-income (Attachment
G).  Ordinance 1615 provides for various means by which  one  can
comply  with  Proposition  R  including an in-lieu fee option for
qualifying projects.

Appeal Issues

The applicant is appealing the condition of approval relating  to
Ordinance  1577  (CCS)  implementing  Proposition R on an interim
basis (Attachment A).  Planning Commission condition of  approval
#43  requires that one low and one moderate-income rental unit be
provided and maintained on site through subsequent sales  of  the
property  (Attachment  B  &  C).   This  condition  satisfies the
minimum 30% inclusionary rental  unit  requirement  of  Ordinance
1577 (CCS) (Proposition R) (Attachment G).

Under Ordinance 1615 (CCS), the applicant may have the option  to
pay  an in-lieu fee for any required low income rental unit based
on an "inclusionary unit base  price"  as  set  by  City  Council
Resolution  [Section 9246 (c) (see Attachment G)].  The applicant
may elect to comply with the provisions of Ordinance  1615  (CCS)
as  it  has not received final approval at the time the ordinance
became effective, since the appeal of  the  Commissioners  action
was pending.

The  applicant  is  also  requesting  that  the   $1,630.00   CUP
processing  fee  be  waived  if  the  appeal  is  denied  and the
application  be  returned  to   the   Planning   Commission   for
modification   in   order   to  utilize  the  provisions  of  the
Proposition R permanent implementing  ordinance  (Attachment  A).
Since  the  applicant  may elect to comply with the provisions of
Ordinance  1615  (CCS),  if  the  appeal  is  approved,   a   new
application and processing fee would not be required.

CONCLUSION

The  applicant  may  elect  to  comply  with  the  provisions  of
Ordinance  1615  (CCS)  (Proposition  R),  as the project has not
received  final  approval.   Development  requirements   of   the
ordinance  also  provide  an  in-lieu  fee  option for qualifying
projects.  Thus, the  permanent  Proposition  R  ordinance  would
provide   the  applicant/appellant  with  the  options  they  are
requesting.

BUDGET/FINANCIAL IMPACT

The recommendation presented in this report  does  not  have  any
budget or fiscal impact.

RECOMMENDATION

It is respectfully  recommended  that  the  Council  approve  the
appeal  to  allow  the  applicant  to  elect  to  comply with the
provisions of Ordinance 1615 (CCS) and  approve  CUP  91-015  and
VTTM 50523 with the following amended condition #43 as follows:

43.    The developer shall covenant and agree with  the  City  of
       Santa   Monica  to  the  specific  terms,  conditions  and
       restrictions upon the possession, use and enjoyment of the
       subject property, which terms, conditions and restrictions
       shall be recorded with the Los Angeles  County  Recorder's
       Office  as  a  part  of the deed of the property to ensure
       that two affordable units are provided and maintained over
       time  and  through  subsequent  sales of the property.  An
       inclusionary requirement of at least thirty percent of the
       total  number  of units, excluding any density bonus units
       under  State  Government  Code  Section  65915,  shall  be
       permanently affordable to and occupied by low and moderate
       income  households  of  which  at  least   fifty   percent
       (50%)shall be affordable to households not exceeding sixty
       percent of the (HUD) Los  Angeles  County  median  income,
       with  the  balance of the inclusionary units affordable to
       households with incomes not exceeding 100%  of  the  (HUD)
       Los  Angeles  County median income, expending not over 30%
       of monthly income on housing costs, as  specified  by  the
       Housing  Division  of  the  Department  of  Community  and
       Economic  Development.    Such   restrictions   shall   be
       effective for the lifetime of the project.

       This agreement shall be executed  and  recorded  prior  to
       approval  of  the Final Map.  Such agreement shall specify
       1)  responsibilities  of  the  developer  for  making  the
       unit(s)    available    to   eligible   tenants   and   2)
       responsibilities of the City of Santa  Monica  to  prepare
       application   forms   for   potential  tenants,  establish
       critieria for qualifications, and monitor compliance  with
       the provisions of the agreement.

       Owner shall provide the  City  Planning  Division  with  a
       conformed copy of the recorded agreement prior to approval
       of the Final Map.

       This provision is intended  to  satisfy  the  inclusionary
       housing requirements of the Housing Element of the General
       Plan of the City of Santa  Monica.   The  developer  shall
       have the option to satisfy the obligations created by this
       Agreement by demonstrating to  the  Director  of  Planning
       compliance  with  either Ordinance 1577 (CCS) or Ordinance
       1615 (CCS), providing implementation  standards  for  this
       program.

ATTACHMENTS

A.     Appeal form dated 12/20/91.
B.     Statement of Official Action dated 12/4/91.
C.     Staff Memorandum to Planning Commission dated 12/4/91.
D.     Letter  from  Staff  to  Richard  Chang  &  Henry Wu dated
       10/1/91.
E.     Letter  from Eileen Hecht to the Planning Commission dated
       12/4/91.
F.     Interim Ordinance #1577 (CCS) adopted 3/26/91.
G.     Ordinance #1615 (CCS) adopted 3/3/92.
H.     Notice  of  Development  Proposal  for Hearing by the City
       Council on 1/28/92.
I.     Letter from Eileen Hecht to Staff dated 2/6/92.
J.     Letter from Eileen Hecht to Paul Berlant dated 6/26/91.


Prepared by:  D. Kenyon Webster, Planning Manager
              Susan White, Assistant Planner
              Planning Division
              Land Use and Transportation Management Department

NOTE:  Attachments are not available on PEN, but may be  obtained
       from the City Clerk's office.