Dear Mayor of Manhattan Beach, Planning Director, City Manager, and Assigned Project Planner,

We submit this letter as a formal objection to the proposed multi-family residential development at 201–207 North Sepulveda Boulevard in Manhattan Beach, and as a request that the City conduct a strict, transparent, and comprehensive compliance review of all aspects of the application, including Density Bonus eligibility, requested incentives and waivers, and project impacts.

While we recognize the City’s obligation to process applications pursuant to California’s State Density Bonus Law, that law was not intended to serve as a mechanism for disproportionate private profit at the expense of established residential neighborhoods, nor to eliminate meaningful scrutiny of scale, safety, compatibility, and community impacts.

1. Density Bonus Law Does Not Eliminate Neighborhood Compatibility Requirements

The proposed project represents a dramatic and unprecedented departure from the existing neighborhood in height, massing, and intensity. The scale of the building—particularly its vertical profile—would permanently and irreversibly alter the physical character of the surrounding area, which is currently defined by low-rise, small-scale residential development.

While Density Bonus Law permits limited relief from certain local standards, it does not mandate approval of every incentive or waiver requested, nor does it nullify the City’s obligation to ensure compliance with all applicable objective design, safety, and development standards.

2. Disproportionate Developer Profit Versus Minimal Public Benefit

The project appears structured to maximize developer financial return while providing only the minimum affordable housing component required to trigger Density Bonus eligibility.

This raises substantial concerns that:
   •   The proposal prioritizes profit optimization over neighborhood compatibility;
   •   Requested incentives and waivers may exceed what is legally necessary to make the affordable units financially feasible;
   •   The Density Bonus Law is being leveraged as a financial multiplier, rather than as a balanced housing policy tool.

California law requires that each incentive, concession, or waiver be independently justified and supported by findings demonstrating that it is required to provide the affordable housing units—not merely desirable to enhance project profitability.

3. Mandatory Legal Findings Must Be Rigorously Enforced

Pursuant to Government Code §65915, the City must require the applicant to demonstrate that:
   •   Each requested incentive or waiver is necessary to achieve affordability;
   •   The incentive does not cause a specific adverse impact on public health or safety;
   •   The request represents the minimum deviation required, and is not excessive.

Any incentive or waiver that fails to meet these mandatory findings must be denied, regardless of the project’s by-right status.

4. Objective Standards, Safety, and Infrastructure Remain Enforceable

Density Bonus Law does not exempt the project from compliance with:
   •   Objective design standards
   •   Fire access and emergency response requirements
   •   Traffic safety, visibility, and ingress/egress standards
   •   Stormwater management and drainage capacity
   •   Infrastructure adequacy and service impacts

We respectfully request confirmation that all relevant departments have conducted independent and documented reviews, and that no objective standards have been improperly waived or bypassed.

5. Traffic Congestion and Public Safety Impacts

The proposed increase in residential density at this location will significantly intensify traffic volumes, vehicle turning movements, and on-street parking demand in an area already constrained by arterial traffic along Sepulveda Boulevard.

Increased congestion raises serious concerns regarding:
   •   Pedestrian and cyclist safety
   •   Emergency vehicle access and response times
   •   Intersection visibility and queuing
   •   Spillover parking into adjacent residential streets

We request confirmation that a thorough traffic and access analysis has been conducted and that all identified safety impacts have been fully mitigated in compliance with objective standards.

6. Crime, Cleanliness, and Quality-of-Life Impacts

High-intensity developments that are incompatible with surrounding neighborhoods often place additional strain on public services, including law enforcement, sanitation, and code enforcement.

The proposed project raises legitimate concerns regarding:
   •   Increased calls for police and emergency services due to higher population concentration;
   •   Increased litter, waste management demands, and maintenance pressures;
   •   Reduced neighborhood cleanliness and livability if service capacity does not scale with intensity.

These impacts directly affect public safety, cleanliness, and quality of life, and must be carefully evaluated rather than dismissed as speculative. Density Bonus Law does not require the City to ignore foreseeable service and safety impacts where objective standards and public welfare considerations apply.

7. Adverse Community, Cultural, and Neighborhood Impacts

Beyond physical and infrastructure impacts, the proposed project would cause significant and lasting harm to the established social and cultural fabric of the neighborhood.

This area is defined by a cohesive, stable residential community with long-term residents and a shared neighborhood identity developed over decades. Introducing a project of this scale and intensity would fundamentally alter how residents experience their neighborhood, leading to:
   •   Disruption of long-standing community cohesion;
   •   Widespread neighborhood dissatisfaction and loss of trust;
   •   Permanent alteration of neighborhood character and cultural identity;
   •   Reduced quality of life for existing residents.

While Density Bonus Law addresses housing production, it does not require communities to absorb unnecessary or excessive disruption where objective standards, proportionality, and public welfare considerations still apply.

8. Precedent and Cumulative Impacts

Approval of a project of this magnitude through a ministerial process sets a dangerous precedent, encouraging similarly over-scaled developments that cumulatively undermine neighborhood character, infrastructure capacity, public safety, and public confidence in land-use governance.

The absence of a public hearing does not eliminate the City’s responsibility to evaluate long-term cumulative impacts.

Formal Requests

Accordingly, we respectfully request that the City:
 1. Require full disclosure of all Density Bonus calculations, incentives, and waivers;
 2. Enforce strict compliance with all applicable objective standards;
 3. Deny any incentive or waiver that lacks legally sufficient findings;
 4. Require project revisions to reduce massing, height, traffic, and incompatibility where legally permissible;
 5. Maintain a complete and transparent administrative record of all determinations.

This petition is submitted to ensure accountability, transparency, and responsible governance.