Local Hazard Mitigation Plan - Oppose adoption in current form

Below is a letter sent Nov 16, 2025.

To: Mayor Negrete, City Council members, City Manager, and Office of Emergency Management

From:  Board of Directors, North of Montana Association (NOMA) 

RE:     11/18/25 item 4-S – Local Hazard Mitigation Plan - Oppose adoption in current form

We join, Friends of Sunset Park (who we thank for raising this issue), and other Santa Monica Neighborhood Organizations, to urge you not to adopt the Local Hazard Mitigation Plan in its current form.

This is especially relevant and applicable to NOMA, because we are the most northern point of Santa Monica, the closest to the Santa Monica Mountains and the community that was mostly directly impacted by the January 2025 wildfires. Parts of our neighborhood were under mandatory evacuation orders during these recent fires.  

While the draft outlines the hazards facing our community, it contains gaps that leave it out of compliance with state law and weaken its effectiveness as a public safety document.

First, the plan omits the emergency evacuation route capacity analysis that is expressly required under Government Code section 65302.15, enacted by SB 99 and AB 747. These laws direct local governments to identify evacuation routes and evaluate their capacity, safety, and viability.

The city did not complete this analysis for the 2025 Safety Element, and it remains absent from the LHMP. In a city as dense and constrained as Santa Monica, this omission affects legal compliance, public safety, and public confidence. A quantitative study of roadway capacity, congestion, and evacuation times across multiple hazard scenarios is necessary and must be incorporated into both the Safety Element and the LHMP.

Second, after revisions were made to the draft LHMP, the public comment process was restricted to limited pull down menu choices on an online survey. This prevented meaningful participation and did not allow residents to comment on the significant omissions in the document, including the required evacuation analysis.

 As Santa Monica inevitably increases population density it is imperative that the capacity analysis required by law be accomplished forthwith. 

Considering that gridlock conditions already exist during peak hours, we urge you to prohibit approval of density increases in the city until the requisite capacity study conclusively demonstrates that adding new density is not a hazard to lives and public safety of current and future residents. 

The recent experience in the Palisades fire clearly demonstrates that lives are at risk when evacuation capacity is insufficiently planned and provided.

Therefore, we respectfully ask that you direct the Office of Emergency Management to complete the legally mandated evacuation capacity study before the LHMP is approved so that the plan meets state law, and so the city’s eligibility for FEMA funding is not placed at risk.

Board of NOMA