On December 12, 2012, the City of Santa Monica planning staff presented the Draft Bergamot Area Specific Plan to the Planning Commission and the Public in its "final milestone" prior to plan adoption in Winter 2013. I attended the presentation and listened carefully; both as a resident and as a Civil Engineer. Based on my observations, and my follow up analysis, I am offering my findings, opinions, and thoughts to the Planning Commission, the Planning Staff, the City Manager, and the City Council for consideration.
As I watched the Plan unveil, many questions came to mind. What does the Plan really mean? What are the real hard numbers associated with the Plan? How many new residents will call this exciting new transformed part of Santa Monica home? How many square feet of new commercial space will there be? How many new employees? How many car and bike parking spaces? How much open space is targeted? Will all of the open spaces consist of hardscape patios on private property through Development Agreements, or would there be specifically designated public and green open spaces as well? What was the real connection for both the new and existing community to the new Metro Light Rail Station? What would be the real impacts of the Plan and how would they be mitigated - sustainably? Will there be new public school sites? Would there be a new fire station, a new police station, a new post office, a new library? Certainly, all of these facilities would be required to properly service this new vibrant and sustainable Bergamot community. How would the No Net New trip goals of the LUCE be implemented? Will the existing and aging water mains and sewer lines accommodate this new bolstering community?
These were some, but not all of my questions. And - the few questions that did get answered, revealed to me, the underlying deficiency of the Plan and the 2010 LUCE (Land Use and Circulation Element) as a whole.
The Answers that Didn't Add Up: One plus One = Two; Or does it?
As a Civil Engineer, I found myself disappointed, but I also found myself asking why? Why was I so disappointed? The Santa Monica Planning Staff is bar-none capable of providing a detailed, thorough, and visionary plan - one worthy of the transformation of the industrial Bergamot Area into a new vibrant mixed-use transit village centered on the backdrop of arts and culture. At this exciting time of transformation, surely the Planning staff is capable of providing a sustainable plan which would meet the needs of the new, as well as the surrounding and existing communities. What was the problem?
The answer to this question was revealed by a little detail which has gone unnoticed to date - A little detail which deserves the most amount of attention and has the largest and most significant impacts to all of the Planning efforts currently underway in our City.
Several times during the hearing, Commissioner Richard McKinnon questioned staff regarding the hard numbers associated with the ultimate buildout of the plan. Commissioner McKinnon asked staff how many new residents were envisioned to ultimately live in the area encompassed by the Plan? Staff's Answer: Approximately 1,300 units or 2,300 people - as predicted by the LUCE. How much new commercial space would be added as a result of the Plan? Staff's Answer: 1.2 million square feet - as predicted by the LUCE.
Staff's answers to these questions were then followed by a very insightful observation by Commissioner McKinnon - an observation that touched and skirted around the minor detail which points to the underlying deficiency of the Bergamot Plan and the LUCE. McKinnon's insight was centered around the proposed Paper Mate Site Project. Through his questioning, McKinnon observed that the proposed single site 766,000 square foot project would add 530,000 sq ft of net new construction to the Bergamot Area. His follow up question and observation was poised as follows: "So we are going to increase, in this 140-acres, 1.2 million square feet or so, and half of that would come in the Hines [Paper Mate] Project if that happens." Staff's Answer: "Yes, at this moment."
Staff's answers just didn't add up. Was this really the case? Are all the Specific Plan efforts going to focus 50% of the development on one site? If so, why do we need a Specific Plan? Why not just one or two Development Agreements and one or two EIRs paid for by the developers. Why is the City spending so much time and money developing a Specific Plan for one or two developments? It just doesn't add up.
So, What's the Problem? The Minor Detail that has Gone Unnoticed:
The Draft Bergamot Area Specific Plan is based on the 2010 LUCE, as is required by state law. That is, any specific plan must be consistent with the city's general plan. As the LUCE includes both the land use and circulation elements of the general plan, the Bergamot Area Specific Plan must be consistent with the LUCE.
The LUCE is a Plan which functions as a set of policies and actions for land use and circulation decisions that result in a blueprint for physical development throughout the community. The LUCE is intended to define a realistic long-term vision for Santa Monica through the year 2030. If you will, a 20-year look into the future. In the planning world, year 2030 is what is called the LUCE "horizon year." This 20-year period is the period of time in which the land use planning decisions are expected to have foreseeable implications under the guidelines of the LUCE. As it is generally viewed that gauging the effects of planning under dynamic conditions is extremely difficult beyond an approximate 20-25 year horizon period; in concept, a revision to the LUCE would occur again in 2030.
What is also very difficult, however extremely critical for a Plan to be effective, is the accurate prediction of growth which will occur over the horizon period. This task becomes even more difficult when the proposed land use modifications of the Plan are substantially different than existing conditions - as is the case with the Bergamot Specific Plan Area. Ultimately, planners are required to make these difficult decisions to predict future growth and the correct guess, as it might as well be, may differ substantially from the ultimate reality - which will play its own course - and be dictated by social and economical driving factors, which may not have been considered.
All of this being said, I will offer here my professional opinion as to what I believe is the underlying deficiency in the LUCE, and by default the Bergamot Area Plan. The overall projected growth predicted by the LUCE for the 2030 "horizon year" was vastly underestimated.
The criteria which was used to determine the city-wide horizon year projected growth under the LUCE was based on a combination of two factors: 1) SCAG (Southern California Association of Governments) regional forecast projections; and 2) California State Department of Finance (DOF) forecasts - which are based on historical trends (See LUCE pages 3.4-5 through 3.4-7). Using this criteria as a base, the LUCE 2030 horizon year city-wide projected growth for housing was estimated as 4,900 dwelling units.
A review of Table 2-1: Summary of Proposed Land Use Changes included in the LUCE EIR (page 2-8, LUCE EIR: Volume I) shows the following 2030 horizon year projections of growth for the entire city:
Residential: +4,955 dwelling units
Office: +448,980 sq. ft.
Retail: +566,803 sq. ft.
In short, the LUCE relied on projections, based on historic trends and SCAG forecasts, to predict the anticipated growth that would occur during the planning period. The problem with using this criteria as a prediction of growth is that it fails to consider that the LUCE - by its own actions - is modifying land use and providing increased development opportunities in a city with a robust development potential. This robust development potential has been witnessed by the large number of permits and proposed Development Agreements that flooded the City and the Planning Department after the adoption of the LUCE in 2010. Simply put, if you open up the flood gates, the water will rush in - and the LUCE projections of growth failed to account for this. Rather the LUCE relied on projected and trend forecasts by SCAG and DOF, neither of which account for any of the land use modifications included in the LUCE.
As part of my study and analysis, I have prepared a comprehensive list of projects which are currently either proposed or in plan check in Santa Monica (See Tables R, R-1, R-2, and R-3 in the appendix). These projects reflect the time period after the adoption of the LUCE up to the end of 2012 (an approximately 2.5 year period of the 20-year horizon event of 2030 or 12.5% of the 20-years).
A total of 4,618 Residential Dwelling Units have already either been proposed or are now under construction in Santa Monica in this brief 2.5 year period. Table R below shows the summary of the residential projects included in the appendix of this report.
Table R: Summary of the Number of Proposed Residential Dwelling Units Added to Santa Monica
After the Adoption of the 2010 LUCE
Refer to Appendix Table for Comprehensive List
Number of Net New Residential Units
Development Agreements - Planning Commission Case List
Residential & Mixed-Use Projects - Planning Commission Case List
Active Permits - Building and Safety
Thus, 93.2%, of the total 20-year city-wide projected LUCE dwelling units have already been proposed or are under construction in just 2.5 years. If the rate of proposed projects were to keep pace with the last 2.5 years, this would mean that a total of 37,868 residential dwelling units would be added at the end of 20-years - not 4,955 as predicted by the LUCE.
An analysis of the Bergamot area, reveals an even more interesting and notable observation. That is, four proposed development agreements (located on lands which occupy less than 15% of the total development area), already account for 1,369 new residential dwelling units (see Table R-B Below). These proposed projects exceeds the 1,300 LUCE predicted 2030 horizon year net new dwelling units prior to finalization or adoption of the Bergamot Area Specific Plan. If you will, it appears as though we are already over the horizon, the vision of the LUCE is complete - and we don't know what's next.
TABLE R-B: Bergamot Area - Proposed Residential Development Projects to Date
Number of Net New Residential Units
"Paper Mate Site"
1681 Twenty-Sixth Street
Paper Mate Site: Project also to include 494,927 sf of office and 46,895 sf of retail space: Total size of Project = 766,094 sf.
2848 - 2912 Colorado Avenue
Roberts Center Project: Project also to include 37,220 sf of office and 22,050 sf of retail. Total Project Size = 304,368 sf
3020, 3030-3060 Nebraska Avenue, 3025 Olympic Boulevard, & 1819, 1820 Berkeley Street
"Paseo Nebraska Project"
Project also to include 80,000 sf of Retail.
"Village Trailer Park"
2930 Colorado Avenue
Village Trailer Park: Total 377 Units: Existing site includes 109 existing units: Total 268 net new residential units and : 24,940 sf of Retail
TOTAL BERGAMOT AREA PROPOSED DEVELOPMENT
Buildout of the Plan and Buildout of the LUCE Must be Considered - But it has Not:
To fully understand the impacts of any Specific or General Plan, and for that Plan to be developed in a responsible, effective, and sustainable manner, that Plan must be assessed and examined not only at the "horizon year" but also at the ultimate or theoretical "buildout" scenario. This theoretical buildout scenario becomes more critical in an area such as the Bergamot Specific Plan Area wherein the entire fabric of the area is being modified by entirely new land use designations. A complete and ultimate buildout Vision of the Bergamot Specific Plan Area must be included and analyzed - for the Plan to have any meaning.
The Oxford Dictionary defines "buildout" as: "the state of maximum development as permitted by a plan or regulations." The State of California General Pan Guidelines published by the Governor's Office of Planning and Research defines "buildout" as: "Development of land to its full potential or theoretical capacity as permitted under current or proposed planning or zoning designations."
In the context of the Bergamot Area Specific Plan, as well as for the LUCE, this necessarily implies an analysis of Tier III development as the "buildout" scenario. An absence of a Tier III development scenario as the ultimate buildout, in any planning efforts, would lead to unintended and unsustainable development across the Specific Plan Area - and the City as a whole. Additionally, because Tier III developments require that community benefits be included as part of the development agreement process, only a Tier III buildout analysis can provide the proper framework for a Plan which will ultimately be used by Decision Makers as an effective tool to assess appropriate community benefits during the discretionary approval process. Only in this case, can a sustainable plan be developed and implemented to achieve a healthy, livable, vibrant community.
Essentially Commissioner McKinnon was asking the proper questions - What does "buildout" of the plan look like in terms of numbers? However, the answers that the Planning Staff provided did not reflect the true "buildout" of the plan - but rather the horizon year projections of the LUCE. Horizon year projections which appear to have already been surpassed by the four current proposed development agreements.
This is the "minor" detail that is missing from the plan - the true deficiency of the Plan - with giant consequences. It appears that the true buildout of the plan has not been considered in the planning process - and it must.
Only the ultimate and accurate "buildout" answers to Commissioner McKinnon's questions could be used by the Planning Commission, as the basic foundation, which would allow for meaningful analysis and input by the Planning Commission to properly shape the Plan. Only the ultimate and accurate "buildout" answers to these questions could lead to the preparation of the ultimate and Final Bergamot Specific Plan.
So, What are the Numbers? Buildout of the Draft Bergamot Area Plan:
One Plus One equals What?
I offer here my independent and professional analysis of what Buildout of the Bergamot Area will truly entail. This analysis is based on the proposed development standards included in the Draft Bergamot Area Plan. The proposed Floor Area Ratios (FARs) for Tier I, Tier II, and Tier III for the different areas encompassed by the plan (i.e. the Transit Village, the Mixed-Use Creative, the Nebraska Spine, and the conservation areas) were applied to each property included within the Plan boundary and the detailed analysis is included in the Appendices of this report. The ultimate Buildout of the Plan is considered as Tier III development for reasons as described earlier.
Table 1 below shows the summary of the Draft Bergamot Area Plan Buildout analysis. This ultimate buildout scenario shows that the Bergamot Area will contain a total of approximately 10.5 million square feet of buildings. Roughly 50% commercial and 50% Residential. This means that the 140-acre Bergamot Specific Plan area will be the new home of approximately 10,750 to 13,100 new Santa Monica residents. The area will contain a total of 5.7 million square feet of total commercial space employing roughly 17,200 total employees - a 100% increase from the 2.9 million square feet of mostly existing industrial buildings currently located within the area.
Table 1: Buildout of the Draft Bergamot Area Specific Plan - Under a TIER III Scenario
Total Construction Building Area (sq. ft.)
Total Number of New Residential Dwelling Units
Total Number of New Santa Monica Residents
Bergamot Transit Village Subtotal
Mixed-Use Creative District Subtotal
Total Specific Plan Area
(1) Buildout proposed commercial building area = 60% of Total building area for Bergamot Transit Village per Draft Specific Plan
(2) Buildout proposed residential building area = 40% of Total Construction for Bergamot Transit Village per Draft Specific Plan
(3) Buildout proposed commercial building area = 50% of Total Construction for Mixed-Use Creative per Draft Specific Plan
(4) Buildout proposed residential building area = 50% of Total Construction for Mixed-Use Creative per Draft Specific Plan
(5) Assumes Average Residential Unit size will be between the range of 690 sf to 839 sf (gross) per unit. This range is based on the two projects that have already been proposed within the specific plan area. The Village Trailer Park (VTP) Project under the approved Tier III Development Agreement sets the lower range value of 839 gross sf per unit. The proposed Tier III Paper Mate Site project sets the higher range value of 690 gross sf per unit.
(VTP Proposed Total Residential Gross Building Area = 316,350 sf and 377 units = 316,350 sf / 377 units = 839 gross sf per unit)
(Paper Mate Site Proposed Residential Gross Building Area = 224,272 sf and 325 units = 224,272 sf / 325 units = 690 gross sf per unit)
(6) Average Household size in Santa Monica in 2010 per 2010 Census Bureau = 1.87 (used for analysis) Note: in 2007 average household size = 1.83 people per unit per the Santa Monica Housing Element page 3-12, Table 3-12. Note: This is combined single family and multi family, however multi family is noted as more overcrowded and overcrowding is considered as above 1.5 people per bedroom. Therefore the 2010 US Census data was taken as more accurate for Multi Family.
(7) Assumes an average of three employees per 1,000 sf of commercial space.
The Bergamot Area Specific Plan Buildout Numbers in Perspective:
According to the 2010 Census Bureau statistics, the 2010 population of Santa Monica was 89,736 people.
The entire City of Santa Monica is comprised of a total of 8.416 square miles or 5,386 acres. The Bergamot Area consists of 140-acres (0.22 square miles) - which represents 2.6% of the overall area of the City.
Buildout of the Bergamot Area will increase the existing residential population of Santa Monica by 12% to 14.5% above existing levels within this 140-acre area of Santa Monica.
The current average density of Santa Monica is 10,663 people per square mile. The proposed density for the Bergamot Area will be somewhere between 49,147 to 59,760 people per square mile - a density of between 4.6 to 5.6 times that of our existing city.
There will be approximately 1,505 to 1,830 new children under the age of 18 living in the Bergamot Area who will need to attend school. Which School?
What's This All Mean? - Potential Impacts to the Bergamot Area and the City:
Based on LUCE projections, the Planning Staff presented findings that the number of new Santa Monica Residents that will live within the area encompassed by the Bergamot Area Plan would be approximately 2,300 people (or 1,300 dwelling units). My professional analysis of the Bergamot Plan shows this number can be between 10,751 and 13,073 people (or between 5,749 to 6,991 dwelling units) at buildout - a difference of approximately 4.7 to 5.7 times the projected LUCE number.
Based on LUCE projections, the Planning Staff presented findings that the amount of new square footage of commercial space in the Bergamot Area will be an additional 1.2 million square feet for a total commercial area of 4.1 million square feet. My professional analysis of the Bergamot Plan shows this number to be an increase of 2.8 million square feet for a total commercial area of 5.7 million square feet - a difference of 2.3 times the projected LUCE number.
The overall impacts to both the Specific Plan Area and the City as a whole would be quite different between these two very differing scenarios. It appears that the Bergamot Area Plan has been analyzed and assessed using the horizon year projections of the LUCE - projections which have already proven to be vastly underestimated. The Bergamot Area analysis should be revised to include the ultimate buildout of the area, a correction course must be made so that the Plan will be meaningful as a tool for decision makers.
Of course the real impacts of the Land Use changes proposed in the Bergamot Area Specific Plan will be far reaching and are outside the scope of this report. The impacts of the buildout scenario should be studied by the Planning Staff and the City's Consultants and the findings presented to the Planning Commission for meaningful input in order to shape the Draft Plan into its final and sustainable format. This being said, however, I will provide limited analysis and thoughts to demonstrate some of these impacts.
Thoughts on Traffic Impacts:
Although, research has found that in the most centrally located, well-designed neighborhoods, residents drive as little as half as much as residents of outlying areas, the buildout projections of 5,749 to 6,991 dwelling units (coupled with a total projected employment base of 17,200 people) will have significantly different impacts than the 1,300 dwelling units predicted by the LUCE. These traffic impacts will ultimately impact the Bergamot Area, the City as a whole, and the region (freeways, major streets, and local and collector streets in and out of West Los Angeles, etc).
A review of the LUCE EIR and the LUCE EIR appendices, shows that the traffic impacts associated with the Land Use modifications for the entire city, and the Bergamot Area, have been studied at the lower impact levels associated with the 2030 horizon year event and that the ultimate buildout impacts were not included. The ultimate buildout impacts should be addressed at this time - as it appears as though we have already reached the horizon year in just 2.5 years.
How can we accomplish the No Net New Trips goal of the LUCE under a more realistic growth scenario in the Bergamot Area? If this question is not asked now, it will not be addressed in the Plan - and it must.
Thoughts and Some Analysis on Parking Counts:
In the presentation to the Planning Commission, Staff estimated that the Draft Bergamot Plan with the 1,300 units and 1.2 million additional square feet of commercial space would entail a total off-street parking requirement in the future of approximately 4,500 spaces. To be fair, Planning staff predicated these estimates with a disclosure that the numbers provided were from memory and would have to be checked in the spreadsheets and could be provided to the Commission at a follow up meeting. However, if one were to conduct a simple exercise, the total projected future spaces that staff expects could be calculated as follows: If we take the projected growth predicted by the Planning Staff (i.e. 1,300 units + additional 1.2 million sf of commercial for a total commercial space of 4.1 million sf) for the Bergamot Area and apply the parking development standards of 1.5 spaces per dwelling unit and 2 spaces per 1,000 sf of commercial, as proposed by the Draft Plan, the projected total future parking requirements which the Plan is assuming (and the Plan is based on) is calculated to be 10,150 total off-street future parking spaces; (i.e. 1,300 units x 1.5 spaces per unit + (4,100,000 sf /1,000 sf) x 2 spaces = 10,150 spaces).
Applying the same calculation to the projected growth based on Tier III Buildout shows a vastly larger parking count of somewhere between approximately 27,600 to 31,000 total off-street future parking spaces required. (i.e. 5,749 units x 1.5 spaces per unit + (5,733,971 sf /1,000 sf) x 2 = 27,594 spaces or 6,991 units x 1.5 spaces per unit + ((5,733,971 sf /1,000 sf) x 2 = 31,077 spaces)
As the Parking Strategy for the Bergamot Area is proposed as shared and unbundled facilities, it is critical that the correct expected buildout projections be included at the Planning Stage in order to shape the Plan correctly. There is a big difference between 10,150 parking spaces, predicted by the Planning Staff, and the Buildout numbers presented in this report of between 27,600 to 31,000 parking spaces.
To put these numbers in perspective, public parking structures 1 through 9 in Downtown Santa Monica have a total capacity of 5,477 cars (this includes the new parking structure 6). Total public parking capacity in Downtown Santa Monica, including the Civic Center and the library, allows for a maximum of 7,968 cars.
Thoughts about Schools:
Based on the buildout scenario presented in this report, new school sites may be warranted to service the new residents located in the Bergamot Area. According to the 2010 Census Bureau statistics, 14% of Santa Monica residents are under 18 years old. This would mean that there would be approximately 1,505 to 1,830 new Santa Monica residents under the age of 18 living in the Bergamot Area. All of these children would require public education facilities, i.e. elementary, middle, and high school which are currently not included in the Draft Bergamot Plan.
The question needs to be addressed as to whether these 1,505 to 1,830 children can be absorbed into the existing school facilities or new schools would be warranted. Additionally, how many car trips will be required to get these new children to schools (if schools are located outside the Bergamot Area). A planned, walking, biking, thriving neighborhood such as the new Bergamot should include new school facilities as warranted. Now is the time to Plan for it. If the Plan actually recognizes the ultimate buildout of the area, then the Plan could identify an area for this (or these) new school facilities. Then and only then could decision makers use this information as part of the Community Benefits negotiations to obtain the physical sites that would be required. Without the recognition of the need for a new public school within the Plan at this stage - there will never be a new public school in Bergamot.
Thoughts and Some Analysis - Water Demand and Distribution and a little on Sewers:
Based on Buildout projections included in the analysis of this report, water Demand for the Bergamot Area will increase by between approximately 630 to 730 million gallons per year (1,925 to 2,250 afy or acre-ft per year) from the existing water usage of the industrial area (See Appendix). These increases assume that the state mandated 20% reduction of urban per capita water use goals are achieved as required by Senate Bill SBx7-7. To put these numbers in perspective, imagine a tank of water the size of a football field and roughly 2,000 feet high: this would be the additional water consumption every year, beyond existing levels, which would result from buildout of the Plan.
Table 4.13-6 of the LUCE EIR Volume I (page 4.13-30) shows that the total anticipated water demand in year 2030 for the City of Santa Monica will be 16,066 afy (which includes the anticipated total additional 354 afy of water as a net result of the LUCE horizon projections). Table 4.13-6 also shows a total available water supply for the City as 16,406 afy for the year 2030. This leaves a total extra water supply of only 340 afy according to Table 4.13-6. And remember, this assumes a net addition of only 4,955 new dwelling units.
But wait: What happens in 2030 if we are closer to buildout of the Bergamot Area than we think? We are already over the 1,300 unit LUCE predicted growth - and the Bergamot Area plan hasn't even been adopted yet. What happens if we need all 1,925 to 2,250 afy of water included in the buildout analysis of the Bergamot Area Plan? According the Table 4.13-6 of the LUCE EIR, we will not be able to meet our water demand.
Assuming, however, that the water shortage is fixed by some other means, what about the distribution of the water to all of the new residents and businesses located in the Bergamot Area? The increased local water demand across the Bergamot Area will most likely entail the replacement of all of the existing aging water mains located within the Specific Plan Area in order to provide the required increases in demands at acceptable water pressures. This would mean that approximately 5 miles of water line would need to be replaced to properly service the Bergamot Area. Additionally, impacts may be farther reaching, as water mains would require replacement beyond the plan area as well.
Similarly, all of the existing 5 miles of sewage lines (and again most probably beyond) will also require replacement in order to accommodate all of the new residents and businesses. The scope of this analysis is outside of this report, however, it should not be outside the scope of analysis of the Specific Plan.
So, Where do We Go from Here?
I believe that the first and most important step in moving forward is to identify what the real and correct projections of growth entail for our City under the blueprint provided by the LUCE. There is no doubt that a Specific or General Plan will fail if the projected growth over its anticipated planning period is vastly underestimated. The plan will not adequately identify the required facilities, means, or methods which can prove as effective tools to be used by decision makers in the implementation of the Plan.
All of the environmental impacts associated with the LUCE were analyzed assuming the projected levels of growth identified in Table 2-1: Summary of Proposed Land Use Changes (page 2-8, LUCE EIR: Volume I). And these impacts were assumed as occurring over the next 20 years. The last 2.5 years however have shown that Santa Monica has absorbed most of this projected growth, with the proposed projects already in the pipeline, in a much shorter time frame. The danger is that the LUCE EIR, will not function as an informative document beyond these already proposed projects.
The Draft Bergamot Area Plan was forced to comply with the LUCE and the LUCE EIR, which is the real explanation of why the Draft Bergamot Area Plan falls short of becoming a true detailed, thorough, sustainable, and visionary plan. The Santa Monica Planning Staff is capable of providing an award-winning plan; however, it appears as though their hands are tied. The reality is that the four development agreements, which have already been proposed, are not only driving the Bergamot Area Plan, but, technically, they are the Bergamot Area Plan. The supporting documents and analysis completed to date, and at this time, do not allow for a vision beyond what we have seen.
The impacts of buildout of the Bergamot Area Plan, the LUCE, and the Downtown Specific Plan for that matter, must be assessed at the ultimate buildout scenario. Although an ultimate buildout scenario would represent the theoretical maximum buildout which would be allowed, it is my opinion that this analysis would provide the most meaningful tools for decision makers in a city such as Santa Monica - a city that so many people want to call home.