NOMA formally opposes Zbur's AB1740, a bill we feel weakens coastal protections

The following letter articulates our concerns:

April 30, 2026

TO:  Assemblymember Rick Chavez Zbur, California State Assembly, 51st District
FROM:  The North of Montana Association Board of Directors

Re: Assembly Bill 1740 — Oppose Unless Amended

Dear Assemblymember Zbur,

The Board of Directors of the North of Montana Association (NOMA) writes to oppose Assembly Bill 1740 in its current form.

NOMA supports the reforms the bill’s sponsors have publicly described as its purpose: streamlining Coastal Commission approvals for bike lanes, outdoor dining, parking adjustments, and temporary events that have long been subject to unnecessary delays. The amendments introduced in April that protect beach parking and limit temporary events near the shoreline are genuine improvements.

However, NOMA strongly opposes the bill’s residential development exemptions. These provisions were never publicly described as among the bill’s purposes, would remove Coastal Commission oversight from the residential coastal zone entirely, and allow developers to build luxury market-rate housing with no deed-restricted affordable units required.

I.  SUBSTANCE: WHAT THE BILL ACTUALLY DOES

As you know, AB 1740 exempts from Coastal Commission review any housing development project in areas zoned for multifamily use and located more than 300 feet from the beach.¹ The bill’s own text defines qualifying projects by reference to Government Code Section 65589.5(h)(2) — a definition that imposes no affordability condition whatsoever.² A 100% luxury market-rate development, for example, qualifies in full, with no deed-restricted affordable units required. The bill also exempts building expansions of up to 50% of an existing footprint and permits changes-of-use or intensifications of use for existing buildings³ — provisions directly applicable to speculative coastal redevelopment that bear no relationship to the bike lanes and outdoor dining its sponsors have described.

In his public testimony and op-ed supporting AB 1740, Councilmember Dan Hall recently described the bill’s purpose as addressing delays to bike lanes, parking adjustments, outdoor dining, and tenant improvements.⁴ Those are the provisions NOMA finds most legitimate. Not addressed in that description — and from every public statement made by the bill’s sponsors — are the residential development exemptions, the footprint expansion allowance, and the changes-of-use provision. The bill’s text and impact extend significantly beyond its publicly stated purpose.

This gap between the bill’s text and its public description was evident at NOMA’s own April 2nd meeting, where you and Mayor Torosis presented AB 1740 to our membership.⁵ Your remarks focused on the same provisions — bike lanes, outdoor dining, parking, and temporary events. None of these residential provisions were discussed at that meeting. When NOMA members raised concerns about the bill’s broader development implications, Mayor Torosis encouraged us to bring those concerns directly to you. We are doing so here.

II.  PROCESS: A SANTA MONICA-ONLY BILL REQUIRES SANTA MONICA PUBLIC INPUT

Because AB 1740 now applies exclusively to the City of Santa Monica,⁶ we believe a formal public process is both appropriate and necessary before it advances. The City’s co-sponsorship was determined administratively, without a public vote, public hearing, or City Council deliberation. At the April 2nd NOMA meeting, a city representative stated that waiting two or three weeks to bring the co-sponsorship to a full Council vote would have slowed the City’s ability to be impactful in the legislative process.⁷

As Councilmember Hall noted publicly, the decision was made under the State Legislative Platform process and communicated to the City Council through staff updates rather than formal deliberation.⁸ Santa Monicans were not asked whether they supported removing Coastal Commission oversight from their residential coastal zone.

A bill of this specificity — one that removes a layer of independent state oversight from a single city’s coastal zone — requires genuine public engagement in that city before it advances. That process has not occurred.

III.  A CONCRETE LOCAL EXAMPLE

A concrete example of how AB 1740 would directly affect our neighborhood involves two former senior-living facilities at 413 and 825 Ocean Avenue — prime blufftop properties within NOMA’s boundaries, already zoned multifamily (R3 and SMR4 respectively)⁹ — currently held under a master lease by a developer who has publicly stated his intention to convert them to luxury residential development.¹⁰ Over the past year, this developer repeatedly placed vulnerable populations in these vacant buildings as interim occupants — including an unpermitted sober-living facility and a proposed prisoner housing program¹¹ — while pursuing entitlements for a far larger redevelopment. Under AB 1740, that redevelopment would qualify for full Coastal Commission exemption with no deed-restricted affordable units required. The Coastal Commission is the most significant independent check on that outcome. The amendments we propose below would address that risk directly.

IV.  REQUESTED AMENDMENTS

NOMA asks that you work with the Legislature to amend AB 1740 to:

• Remove the residential development exemption under Section (a)(7) in its entirety. The Coastal Commission’s oversight of residential development in Santa Monica’s coastal zone serves important public interests that cannot be waived without formal public deliberation, regardless of what affordability provisions may or may not be attached.
• Remove the building footprint expansion exemption and the changes-of-use and intensification-of-use exemptions under Section (a)(6), which enable substantial coastal redevelopment beyond any reasonable definition of permitting streamlining.
• Require a formal public process — including at least one announced public hearing — before Santa Monica or any other city may be designated under this legislation.

Should these amendments be adopted, NOMA would be prepared to support the remaining provisions of AB 1740 as a meaningful step toward coastal permitting reform. 

NOMA remains committed to a Santa Monica coast that is accessible, protected, and equitably enjoyed by all residents. We look forward to working with your office toward a version of this bill that delivers what has been publicly described as its purpose. We welcome that conversation at your earliest convenience.

Respectfully submitted,

The Board of Directors
North of Montana Association (NOMA)
Santa Monica, California

CC: Mayor Caroline Torosis and Members of the Santa Monica City Council

FOOTNOTES

¹ AB 1740, Section 30610.55(a)(7) and (a)(7)(C)(i), as amended April 2026.

² AB 1740, Section 30610.55(a)(7)(B), as amended April 2026, incorporating the definition from paragraph (2) of subdivision (h) of Section 65589.5 of the Government Code. That definition covers any residential development project and imposes no minimum affordability requirement.

³ AB 1740, Section 30610.55(a)(6), as amended April 2026 (exempting "interior or exterior renovations, changes of use, or intensifications of use of existing buildings").

⁴ Councilmember Dan Hall, "AB 1740: Facts, Not Fearmongering," Santa Monica Daily Press, April 28, 2026; Streetsblog California, "Zbur's Legislation to Scale Back Coastal Commission Powers Now Only Applies to Santa Monica," April 24, 2026 (reporting Hall's Assembly Housing Committee testimony on April 22, 2026).

⁵ NOMA Board Meeting, April 2, 2026 (Assemblymember Zbur and Mayor Torosis presented AB 1740; residential development exemptions were not addressed in their presentation; Mayor Torosis directed NOMA’s concerns to Assemblymember Zbur’s office).

⁶ Santa Monica Daily Press, "Santa Monica becomes sole focus of Zbur's revised coastal development bill," April 24, 2026.

⁷ NOMA Board Meeting, April 2, 2026.

⁸ Councilmember Dan Hall, "AB 1740: Facts, Not Fearmongering," Santa Monica Daily Press, April 28, 2026 ("The decision to co-sponsor was made under the City's State Legislative Platform publicly adopted by Council in March 2025").

⁹ City of Santa Monica Zoning Map; Santa Monica Municipal Code, Zoning Designations R3 (Multiple Residential) and SMR4 (High Density Residential), confirmed April 2026; AB 1740, Section 30610.55(a)(7)(A), as amended April 2026.

¹⁰ Los Angeles Times, 'In pricey Santa Monica neighborhood, a battle rages over supportive housing,' January 12, 2026

¹¹ Los Angeles Times, 'In pricey Santa Monica neighborhood, a battle rages over supportive housing,' January 12, 2026; Santa Monica Daily Press, 'Rogue housing facility causes holiday chaos for city staff on Ocean Ave.,' December 4, 2025; Santa Monica Daily Press, ''Prisoner housing' is on the table for Ocean Ave.,' January 15, 2026.