Beverly Hills City Council
July 21, 2026

Cultural Resources - Historical Resources

1. Introduction
CEQA requires analysis of impacts to historical resources and defines historical resources as those listed in or determined to be eligible for listing in the California Register of Historical Resources (California Register), those designated locally, and those that the City elects to treat as historical resources based on substantial evidence that they meet federal, state, or local listing criteria. Historical resources may include buildings, structures, sites, objects, and historic districts. Regulating historical resources falls within the jurisdiction of several levels of government: the framework for the identification of historical resources is established at the federal level, while the documentation and protection of such resources are often undertaken by state and local governments.

The determination of whether a property is a historical resource pursuant to CEQA, whether a historical resource will be impacted by a Project, and whether mitigation measures are adequate to reduce an impact to less than significant, is a question requiring technical expertise from a professional who meets the Secretary of the Interior’s Professional Qualifications Standards for historic architecture, architectural history, and history. a. Purpose of Analysis
The purpose of a CEQA analysis of historical resources is to determine whether a proposed project will affect any historical resources, as defined by CEQA, either directly through demolition, relocation, alteration, etc., or indirectly by causing a substantial material change to the integrity of the resource or its immediate surroundings.

Under CEQA, the evaluation of impacts to historical resources consists of a two-part inquiry: (1) a determination of whether the project site contains or is in the immediate vicinity of a historical resource(s) and, if so, (2) a determination of whether the proposed project will result in a “substantial adverse change” in the significance of the resource(s). A “substantial adverse change” in the significance of a historical resource means an alteration that materially impairs the physical characteristics that convey its significance and justify its eligibility for listing in federal, state, or local registers.

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b. Regulatory Context
There are several plans, policies, and programs regarding historic preservation at the federal, state, and local levels, including those listed below. Refer to the [City’s Regulatory Framework document] for further discussion of each of these documents. • National Historic Preservation Act of 1966, as amended (36 CFR Part 60) • Secretary of the Interior’s Standards for the Treatment of Historic Properties (36 CFR Part 68)
• Native American Graves Protection and Repatriation Act (25 USC Chapter 3001- 3013)
• Archaeological Resources Protection Act (16 USC Chapter 470) • Archaeological Data Preservation Act (54 USC Chapter 3125) • California Environmental Quality Act (PRC Section 21000 et seq) • California Register of Historical Resources (PRC Section 5024.1) • California Health and Safety Code
• California Public Resources Code
• California Historical Building Code (CCR Title 24, Part 8) • California State Assembly Bill 52
• City of Los Angeles General Plan
• City of Los Angeles Cultural Heritage Ordinance (LAAC, Section 22.171) • City of Los Angeles Historic Preservation Overlay Zone Ordinance (LAMC Section

12.20.3)
• City of Los Angeles Redevelopment Plans, as relevant
• City of Los Angeles Specific Plans, as relevant
• City of Los Angeles Community Plan Implementation Overlays (CPIO), as relevant • Permits for Historical and Cultural Buildings (LAMC Section 91.106.4.5) Cultural Resources—Historical Resources
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c. Historical Resource Fundamentals
Historic preservation has four essential components: identification, evaluation, registration, and protection. There are numerous federal, state, and local historic preservation programs, including the California Register and the National Register of Historic Places (National Register), which are described in the [City’s Regulatory Framework document]. While the programs are distinct in their procedures and benefits, they rely on a similar set of principles and best practices. The identification and evaluation of properties as potential historical resources typically occurs through a comprehensive historic resource survey, such as the Los Angeles Historic Resource Survey (SurveyLA), or the environmental review process for compliance with federal and state laws and regulations. The registration process involves a formal nomination and public hearing(s). Registration programs include the National Register, California Register, California Historical Landmarks, California Points of Historical Interest, Los Angeles Historic-Cultural Monuments (HCMs), and Historic Preservation Overlay Zones (HPOZs). Properties listed or designated under these programs are protected in varying degrees. The following are terms often used in the identification, evaluation, registration, and protection of historical resources. • Impact Area - The analysis of project impacts is based upon the Impact Area, which is the geographic area within which a project may directly or indirectly impact the character of historical resources. Impact Area is similar to the term Area of Potential Effect, which is defined in the regulations implementing Section 106 of the National Historic Preservation Act. The Impact Area will vary depending on the type of project proposed. In determining the Impact Area, three factors should be considered: (1) the existing setting of the project site; (2) the scale and nature of the proposed project; and (3) the impacts the project could have on historical resources, if such resources exist. The Impact Area may be limited to the project site if the scale and nature of proposed construction is similar to the existing setting. If that is not the case, the Impact Area may be expanded to include the entire city block on which the project site is located, adjacent parcels, and parcels on opposite block faces. The Impact Area for an individual project may be delineated as a uniform radius from the center of the project site but should rarely exceed a one-block or 1,000-foot distance. The guiding principle on delineating an Impact Area is that it should be commensurate with, and provide for, an appropriate level of effort to take into account a project’s potential to impact historical resources.
• Categories of Historical Resources/Historic District - Historical resources may include buildings, structures, sites, objects, and historic districts. A district is defined as a concentration, linkage or continuity of buildings, structures, sites, and objects united historically or aesthetically by plan or physical development. Within a district, features are evaluated as contributing or non-contributing. Cultural landscapes may be vernacular or deliberately designed; in either case they may be documented as sites or districts, as appropriate. For a full definition of these categories, see the National Register Bulletin: How to Apply the National Register Criteria for Evaluation.

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• Significance - The definition of historic significance used by the State Office of Historic Preservation (SOHP) in its administration of the California Register is based upon the following definition used by the National Park Service (NPS) for the National Register.1 Historic significance is [defined as] the importance of a property to the history, architecture, archaeology, engineering, or culture of a community, state, or the nation. It is achieved in several ways:
– Association with important events, activities, or patterns – Association with important persons
– Distinctive physical characteristics of design and construction – Potential to yield important information
The City of Los Angeles uses a similar definition of historic significance. For the specific criteria for significance used in federal, state, and local landmark and historic district registration programs see the [City’s Regulatory Framework document].
• Context - The significance of a property can be judged only when it is evaluated within its historic context(s). Historic contexts are “those patterns, themes, or trends in history by which a specific...property or site is understood and its meaning... is made clear.”2 The Los Angeles Citywide Historic Context Statement (LACHCS) is used to identify the relevant contexts and eligibility standards for evaluating the potential significance of a property within the City of Los Angeles.

The LACHCS was developed by the Office of Historic Resources (OHR) for SurveyLA and is organized into nine broad contexts that generally cover the period from 1850 to 1980 and are specific to Los Angeles.
• Integrity - In addition to possessing significance within a historic context, to be eligible for listing in the National and California Registers a property must have integrity. Integrity is defined as the ability of a property to convey its significance.3 Within the concept of integrity, the National Register recognizes the following seven aspects or qualities that in various combinations define integrity: feeling, association, workmanship, location, design, setting, and materials. Integrity is based on significance: why, where, and when a property is important. Thus, the significance of a property must be fully established before the integrity is analyzed.

A before and after assessment of integrity is often the basis for determining 1 U.S. Department of the Interior, National Register Bulletin 16A: How to Complete the National Register Nomination Form (Washington, DC: National Park Service, 1997), https://www.nps.gov/subjects/nationalregister/upload/NRB16A-Complete.pdf, accessed June 23, 2024. 2 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, pages 7 and 8.
3 National Register Bulletin #15, 44–45.

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whether the significance of a historical resource will be materially impaired by a project, and thus result in a significant impact.
d. Related Topics Addressed in Other Sections of this
CEQA Guide
• Visual impacts involving historical resources are addressed in Chapter 4.XX, Aesthetics and Views, based on a different set of criteria and thresholds than addressed herein. Aesthetic/view impacts consider the experiences of people who view the landscape, which may include historical resources, while historic impacts consider whether a project will adversely affect the integrity of historical resources. • Effects from vibration on historical resources are addressed in Chapter 4.XX, Noise and Vibration. Vibration from construction activities has the potential to impact buildings and structures that may qualify as historical resources. • Although archaeological and tribal resources may be considered historical resources, impacts to these types of resources are addressed in Chapter 4.XX, Cultural Resources—Archaeological Resources and Chapter 4.XX, Tribal Cultural Resources.

2. Appendix G Thresholds of Significance
The City has adopted the State CEQA Guidelines Appendix G Environmental Checklist questions as thresholds to determine the significance of a project’s impacts. As such, in accordance with the Cultural Resources portion of the State CEQA Guidelines Appendix G, a project would have a significant impact related to historical resources if it would:

Threshold (a): Cause a substantial adverse change in the significance of a historical resource defined in Section 15064.5.

3. Screening Criteria
The following screening criteria may be used to determine whether evaluation of this issue in a CEQA document is necessary. After reviewing the project plans and project description, if the response to the question below is “yes,” further analysis is likely required. If the response is “no”, there would normally be no potential for a significant impact on a historical resource from the proposed project and further analysis is not required.

Historical Resources
• Are there historical resources on the project site or in the immediate vicinity that meet the definition of a historical resource under CEQA in Public Resources Code Cultural Resources—Historical Resources
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(PRC) Section 21084.1 and CEQA Guidelines Section 15064.5(a), that would be adversely impacted through demolition, construction, rehabilitation, relocation, or alteration?
– How to Determine: Review online databases and lists in Section 8, Additional Sources to identify historical resources on the project site or in the immediate vicinity. In most cases, the immediate vicinity should be defined as the City block on which the project site is located. The three categories below provide direction in making this determination based upon the definition of a historical resource in PRC Section 21084.1 or Section 15064.5 of the State CEQA Guidelines: Category 1 historical resources are mandatory; Category 2 historical resources are presumptive; and Category 3 historical resources are discretionary. Each category of historical resources is defined below:
o Category 1—Mandatory historical resources are properties listed in the National Register, listed or determined to be eligible for listing in the California Register by the State Historical Resources Commission, designated State Landmarks from No. 770 onward, and California Points of Historical Interest that have been evaluated by SOHP and have been recommended to the State Historical Resources Commission for inclusion on the California Register. A property listed on the California Register or found eligible by the State Historical Resources Commission does not require evaluation in a technical study; it must be treated as a historical resource.
o Category 2—Presumptive historical resources are properties designated as Historic-Cultural Monuments (HCMs) and areas designated as Historic Preservation Overlay Zones (HPOZs). Only a preponderance of evidence demonstrating that a HCM or HPOZ is not historically, architecturally, or culturally significant will preclude the property or area from being treated as a historical resource. Evidence may include that the property or area no longer meets the criteria for designation as a HCM or HPOZ because the qualities that caused the designation have been destroyed subsequent to the designation. Such would rarely be the case, as alterations to listed historical resources are reviewed by OHR.
 Presumptive historical resources also include properties identified as significant in a historic resource survey meeting the criteria in PRC Section 5024.1 (g). These criteria pertain to the requirements for the nomination of historic resource surveys for listing in the California Register.4 There are no historic resource surveys conducted for Los Angeles that meet these criteria.
4 A resource identified as significant in a historical resource survey may be listed in the California Register if the survey meets all of the following criteria:

1. The survey has been or will be included in the State Historic Resources Inventory; (footnote continued on next page)
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 Properties identified as “historic” in a Specific Plan, or other adopted plan, ordinance, or overlay, could be considered presumptive historical resources. A Historical Resource Assessment Report (see Section 5, Technical Studies to Support the Analysis, below) may be required to determine if the previous evaluation of eligibility is still valid. o Category 3—The City, as the lead agency, has the discretion to treat properties evaluated as appearing eligible for listing in federal, state, and local registers as historical resources for the purposes of CEQA. The determination must be supported by substantial evidence, in light of the whole record.5 Properties identified as eligible by SurveyLA, a survey completed as part of a Redevelopment Plan, or another historic resource survey conducted by a qualified professional and accepted as complete by the Director of Planning, should be considered substantial evidence. The Planner shall consult with OHR to determine if there is substantial evidence based on SurveyLA and their review of the record, including any applicant study, that the property is a discretionary historical resource.

Properties that are not mandatory (Category 1), presumptive (Category 2), or discretionary (Category 3) historical resources may be screened from further consideration.

In determining whether or not to exempt a property from evaluation as a potential historical resource, consultation with OHR may be warranted. Alternatively, the applicant may provide an Initial Historical Resource Evaluation Memorandum (see Section 5, Technical Studies to Support the Analysis, below).

4. Methodology
The following describes the general methodology to be followed in order to provide a detailed analysis when further analysis is required to address the threshold listed above.

Threshold (a)—Historical Resources
The State CEQA Guidelines set the standard for determining the significance of impacts to historical resources as follows:

2. The survey and the survey documentation were prepared in accordance with office procedures and requirements; and

3. The properties were evaluated and determined by the office (SOHP) to have a significance rating of Category 1 to 5 on DPR Form 523.
5 14 CCR Section 15064.5 (a)(3)(4).

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A project with an effect that may cause a substantial adverse change in the significance of ahistorical resource is a project that may have a significant effect on the environment.6
“Substantial adverse change” is defined as follows:

Substantial adverse change in the significance of a historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired.7
A historical resource is “materially impaired” when a project:

Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.8 As a property conveys its significance as a historical resource through its physical characteristics, the test for determining whether or not a proposed project will have a significant impact on an identified historical resource is whether or not the project will alter in an adverse manner the physical characteristics of the historical resource such that it would no longer be eligible for listing in the National Register, California Register, or other landmark programs such as the list of HCMs and HPOZs.

5. Technical Studies to Support the Analysis
Chapter 5.XX, Technical Studies—Historical Resources, provides detailed information about the contents and requirements for technical studies related to historical resources, as well as guidance on when such studies are required or appropriate. These technical studies should be prepared by professionals meeting the Secretary of the Interior’s Professional Qualifications Standards for historic architecture, architectural history, and history. The following summarizes the types of technical studies that may be needed to support a historical resource analysis.
6 14 CCR Section 15064.5 (b).
7 14 CCR Section 15064.5 (b)(1).
8 14 CCR Section 15064.5 (b) (2) (c).

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• Initial Historical Resource Evaluation Memorandum - For properties that are not listed under federal, state, or local landmark or historic district programs or not previously identified as significant in a historic resource survey, an Initial Historical Resource Evaluation Memorandum may be required before concluding a project site and/or its immediate vicinity do not contain any historical resources. A memorandum should confirm whether or not the properties comprising a project site meet the relevant eligibility standards set forth in the applicable context(s) or theme(s) of the LACHCS.
• Historical Resource Assessment Report - In most cases, a Historical Resource Assessment Report (HRAR) will not be required for properties in Categories 1 and

2. For properties in Category 3, a HRAR may be required to determine the character-defining features of the property or to determine if a previous evaluation of eligibility is still valid.
• Historical Resource Technical Report - A Historical Resource Technical Report (HRTR) identifies historical resources on or in the immediate vicinity of a project site, analyzes the potential impact the project may have on the identified historical resources, and recommends mitigation measures, as warranted. A HRTR may include the evaluation of properties as potential historical resources or may summarize the significance, integrity, and character-defining features of listed historical resources.
• Secretary of the Interior’s Standards Compliance Report - A Secretary of the Interior’s Standards Compliance Report (SOIS Report) may be applicable to projects involving alterations to properties listed under federal, state, or local landmark and/or historic district programs (Categories 1 and 2), or identified as significant in a historic resource survey or HRAR (Category 3), if the project is seeking a Class 31 Categorical Exemption.

6. Project Design Features
In general, OHR should be consulted regarding project design features related to project sites with historical resource(s). Such project design features may include the following:
• Historic Structure Report - A Historic Structure Report (HSR) may be an appropriate project design feature for projects involving architecturally significant historical resources, exceptionally significant historical resources, historical resources with multiple components, and complex rehabilitation efforts executed in phases. A HSR provides documentary, graphic, and physical information about a resource’s history and existing condition. Additionally, a HSR identifies characterdefining features and makes recommendations for their treatment and maintenance in compliance with the Secretary of the Interior's Standards. HSRs should be prepared based upon the NPS Preservation Brief #43: The Preparation and Use of Historic Structure Reports prior to the development of architecture and Cultural Resources—Historical Resources
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engineering drawings. HSRs prepared as project design features should be submitted to OHR for review and concurrence.
• Preservation Plan - A Preservation Plan may be an appropriate project design feature for projects involving sites with multiple buildings such as campuses and studios. Such plans may also address aspects of the site such as wayfinding and landscaping that contribute to its historic character as well as development standards and design guidelines for new construction. A Preservation Plan prepared for a Specific Plan may also include a rehabilitation and maintenance schedule for historic buildings on the site. Preservation Plans prepared as project design features should be submitted to OHR for review and concurrence. a. Regulatory Measures to be Implemented as Part of the Project
The City has adopted several ordinances, codified in the Los Angeles Municipal Code (LAMC) and Los Angeles Administrative Code (LAAC), to preserve and protect historical resources. The following ordinances are applicable on a project basis and must be incorporated into the project’s plans or operations:
• LAAC Section 22.171 (Cultural Heritage Ordinance) pertains to historical resources designated as HCMs. Projects involving HCMs must include compliance with the Cultural Heritage Ordinance as a regulatory measure. As stated in LAAC

22.171.14(a), the findings required for the approval of a permit by the Cultural Heritage Commission for the substantial alteration of an HCM are as follows:

1. The substantial alteration, including additional buildings on a site containing multiple buildings with a unified use, complies with the Standards for Rehabilitation approved by the United States Secretary of the Interior;

2. Whether the substantial alteration protects and preserves the historic and architectural qualities and the physical characteristics that make the site, building or structure a designated HCM; and

3. Compliance with the CEQA, PRC Section 21000, et seq.

The Commission’s authority for permit approval is delegated to OHR staff. Thus, compliance with the Standards will be ensured by OHR, who will review the construction documents prior to approving building permits pursuant to the Cultural Heritage Ordinance. Therefore, a project in compliance with subsections 1 and 2 shown above, would not result in an adverse impact on a historical resource. OHR should be consulted regarding additional considerations, such as the qualifications of the project team and construction monitoring.
• LAMC Section 12.20.3 (Historic Preservation Overlay Zones) pertains to properties located within designated HPOZs (locally listed historic districts).

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Projects located within an HPOZ must include compliance with the LAMC as a regulatory measure. This LAMC Section includes criteria for the issuance of Certificates of Appropriateness for Contributing Elements and Certificates of Compatibility for Non-Contributing Elements to protect the historic character and integrity of the HPOZ. All HPOZs have adopted Preservation Plans that elaborate on the regulations of the Ordinance. The Preservation Plans are based on the Secretary of the Interior’s Standards (Standards) and therefore, a project in compliance with the Preservation Plan would not normally result in an adverse impact on a historical resource.
• Community Plan Implementation Overlays, Conservation Districts, Specific Plans, and Redevelopment Plans, in some cases, include protections for identified historical resources and requirements for compliance with the Standards.

Projects located within the boundaries of plan areas with such regulations must include compliance with the plans as a regulatory measure. Therefore, a project in compliance with certain plans would not normally result in an adverse impact on a historical resource. It must be noted, however, that all of the Redevelopment Plans are set to expire at various times, with the last remaining in effect until 2033.

7. Impact Analysis
The purpose of a CEQA analysis of historical resources is to determine whether a proposed project will impact any historical resource, as defined by CEQA, either directly through demolition, relocation, alteration, etc., or indirectly by causing a substantial material change to the integrity of the resource or its immediate surroundings, based on the State CEQA Guidelines Appendix G thresholds of significance, detailed above. In accordance with the State CEQA Guidelines, all phases of a project shall be considered in the analysis of environmental impacts. The analysis can typically be limited to an examination of changes in the existing physical conditions in the project Impact Area. Both direct and indirect impacts, as well as short-term and long-term impacts, must be identified. Refer to State CEQA Guidelines Section 15126.2 for further guidance regarding relevant issues to consider in an impact analysis.

Direct or primary impacts are caused by a project and occur at the same time and place. Regarding historical resources, direct impacts include the demolition of historical resources as well as the relocation or alteration of historical resources that result in a loss of integrity.

Indirect or secondary impacts are caused by a project and occur at a different time and place. Examples of indirect impacts may include visual, auditory, and atmospheric changes to the immediate surroundings of a historical resource from construction. Thus, the historical resource impact analysis may overlap with the aesthetic and noise/vibration analysis (see Section 1.c, Related Topics Addressed in Other Sections of this CEQA Guide, above).

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a. Construction and Operational Impacts
To address the thresholds of significance, the analysis should consider the issues outlined below. The initial items listed below are applicable to all CEQA document types, while a more robust discussion will be needed for an EIR, as indicated below.

Threshold (a): Change in the significance of a historical resource defined in Section 15064.5.
• Demolition—The demolition or destruction of an individual historical resource will always constitute a significant impact. Mitigation measures may be recommended; however, the demolition of a historical resource cannot be mitigated to a less-thansignificant level when the demolition destroys the character defining features or makes the resource no longer eligible for listing (Section 15064.5(b)). Thus, an alternative that avoids and/or lessens the impact must be analyzed. As discussed below, the demolition of a contributing building within a historic district may or may not result in a significant impact.
• Relocation—The relocation of historical resources such as buildings, structures, and objects are generally discouraged but will not automatically result in a significant impact. The potential for a direct impact will depend upon: (1) the reason the historical resource is significant; and (2) the compatibility of the new location.9 If the historical resource is significant for an association with an event or person, the original location and setting will likely be essential factors of integrity depending on the length of the association. Thus, the relocation may result in a significant impact because the historical resource would no longer convey its significance. If the historical resource is significant for its design and construction, the original location and setting will not necessarily be essential factors of integrity.

The historical resource could still convey its significance so long as the new location is compatible with the original character and use. To avoid a significant impact, the relocated historical resource should retain its character-defining features, orientation, and general environment.10 Mitigation measures will likely be required to reduce the impact to a less-than-significant level. • Alteration—The alteration of historical resources such as buildings, structures, objects, and sites will not automatically result in a significant impact. Normally, a project will qualify for a Class 31 Categorical Exemption if the alteration complies with the Standards. The Standards, however, are not the threshold for significant impacts on historical resources. A historical resource will be materially impaired if the project adversely alters the physical characteristics that convey its significance.

Thus, the impact analysis should consider: (1) why the historical resource is significant; (2) the physical characteristics that convey the significance of the 9 14 CCR Section 4852 (d)(1).
10 14 CCR Section 4852 (d)(1).

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historical resource; (3) the current integrity of the historical resource; and (4) whether the proposed alterations would result in a substantial adverse change in the integrity of the historical resource. A historical resource must retain most of the seven aspects of integrity to retain eligibility. A project that destroys a resource’s essential character-defining features will potentially result in a significant impact. If it is determined that the alteration(s) will result in a significant impact, it should be determined if there are feasible mitigation measures available to reduce the impact to a less-than-significant level.
• Construction—New construction related to historical resources refers to freestanding buildings and structures. Additions to historic buildings should be analyzed as alterations. Construction, not involving an historical resource, but in the immediate vicinity would not normally alter the physical characteristics of a historical resource. The only impact to the historical resource would be a potential loss in integrity of setting. Setting refers to the character of the place in which the historical resource is situated within the boundaries of the property as well as the resource’s broader surroundings. The potential for an impact from construction will depend upon: (1) the reason the historical resource is significant; (2) whether setting is an essential factor of integrity of the historical resource; (3) whether the integrity of setting is intact or disrupted from the period of significance; and (4) how and to what degree the setting will be diminished by the visibility of the project from the historical resource. The impact will be less than significant if the historical resource continues to convey its significance by retaining a majority of the seven aspects of integrity.
• Historic Districts—If the historical resource is a historic district, the impact analysis should consider whether the project’s demolition, alteration, relocation, or construction activities will result in a substantial adverse change to the district as a whole. The demolition or alteration of a single non-contributing building will rarely result in a significant impact, while the demolition or alteration of a contributing building may or may not result in a significant impact. The impact analysis should consider how the demolition or alteration of the contributing building will affect the integrity of the district. The analysis should take into account: (1) the current integrity of the district; (2) the concentration and distribution of contributing buildings; (3) the ratio of contributing to non-contributing buildings, and (4) the location of the contributing building proposed for demolition or alteration. A similar approach should be used in the analysis of impacts from the construction of a new building within the boundary of a district. The impact analysis should consider:
(1) the size, scale, and design of the new building; (2) the location of the new building within the district boundary; and (3) the ratio of contributing to noncontributing buildings upon the completion of the project. A district will not remain eligible as an historical resource if it contains so many alterations and intrusions that it is unable to convey its significance. To remain eligible, a district must retain a significant concentration of features. The impact analysis, however, should not be based solely on the ratio of contributing and non-contributing buildings. If the project involves a contributing building that is also individually listed or eligible for listing, and therefore a historical resource in its own right, then the impact analysis must address both the building and the district.

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The result of the impact analysis should be a clear determination as to whether the project would result in a substantial adverse change in the significance of a historical resource(s); in other words, whether the project materially impairs the physical characteristics that convey the resource’s historical significance and justify its eligibility for listing. An explicit conclusion should be made as to whether the construction-related and operational impacts, including direct and indirect impacts, would be less than significant or significant. b. Cumulative Impacts
Refer to Chapter 3.XX, CEQA Document Preparation, for general guidance regarding the evaluation of cumulative impacts, including how to determine the appropriate geographic context for the analysis and how to define the list of related projects that should be considered in the cumulative impact analysis.

In most cases, the geographic context for the cumulative impact analysis of historical resources will be the same as the Impact Area for indirect impacts. If there are no related projects in or adjacent to the Impact Area, there is no potential for cumulative impacts on historical resources and no further analysis is required.

The development of related projects can affect historical resources if such projects adversely alter and/or demolish historical resources that may be interconnected. Cumulative impacts involving historical resources are unusual except in the context of multiple projects within a historic district. If a project is located within the boundary of a historic district, the analysis should identify past, present, and proposed projects within the boundary. The discussion may rely on the analysis and conclusions in the environmental review documents for the related projects, if available. The discussion need not be as detailed as the analysis for the proposed project. A brief summary of the impacts, if any, from related projects is sufficient.
c. Mitigation Measures
Mitigation measures must be fully enforceable through legally binding instruments.

They must be performance based and state what needs to be done, who is responsible for doing it, and when it needs to be done. Mitigation measures should be commensurate with the historic property type, its historical, architectural, or cultural significance, and the action that will impact it. For projects involving impacts to a historical resource, more than one mitigation measure may be required. Appropriate mitigation measures for historical resources are discussed below but are not necessarily exhaustive. Mitigation measures such as documentation, commemoration, and interpretation should include some flexibility for consultation on the content with the lead agency and stakeholders but should not reduce the effectiveness or implementation. The application of mitigation measures will not necessarily reduce the impact to a less-than-significant level. The ultimate adoption of mitigation measures is within the purview of the lead agency.

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• Rehabilitation—For projects involving the relocation or alteration of a historical resource where compliance with the Standards cannot be conclusively determined based upon conceptual or schematic design drawings, mitigation may include retaining a qualified professional to oversee the work. Professionals should meet the Secretary of the Interior’s Professional Qualifications Standards for architecture, historic architecture, or architectural history with at least five years of demonstrated experience in the rehabilitation of historic buildings. The professional should review the construction drawings for compliance with the Standards. If the drawings do not meet the Standards, the professional should make recommendations for bringing them into compliance. The professional should ensure the notes on the drawings include procedures for unforeseen discoveries during construction. The professional should prepare a technical memorandum with findings, recommendations, and conclusions, which shall be submitted to OHR for review and concurrence. Building permits shall not be issued until OHR has concurred the drawings comply with the Standards. Compliance with the Standards would reduce the impact to a less-than-significant level. Such mitigation is not required for historical resources subject to regulations regarding the preservation of HCMs or HPOZs.
• Relocation—For projects involving the demolition of a historical resource, mitigation may include relocation on or off site. Relocation is appropriate mitigation when the historical resource is significant for its design or construction (i.e., when the location and setting are not essential to understanding the importance of the building, structure, or object). Relocation is not appropriate mitigation for certain types of historical resources, such as those in extremely poor condition or large in scale where the end result would require reconstruction rather than rehabilitation.

With conditions for approval pertaining to the suitability of the receiving site and treatment of the historical resource during and after the move, relocation could reduce the impact to a less-than-significant level. The relocation of a contributing building outside the boundary of its associated historic district would not reduce the impact to a less-than-significant level.

Mitigation may also include requiring the project applicant to make a historic building available for relocation to third parties. If this option is pursued, no later than 90 days before the commencement of construction of the project, the applicant should publicize the availability of the building by publishing notice in a newspaper of general circulation and by directly informing potentially interested parties. If relocation of the historical resource cannot be guaranteed when the CEQA document is certified, this measure would not reduce the impact to a lessthan-significant level. • Commemoration—For projects involving the demolition of a historical resource, mitigation may include commemoration. Commemoration is appropriate mitigation when the historical resource is significant for its association with an historic event or person and the location is inherently important to the understanding of the event or person’s life. Commemoration may include on-site signage such as markers and plaques and/or public art such as murals and sculptures. The location of such objects should be thoughtfully integrated into the project and situated for maximum Cultural Resources—Historical Resources
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visibility. OHR should be consulted on the content and design of commemorative objects. Commemoration would not mitigate to a less-than-significant level when the demolition destroys the character defining features or makes the resource project no longer eligible for listing (Section 15064.5(b)). • Interpretation—For projects involving the demolition of a historical resource, mitigation may include interpretation. Interpretation is appropriate mitigation when the historical resource is significant for its association with an historic event, series of events, person, or groups. Interpretation usually refers to off-site displays, printed materials such as historic context statements, multiple property documentation forms, websites, oral histories, lesson plans, videos, etc.

Interpretive materials should be directly related to the significance of the historical resource that will be lost and meaningful to stakeholders. For culturally significant resources, stakeholder engagement should be required. Interpretation would not mitigate to a less-than-significant level when the demolition destroys the character defining features or makes the resource project no longer eligible for listing (Section 15064.5(b)).
• Documentation—For projects involving the adverse alteration or demolition of a historical resource, mitigation may include documentation. Documentation is particularly appropriate mitigation for historical resources that are significant for their design and construction. Documentation usually refers to large format photographs, a written report, and sometimes measured drawings based upon NPS guidelines. The NPS manages three programs, including the Historic American Building Survey (HABS), Historic American Engineering Record (HAER), and Historic American Landscapes Survey (HALS). The documentation program will depend on the historic property type impacted. The level of documentation should be commensurate with the significance of the historical resource and developed in consultation with OHR.

Making one copy of HABS, HAER, or HALS documentation as a donation to NPS is preferable to making multiple copies for local archives. NPS will review the documentation for consistency with their program guidelines, properly store the documentation, and make the documentation available to the public through the Library of Congress. Digital copies of the documentation can be offered to OHR and local archives.

The fieldwork for the documentation must be completed prior to any physical alterations of the historical resource. Proof of the submittal and receipt of the documentation by NPS must be submitted to OHR prior to the issuance of a Certificate of Occupancy.
• Historic Structure Reports—If a Historic Structure Report (HSR) is not a project design feature, it may be mitigation for projects involving the relocation or alteration of a historical resource. See Section 6, Project Design Features for a description of an HSR.

Cultural Resources—Historical Resources
CEQA Guide City of Los Angeles
July 2024

Mitigation measures to minimize impacts to historical resources caused by vibratory construction activities, including the use of vibration monitoring equipment and force adjustable ground compaction devices, are provided in Chapter 4.XX, Noise and Vibration.

8. Additional Resources
The following additional resources may be referenced in identifying historical resources on the project site or in the immediate vicinity:
• BERD—The Built Environment Resources Directory (BERD) is maintained by SOHP and includes properties listed and determined eligible for listing in the National Register, listed and determined eligible for listing in the California Register, California Historical Landmarks, Points of Historical Interest, as well as properties that have been evaluated in historic resource surveys and other planning activities reviewed by SOHP through federal and state environmental compliance laws. To determine if a property is listed under federal or state landmark and historic district programs visit https://ohp.parks.ca.gov/?page_id= 30338. Click on the Los Angeles County file to download a searchable spreadsheet. In using this data, the following should be noted:

The BERD is updated periodically. Therefore, it is recommended that the latest copy be downloaded to ensure the most up-to-date data. As discussed below, it may be necessary to review the National Register Database to determine if a property was listed under a federal program recently.
– Properties in communities within the City that go by another name like Canoga Park, Watts, Pacific Palisades, San Pedro, Hollywood, etc., may be entered under those names rather than Los Angeles.
– Properties may be entered more than once. The most recent entry will be the most relevant in determining if the property is a listed historical resource. – Properties previously surveyed in the 1970s, 1980s, 1990s, and 2000s may have been resurveyed by SurveyLA. If not, they may require reexamination before concluding they are historical resources as defined by CEQA. • National Register Database—To determine if a property is listed under federal landmark and historic district programs visit: https://www.nps.gov/subjects/ nationalregister/database-research.htm. NPS maintains this database and is digitizing National Historic Landmark files, federal determinations of eligibility, and National Register nominations.
• ZIMAS—The Zoning Information and Map Access System (ZIMAS) is maintained by Los Angeles City Planning. A property may be searched by address, street intersection, Assessor Parcel Number, Parcel Identification Number (PIN), or legal description; see the ZIMAS User Guide for basic instructions. Designated historical resources can be identified through ZIMAS under the “Planning and Zoning” tab on Cultural Resources—Historical Resources
CEQA Guide City of Los Angeles
July 2024

the left side of the webpage. Under the Historic Preservation Review tab, a red “yes” or a black “no” will display. By clicking on the “yes,” you may continue in ZIMAS or reroute to HistoricPlacesLA. Historic resource survey findings, including SurveyLA, will not result in a “yes” in ZIMAS. By continuing in ZIMAS, the Historic Preservation window will pop-up. There are three information tabs: Historic Preservation Overlay Zone, Other Historic Designations, and Mills Act. Click on the PDF icon for a report that contains all of the historic designation information pertaining to the parcel. The Historic Preservation Overlay Zone tab will provide the name of the HPOZ and indicate whether the property is a contributing or noncontributing feature. The Other Historic Designations tab will indicate federal, state, and local designations. The information regarding federal and state designations should be the same information found in the BERD, but with more detail regarding the date designations were made and surveys were conducted.

The Mills Act tab will indicate whether the property has a Mills Act Historical Property Contract, although it is not relevant for CEQA purposes. • SurveyLA—SurveyLA was a comprehensive program that identified historical resources throughout the City of Los Angeles (from the time period 1850-1980).

Field surveys conducted from 2010 through 2017 covered the entire City of Los Angeles—over 880,000 legal parcels in an area of almost 500 square miles. The surveys and resource evaluations were completed by consultant teams meeting professional qualification standards in historic preservation under the supervision of OHR. Evaluations were conducted according to standardized criteria for listing under federal, state, and local landmark and historic district programs. This information can be found in SurveyLA reports, available at https://planning.lacity. org/preservation-design/historic-resources-survey. Report data is organized by Community Plan Area (CPA), clicking on the applicable CPA in the interactive map will provide PDF documents of the survey report and consolidated data tables. In using this data, the following should be noted:
– SurveyLA was conducted from the public right-of-way, thus properties not visible to field teams may not have been surveyed.
– Properties previously listed under federal, state, and local landmark and historic district programs were not re-evaluated by SurveyLA.
– Surveys completed by the Community Redevelopment Agency (CRA) after 2005 and concurrent with SurveyLA were not resurveyed through SurveyLA.

See CRA Surveys below for more information.
• HistoricPlacesLA—SurveyLA data is also in HistoricPlacesLA, the City’s online historical resources inventory. HistoricPlacesLA also includes properties and districts listed in the National Register and those designated locally as HCMs and HPOZs. To determine if a property was identified by SurveyLA, visit https:// historicplacesla.lacity.org/. Search the inventory utilizing the Interactive Map, Address Search, and/or Resource Search functions. Open the Resource Report associated with each historic resource to view the resource evaluation and other Cultural Resources—Historical Resources
CEQA Guide City of Los Angeles
July 2024

relevant data recorded by SurveyLA. For guidance on searching HistoricPlacesLA, visit https://historicplacesla.lacity.org/about_search. • CRA Surveys—The following Redevelopment Plan Areas were not resurveyed by SurveyLA:
– Adelante Eastside Redevelopment Area
– Cornfield Arroyo Seco Specific Plan Area
– Hollywood Redevelopment Project Area
– Normandie 5 Redevelopment Area
– Northeast Los Angeles River Revitalization Area
– San Pedro Commercial Corridor Redevelopment Area
– Westlake Recovery Area
– Wilshire Center and Koreatown Recovery Redevelopment Area The historical resource survey data for the majority of the above-listed Redevelopment Plan Areas has been integrated to HistoricPlacesLA, with the exception of the survey data for the following areas: Cornfield Arroyo Seco Specific Plan, Normandie 5 Redevelopment, and Northeast Los Angeles River Revitalization. If a proposed project is located in one of the three Redevelopment Plan Areas whose survey data is not yet in HistoricPlacesLA, the project planner will need to determine if a property has been identified as eligible for designation by searching the applicable survey report. These can be found at https://planning. lacity.org/preservation-design/historic-resources-survey under Other Recent Historic Resource Surveys.
• California Historical Resource Status Code—All surveyed properties have an alphanumeric California Historical Resource Status Code. These status codes are used statewide in the preparation of historical resource surveys and evaluation reports. The first code is a number that indicates the general category of evaluation. The second code is a letter that indicates whether the property is separately eligible (S), eligible as part of a district (D), or both (B). There is sometimes a third code that describes some of the circumstances or conditions of the evaluation. The general evaluation categories are as follows:

1. Listed in the National Register or the California Register

2. Determined eligible for listing in the National Register or the California Register

3. Appears eligible for listing in the National Register or the California Register through survey evaluation
Cultural Resources—Historical Resources
CEQA Guide City of Los Angeles
July 2024

4. Appears eligible for listing in the National Register or the California Register through other evaluation

5. Recognized as historically significant by local government

6. Not eligible for listing or designation as specified

7. Not evaluated or needs re-evaluation
For the purposes of SurveyLA, additional status codes were developed in collaboration with SOHP:
• QQQ—Properties requiring additional research to evaluate or that cannot be evaluated due to limited or no visibility.
• 6LQ—Not eligible. Area determined ineligible for district designation through SurveyLA; neighborhood or area may warrant special consideration for local planning.
• 6LS—Individual property identified through SurveyLA as ineligible for National Register, California Register, or Historic-Cultural Monument designation; may warrant special consideration for local planning.
• 7RQ—Not evaluated. Individual property identified in SurveyLA.— • 7SQ—Not eligible. Individual property assessed for significance in accordance with SurveyLA, but does not meet eligibility standards.

Erin Siegel
Schumacher Drive
City of Beverly Hills Planning Commission
455 North Rexford Drive
Beverly Hills, CA 90210
Re: Opposition to Proposed 232 Tower- Serious Impacts to Privacy, Safety, and Neighborhood Livability
Dear Members of the Planning Commission,
Privacy, Safety, and Property Concerns
I live directly behind the proposed eight-story multi-family building at 232 Tower Drive. While I am unable to attend the hearing in person—I am nine months pregnant— I ask that this letter be included in the official record. I am deeply concerned about the scale, health and safety implications, and incompatibility of this project with our neighborhood. Because my home sits directly behind the property, I will be among the most immediately and permanently affected residents. The proposed 85-foot height would create a looming, intrusive structure towering over my yard and windows. It will destroy the privacy and natural light my family relies on, effectively placing dozens of windows looking straight into our living space and backyard. The design is completely out of proportion to the neighborhood’s existing scale and threatens to erode the very character that makes this area livable. I also have serious concerns about property protection during construction. The current owner already cut down trees and left debris on my property without notice or cleanup—a violation that speaks volumes about how this project may be managed. If this plan were to unfortunately go through - Given that history, I will be taking photographs and video documentation before, during, and after any work to ensure my property remains safe and untouched. I expect the City to require a pre-construction boundary survey, a neighbor protection and monitoring plan, proof of adequate insurance, and a performance bond to guarantee compensation for any property damage or debris that results. Anything less would leave surrounding homeowners exposed.

Prolonged Construction Noise, Dust, and Vibration
This project would introduce years of disruptive, unhealthy, and unavoidable construction impacts — including heavy noise, dust, vibration, and truck traffic. These are not minor inconveniences; they would directly interfere with our ability to live safely in our home. As someone expecting a child within days, I am alarmed at the stress, air quality risks, and long-term disturbance this will cause to my family and others nearby.

Under California law, persistent noise, vibration, and dust that substantially interfere with a homeowner’s use and enjoyment of property can amount to a private nuisance (Renz v. 33rd Dist. Agricultural Assn., 39 Cal.App.4th 61 (1995); Chase v. Wizmann, 64 Cal.App.5th 262 (2021)). The City should not sanction a project that so clearly exposes surrounding residents to these harms. This project would introduce years of disruptive, unhealthy, and unavoidable construction impacts — including heavy noise, dust, vibration, and truck traffic. These are not minor inconveniences; they would directly interfere with our ability to live safely in our home. As someone expecting a child within days, I am alarmed at the stress, air quality risks, and long-term disturbance this will cause to my family and others nearby. Under California law, persistent noise, vibration, and dust that substantially interfere with a homeowner’s use and enjoyment of property can amount to a private nuisance (Renz v. 33rd Dist. Agricultural Assn., 39 Cal.App.4th 61 (1995); Chase v. Wizmann, 64 Cal.App.5th 262 (2021)). The City should not sanction a project that so clearly exposes surrounding residents to these harms.

Furthermore, the City is legally obligated under the California Environmental Quality Act (CEQA) to make findings that the project will not result in a significant adverse impact. We assert that the sheer scale of the construction—an [8-story] structure in this density—will produce emissions that exceed established thresholds set by the South Coast Air Quality Management District (SCAQMD) for particulate matter (PM10 and PM2.5 ) and the City's own standards for noise (dBA). Given the scale of the proposed construction, the density of surrounding homes, and the lack of adequate buffer space, it is evident that no mitigation or “monitoring” could reasonably eliminate these impacts. This is a project that simply does not belong in this location.

Parking and Infrastructure Strain
Parking in this area is already severely limited, especially during baseball and soccer season at nearby la Cienega Park. The proposed development offers too few parking spaces for its size, meaning overflow parking will inevitably spill into the surrounding streets. This will worsen congestion, reduce safety for pedestrians and children, and erode the quality of life for current residents. Moreover, our neighborhood does not have the restaurants, small businesses, or public infrastructure to absorb a large influx of new residents. There are not enough local services to support the increased density this project would bring.

Height, Light, and Neighborhood Character
The proposed height is entirely out of scale with the existing neighborhood and would block natural sunlight into our yard and home. It would diminish property values and disrupt the character of a quiet residential area. We picked this neighborhood because we wanted to live in a quiet family oriented neighborhood. We didn’t live here to have our backyard be balcony apartments! Homebuyers pay a premium for quiet, residential settings and the seclusion of a private backyard, and the constant exposure to dozens of new neighbors on balconies fundamentally changes that dynamic. This permanent privacy invasion erodes the desirability of the property, making it less appealing to prospective buyers who are looking for a secluded, family-oriented environment. The resulting feeling of being perpetually watched directly undermines the residential peace and quiet that define the existing neighborhood's appeal, ultimately exerting downward pressure on the home's market value.

Misuse of Transit-Oriented Development (TOD) Incentives I understand that the developers may be relying on new zoning allowances related to “transit-oriented development,” claiming the property qualifies because it lies within one-half mile of a Metro station. However, this area is not truly walkable to that station due to both distance and street conditions. The intent of the TOD code was to promote responsible, accessible development near actual transit hubs — not to justify high-density projects deep within residential neighborhoods. Applying that exception here would be a misuse of the law and contrary to the spirit of the ordinance.

For all of these reasons — including the clear impacts to privacy, safety, livability, and property rights — I strongly urge the City to deny this project in its current form. It is incompatible with the surrounding neighborhood and presents unresolvable harms to existing families who have built their lives here.

Thank you for your time and for considering the perspective of those of us who would be most directly and severely affected by this development.

Respectfully,
Erin Siegel
Schumacher Drive
1 Edgar Arroyo
From: Jonathan Starr
Sent: Wednesday, October 22, 2025 10:35 PM
To: Edgar Arroyo
Subject: Re: 232 Tower Drive: Upcoming Meeting on 10/23/2025 - Report Available
CAUTION: EXTERNAL SENDER

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34 stories at the top of So. Tower
8 stories in the middle of So. Tower
5 stories in the middle of So. Tower
Have you ever walked So. Tower ?
It's a lot of additional people for a street
you can cover up and down in 12 minutes.

A lot of people for sure.
jonathan starr on So. Tower Drive.

On Fri, Oct 17, 2025 at 2:29 PM Edgar Arroyo <[email protected]> wrote:

You are receiving this message because you have previously expressed interest in the proposed project at 232 Tower Drive.

Good Morning:

The Planning Commission is scheduled to have a hearing on the proposed new multi-family residential project at 232 Tower Drive at their upcoming meeting on Thursday, October 23, 2025 at 1:30 P.M.

A copy of the Planning Commission agenda and report for this project are available online using the following links:

Agenda:
2 https://beverlyhills.granicus.com/GeneratedAgendaViewer.php?event_id=925c9511-54a0-4484-96e7- 1a0b27ff743b

Staff Report:

Part 1: https://beverlyhills.granicus.com/MetaViewer.php?view_id=&event_id=7465&meta_id=656322 Part 2: https://beverlyhills.granicus.com/MetaViewer.php?view_id=&event_id=7465&meta_id=656324 Part 3: https://beverlyhills.granicus.com/MetaViewer.php?view_id=&event_id=7465&meta_id=656326

Plans: https://beverlyhills.granicus.com/MetaViewer.php?view_id=&event_id=7465&meta_id=656328

Additional meeting information is included on the meeting agenda, including information on how to participate. Feel free to forward this information to any member of the public who may be interested.

If you have any questions regarding this project, feel free to contact me.

Regards,

Edgar Arroyo
Senior Planner
Community Development Department
City of Beverly Hills
455 North Rexford Drive
Beverly Hills, CA 90210
Office: (310) 285-1138 | Fax: (310) 273-0972
E-mail: [email protected]
3 NOTE: Planning applications and project resubmittals are currently accepted via email. However, planning applications and project resubmittals are not considered received by the City until such submittal is acknowledged by a Planning Division staff member. If you have questions regarding the status of your planning application, please call 310-285-1000 and ask to speak to a planner. If you have questions about the status of your project resubmittal, please reach out to your assigned planner directly.

The City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public Records Act, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act.

October 23, 2025
Dear City Clerk and Honorable Members of the Beverly Hills City Council:

RE: Opposition to Builder's Remedy Application for 232 Tower Drive 85-Foot High-Rise Development – October 23, 2025, 1:30 PM
My husband, Joel Amsterdam, and I live at Schumacher Drive in Los Angeles. Our backyard bounds the back of the Westernmost lots on Tower Drive in Beverly Hills.

We are vehemently opposed to the proposed development at 232 Tower Drive.

This development is not only out of character for our directly adjacent neighborhood, but out of character for the already dense Beverly Hills neighborhood where it is being proposed.

Tower Drive is not a transit corridor. It has no light on either end, and it does not have enough spaces to accommodate the residents currently, let alone a building that is WILDLY underparked in the current proposal.

At the very least, comprehensive environmental and traffic/parking studies must be carried out in order to better understand the impact on the surrounding neighborhood.

Please see the attached letter from Ken Dusick for further, more specific opposition.

Thank you,
Joel and Amy Amsterdam
Amy & Joel Amsterdam
Schumacher Drive
1 Edgar Arroyo
From: Ann Rubin
Sent: Thursday, October 23, 2025 2:09 AM
To: CommentPC
Cc: Edgar Arroyo
Subject: 10/23/25 -- Item #3 -- 232 Tower Drive proposal project -- public comment from Ann Rubin
Attachments: 20240111_Beverly Hills 2nd Comment Letter_1050 La Cienega Blvd.pdf [Some people who received this message don't often get email from . Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
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Dear Beverly Hills Planning Commission,
I am a resident on nearby Commodore Sloat Drive, in Carthay Circle Historic Preservation Zone, also on the National Register of Historic Places, around the corner from the proposed development at 232 Tower in Beverly Hills and contemporaneous to our LA side of the neighborhood.

I am opposed to the development of this 8-story, 101-foot hight apartment building on narrow Tower that is incompatible with the block and the neighborhood.

Firstly, I thought the proposal was for 85 feet, so it's a shock to now read the staff report that says 101-feet high on a 10,000 or so square foot lot in the middle of the block, surrounded by 2-story multi-tenants and backing up to one-story residential in Carthay Circle, with NO transition zone and NO alley.

Such buildings belong on Wilshire Blvd. and commercial corridors. Builders Remedy or not, this is unconscionable on the part of the developer and such a tragedy for Beverly Hills that excels on excellent planning and respect for the community. The massing is out of scale, and the design is out of context.

These studio and one-bedroom apartments are minuscule, akin to dorm rooms. Families can't live in them. You are replacing high-quality, livable apartments with shoeboxes. At least make them into deeded condos to give people a chance to build wealth. Otherwise, no one will live in these units for long. That of course makes one wonder about the risk of sub-rentals and short-term rentals, on the books or off.

Should this high-rise go forward, the land value on the whole block, and Gale and Hamilton, will increase, as more period apartments are demolished for taller and denser -- and more expensive! (yet smaller) -- apartments. This is the dilemma -- how to have mass transit without gentrification and displacement, even in Beverly Hills! This won't help with our crisis for truly affordable housing.

At the more detailed level, I ask you to deny both the amenity deck on the roof and the wall of balconies on the south side. No BBQs and no amplified sound coming from the dorm rooms. These features are certainly not mandatory or by-right, according to Builders Remedy. The externalities should not be inflicted on the neighboring residents in Beverly Hills or Los Angeles. Utilities should all be under-grounded so as not conflict with large trees that are certainly needed in abundance around this building, although there does not appear to be the necessary space or soil volume for trees to grow.
2 Can't Beverly Hills somehow protect this pocket of mid-density, well-built and designed, multi-tenant apartments -- most from the 1920s and 30s and mid-century -- that constitute a real neighborhood and stable, livable community?
Attached, please find the 1/9/24 letter from the City of Beverly Hills responding to the proposed development at 1050 La Cienega in Los Angeles. Much of the same applies in this case.

Thank you for your consideration,
Ann Rubin
Commodore Sloat
Carthay Circle Historic Preservation Overly Zone
Carthay Neighborhoods National Historic District
LA


1 Edgar Arroyo
From: John D Luca
Sent: Thursday, October 23, 2025 6:53 AM
To: CommentPC
Cc: Karen Myron
Subject: 232 Tower — Item 3

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Hi - Please read this comment at the planning commission meeting today on 10/23/25:
——————————
I live and own an apartment building on S Hamilton Dr, but did not receive notification of this meeting, nor did neighbors. With previous projects such as 227 Tower, we received letters. It’s odd that LA residents in Carthay would be notified within the 500’ radius, but not BH residents two blocks over.

Hamilton Drive is the most ticketed residential street in the City with the Saban Theatre, La Cienega Park and the offices/consulates at 8484 Wilshire. Tower Drive is always full with parked vehicles. 13 garage spaces for 55 units (80-100 individuals) is not viable.

With AB 2097 parking is not required, however the planning commission is not obligated to approve the project if there is a safety concern for the public.

There is safety concern as the infill is too dense on a 50 foot wide lot. There is no ingress / egress area for emergency vehicles, there is no drop off area for the disabled or elderly, there is no delivery vehicle loading zone or Uber/rideshare area, forcing all these vehicles to double park on the street blocking traffic. Tower is narrow with parked vehicles on both east/west curbs. 100 residents will total 50+ deliveries per day. If an Amazon/UPS truck is double parked and the employee goes to a high floor, that vehicle will block for several minutes. On this narrow street, an ambulance/Fire Truck will not be able to fit. For this public safety point alone, the application is not realistic.

The Council is scheduled to vote to ban Builder’s Remedy residents from obtaining parking permits. This should have been passed prior to all planning meetings so it could carry more weight if contested by future residents.

All 13 parking spots should be allocated exclusively to affordable/low income tenants. These individuals should not be forced to take public transportation if they already own a car needed for their job.

Lastly, this lot abuts the Carthay District HPOZ, nationally registered historic district. Last year the eastern side of Tower was omitted from the BH multi-family historic survey of the City. I inquired further, but was not provided clarity, simply that it’s “off-limits” from being analyzed. Why? Who decided?
An independent historical consultant should be brought to properly assess.

Thank You
John Luca
From: Anita Prasad
To: CommentPC
Subject: Development Project at 232 S Tower Drive
Date: Thursday, October 23, 2025 11:31:00 AM
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Hi,
I am writing to notify you that I am against the development of a 7 story building at 232 S Tower Drive.

Please feel free to contact me if you need additional information.

Thank you,
Anita Prasad
Tower Drive
Oct 23, 2025
City of Beverly Hills
455 North Rexford Drive, Room 280A
Beverly Hills, California 90210
Re: Proposed Housing Development Project at 232 Tower Drive To: [email protected]
CC: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Dear Beverly Hills Planning Commission,
The California Housing Defense Fund (“CalHDF”) writes regarding public hearing item number 3 on the agenda for the October 23, 2025 Planning Commission meeting: permit approvals for a proposed 55-unit housing development project at 232 Tower Drive, which includes 11 low-income units. We urge the Planning Commission to approve the project, as is required by law.

The City’s Discretion to Deny the Project is Limited by the HAA The City correctly identifies the standards governing the approval or disapproval of the project as those contained in Government Code section 65589.5, subdivisions (d) and (j). As the staff report notes, there is no evidence in the record to support a denial of the project under those provisions of those sections of law.

The staff report also includes a discussion of the findings purportedly required by local code for the approval of a Development Plan Review. These findings are inapplicable to the project. As a builder’s remedy project, the development is exempt from local zoning and general plan standards. Required findings for local zoning permits are standards, therefore these findings are inapplicable to the development at 232 Tower Drive.

Even if we set aside the fact that the development is a builder’s remedy project, the HAA still constrains the City’s discretion to fail to make the local findings. The required findings for the Development Plan Review are largely subjective, involving consistency with subjective general plan standards, the general welfare of the City, or involving subjective judgement of 2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
City officials. The HAA prohibits the City from denying any housing development project on the basis of such subjective findings. A failure to make any of the findings or grant any of the permits for this development would violate the HAA if not accompanied by findings under subdivision (d)(1)-(5).

Objections to Proposed Conditions of Approval
CalHDF also objects to some of the proposed conditions of approval for the project. The City’s authority to condition the approval of the 232 Tower Drive development is limited in several ways. First, the City cannot impose conditions that would render the project infeasible. (HAA, subd. (d).) Second, as a builder’s remedy project, 232 Tower Drive is not subject to the City’s zoning and general plan standards. The City is not only prohibited from denying the development based on these standards, but it also cannot condition approval on compliance with any zoning or general plan standards. Finally, any exactions imposed on the development through conditions of approval must have a nexus to impacts created by the development, and must be roughly proportional to these impacts, conditions cannot impose costs on the development that are unrelated to the impacted created. (Gov. Code §§ 66000 – 66025; Sheetz v. County of El Dorado, (2025) 113 Cal. App. 5th 113.) First, many of the proposed conditions would have the effect of imposing general plan or local code standards via conditions of approval:
● Limitation on common outdoor living space hours (Condition No. 13) ● Amplified sound prohibition in common outdoor living spaces areas, including balconies and the rooftop of the building. (Condition No. 14) ● Construction of a 6’-0” tall sound barrier on the north, south, and west side of the common outdoor living space areas on the rooftop (Condition No. 17) ● Translucent or opaque barriers on all balconies abut residential properties (Condition No. 18)
● Prohibition on the use of barbeque grills on individual balconies and within the common outdoor living space on the rooftop. (Condition No. 19) The staff report (and proposed Planning Commission resolution) provides evidence that these conditions are an attempt to impose non-objective city code and general plan standards. Beginning on page 15 of the staff report, each required finding for a Development Plan Review is listed, followed by a discussion of whether or not (in the City’s eyes) the finding can be made for the project, and a discussion of how the HAA constrains the city. It is clear from the discussion of the project’s compliance that the relevant condition of approval is being imposed to attempt to force the project to comply with that city code or general plan standard.

Relevant excerpts from the staff report and resolution:
2 of 5

proposed plan is consistent with the general plan and any specific plans adopted for the area.” [BHMC § 10-3-3104(A)]
● “... the project appears to be in conflict with several goals and policies of the City’s General Plan, including: LU 1.1 (Scale of the City), LU 2.1 (City Places: Neighborhoods, Districts, and Corridors), LU 2.10 (Development Transitions and Compatibility), LU 3.1 (Conservation), LU 5.1 (Neighborhood Conservation), LU 5.7 (Neighborhood Transitions), and LU 7.1 (Character and Design) … The placement of the windows and the orientation of open spaces planned for the development are oriented toward neighboring residential properties. The proposed units in the project include balconies along the south and west elevations, which would have direct view of open spaces and windows on neighboring multi-family residential buildings in close proximity to the project, creating privacy concerns that are inconsistent with the goals and policies ofthe General Plan …” [emphasis added] Pages 16 of the staff report, with similar language on pages 14-17 of the resolution: “The proposed plan will not adversely affect existing and anticipated development in the vicinity and will promote harmonious development of the area.” [BHMC § 10-3-3104(B)] ● “... The placement of the windows and the orientation of open spaces planned for the development are oriented toward neighboring residential properties. The proposed units in the project include balconies along the south and west elevations, which would have direct view of open spaces and windows on existing single-family and multi-family residential buildings in close proximity to the project, creating privacy concerns. Based on the foregoing, the proposed project would appear to adversely affect existing and anticipated development in the vicinity of the project and would not promote harmonious development of the area. Thus, this finding cannot be made.In light ofthe issues presented in this finding,the project has been conditioned to address the above noted impacts.” [emphasis added] Pages 17-18 of the staff report, with similar language on pages 14-19 of the resolution: “The proposed plan will not be detrimental to the public health, safety or general welfare.” [BHMC § 10-3-3104(E)]
● “Furthermore, the project includes balconies along the south and west elevations, which would have direct view of open spaces and windows on neighboring multi-family residential buildings in close proximity to the project, creating privacy concerns. Based on the foregoing, the proposed project appears to be detrimental to the general welfare. Thus, this finding that the Project will not be detrimental to public health, safety or general welfare cannot be made..” [emphasis added] 3 of 5
The City is imposing conditions of approval that force the project to at least partially comply with City Code section 10-3-3104 and with various general plan standards. As discussed supra, the HAA forbids the City from applying its code or general plan standards to the project. Applying these standards via conditions of approval is unlawful.

Proposed Condition 11 also seeks to impose local zoning requirements found in the City’s inclusionary housing ordinance on the project, in violation of the builder’s remedy. (Gov.

Code, § 65589.5, subd. (d)(5).) “An inclusionary housing agreement which includes provisions and terms for meeting the requirements of the City’s inclusionary housing requirements shall be approved by the city manager and city attorney and recorded as a deed restriction against the property prior to issuance of either a grading or building permit, whichever comes first.”
Second, several of the proposed conditions would have the effect of deferring the project’s approval to a later stage and/or giving the City discretion to impose requirements that would be inconsistent with the HAA.

Proposed Condition 3 gives the Planning Commission unilateral authority to “impose additional conditions as necessary to mitigate any other unanticipated impacts caused by the Project as they arise.”
● This proposed condition is inconsistent with the HAA, as it allows the City to impose local standards on the project. (Gov. Code, § 65589.5, subd. (d)(5).) Proposed Condition 5. “The Applicant shall provide an updated rooftop operations plan to comply with Project conditions. The updated rooftop operations plan shall be subject to the approval of the Director of Community Development or their designee.” ● As discussed supra, the imposition of local standards via conditions of approval is unlawful under the HAA. (Gov. Code, § 65589.5, subd. (d)(5).) Proposed Condition 6. “Prior to the issuance of building permits, the design, materials, and finish of the building and landscaping shall be subject to the City’s architectural review process.”
● The City’s Architectural and Design Review Commission has no authority to impose local standards on the project, as such standards are forbidden by the HAA. (Gov.

Code, § 65589.5, subd. (d)(5).) Furthermore, the City may not disapprove the project for non-objective reasons. (Gov. Code, §§ 66300, subd. (b)(1)(C); 65589.5, subd. (j)(1)(a).) Proposed Condition 7. “The property shall not be eligible for participation in the City’s Residential Parking Permit Program, or any other City-established parking program..” ● As discussed supra, the imposition of local standards via conditions of approval is unlawful under the HAA. Furthermore, section 7-3-201 of the City code, which governs the residential parking program, allows residential or multifamily buildings 4 of 5
to participate in the program. This condition of approval punishes the future residents of this building for no valid public purpose. Further, if the City only applies this condition to residents of Builder’s Remedy projects, it is a violation of the HAA (Gov. Code, § 65589.5, subd. (f)(6)(E)) and likely a violation of state fair housing law, as low-income residents are a protected class in California (see Gov. Code, §§ 8899.50 and 65008, subs. (a)(3), (b)(1)(C), and (b)(2)(B)).

The Project is Entitled to a Statutory CEQA Exemption
The project is eligible for an exemption from the provisions of the California Environmental Quality Act (“CEQA”) pursuant to AB 130 (Pub. Res. Code, § 21080.66), which was signed into law on June 30, 2025 and was effective immediately (Assembly Bill No. 130, 2025-2026 Regular Session, Sec. 74, available here). Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v.

County of San Diego (2024) 99 Cal.App.5th 890, 911.)
⬢⬢⬢
CalHDF appreciates that the City is moving to approve the proposed housing development project at 232 Tower Drive. However, we warn the City not to impose conditions of approval that would violate state law.

CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org.

Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
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MATTHEW GELFAND, COUNSEL
[email protected]
TEL: (213) 739-8206

October 23, 2025

VIA EMAIL
Planning Commission
City of Beverly Hills
455 North Rexford Drive
Beverly Hills, CA 90210
Email: [email protected]; [email protected] RE: 232 Tower Drive Project
Agenda Item 3., No. PL2400129
To the Planning Commission:

Californians for Homeownership is a 501(c)(3) organization devoted to using legal tools to address California’s housing crisis. We are writing regarding the project at issue in Case No.

PL2400129. The City’s approval of this project is governed by the Housing Accountability Act, Government Code Section 65589.5. For the purposes of the Act, this letter constitutes our written comments on the project.

As you know and as City staff has explained, this project is subject to the builder’s remedy and the City has no lawful basis to deny the project. Additionally, the City cannot lawfully condition the project in a manner intended to impose on the project City standards that the City would not otherwise be able to enforce against the project as a builder’s remedy project; to do so would constitute a denial of the project as proposed. For example, the City cannot impose conditions regarding the nature of the affordable units in the project other than those expressly described in the Act and in other state law.

We have also reviewed the City’s environmental review for the project and determined that it complied with state law. We urge you to approve the project.

Sincerely,
Matthew Gelfand

1 Edgar Arroyo
From: Matthew Duling
Sent: Monday, July 13, 2026 7:14 PM
To: Edgar Arroyo
Subject: Against: Hearing 7/21 re 8-story 55-unit at 232 Tower Dr. 90211
CAUTION: EXTERNAL SENDER

Be cautious when clicking links or opening attachments. Verify the sender's email address and be on the lookout for phishing attempts.

July 14, 2026
TO: Mayor and Council, City of Beverly Hills
Craig A. Corman, Mary N. Wells, Lester Friedman, Sharona R. Nazarian, Rebecca Pynoos RE: Appeal, Hearing July 21 per 232 Tower Dr. 90211
Builder's Remedy, 55 units, 8 stories, 13 parking spaces If built the residents would be the most to suffer its ill-design. Strangely, considerations of their general welfare were denied by the State of California, then in self-appraising themselves as bound by the State, on October 23, 2025, by the City's Panning Commission.

The monster structure in the low-rise neighborhood would lack safeguards and quality-of-life provisions ordinarily granted by the municipal laws and regulations. These were stripped from the City by the State.

Can a developer be blamed for maximizing the rents allowed by such a "regulated housing market"? Residents will notice that the building is wholly devoted to generating income: studios and one-bedrooms, each about 400 or 600 square-feet. There is not even a front Lobby. No Child Care, no Laundry Room, no Community Room. There is no Mail Room, much less gym or sauna. No office for an on-site manager. The State seems to forbid the City to consider the general welfare of perhaps a hundred new citizens, e.g., only 13 parking spaces are available.

Nothing for the community of residents, for people to identity the whole building as "home". Instead, the neighborhood ''environmental design'' sets up a divide and conquer strategy. Not a "one for all" solidarity, but architecturally suggests "each against all". Sooner or later a few stressed renters may start to sub-let their floor space. A miscreant on the upper floor may bully the stranger next door. A sense of anarchy emerges. Street artists do graffiti. The center cannot hold, the falcon cannot hear the falconer.

The institutional learning. of the housing industry knows how to do better. Yet because of a political fixation on speed in upping the count of housing units, here quality of life suffers.

Speaking personally, I served on the Board of Directors at Burbank Housing Development Corporation in Sonoma County for most of the 1990s. Burbank, a creature of the County, was soon spun off as a standalone Non Profit. Yet the Supervisors were adamant that the Board not repeat mistakes in public housing.

In the 1970s projects built were so unintentionally ill-planned that they were demolished in the 1990s.

May my doubts be ill-conceived. Better: may a new design be crafted for Tower Drive.

You don't often get email from Learn why this is important 2 The City is justly proud of its professional staff, often considered the best in the County. Yet following the guidance and direction from the State of California, the City was somehow deemed to fail in qualifying its Housing Element as compliant.

By its honorable Mayor and Council the City is called upon, to the very best of its ability, talents and resources, to protect and defend the general welfare of all its citizens, in the peaceful enjoyment of their residential neighborhoods within its jurisdiction.

Respectfully submitted,
Matthew Duling
Tower Drive
cc: Ken Dusick
1 BEFORE THE CITY COUNCIL OF THE CITY OF BEVERLY HILLS
In re Appeal of Planning Commission Approval of 232 S. Tower Drive Development Plan Review — Case No. PL2400129

BRIEF OF APPELLANTS/OBJECTORS IN SUPPORT OF APPEAL AND IN

OPPOSITION TO PROJECT APPROVAL
Submitted on behalf of Carthay Beverly Hills Neighbors, et al, residents of the City of Beverly Hills and Carthay Circle, City of Los Angeles Historic Preservation Overlay Zone, immediately adjoining the City of Beverly Hills (the “Appellants”).

I. INTRODUCTION.

Appellants urge the City Council to reverse, or at minimum defer and condition, the Planning Commission's approval of an 8-story, 101 foot, 55-unit tower with only 13 parking spaces at 232 S. Tower Drive (the “Tower Project”). This brief does not ask the Council to defy state housing law. It asks the Council to do exactly what the Housing Accountability Act ("HAA") permits and what the California Environmental Act (“CEQA”) requires: apply the rules that existed when this application was filed, conduct the environmental review under the statute, protect the health and safety of the surrounding community, and protect the constitutional rights of residents of the City of Los Angeles, HPOZ protected, historic neighborhood who had no part in Beverly Hills' Housing Element noncompliance.

The Appellants fully support a thoughtful and balanced approach to city planning that achieves the goal of providing additional and affordable housing for the citizens of our great state, while maintaining the beauty, lifestyle and culture of our historic urban environment and its unique, diverse neighborhoods. Unfortunately, the Tower Project, will likely destroy the very environment it is allegedly trying to protect. Members of the Beverly Hills Planning Commission said it best:
2 “We cannot make the findings in a normal manner and that is because we are constrained by state law that wipes out all the things we usually look for or require. We cannot consider shade and shadow. We cannot consider height. We cannot consider setbacks. These are all important things. . . . We cannot take into . . . consideration the historic property.” [Emphasis added.]
Planning Commissioner Kaplan October 23, 2025, hearing
and supported by a similar statement by Commissioner Detmer.

As noted by the Commissioners, by almost every standard the proposed Tower Project is violative of the architectural and living elements of the surrounding community. The east side of Tower Drive is populated by two story apartment complexes, many of which are vintage, charming garden apartments, siblings if you will of the existing 8-unit Tower building. (To this date Appellants are not quite sure why the east side of Tower was not considered for historical designation by the City of Beverly Hills.) These two-story apartments have uniform setbacks and by and large have rear yards of 50 plus feet allowing for parking, turning, loading and unloading as well as locating the apartments a significant distance away from the HPOZ protected homes on Schumacher Drive. Furthermore, the impacts on the immediately surrounding Beverly Hills Tower Drive properties will be tragic. The two-story garden apartments to the north of the Tower Project, which will be dwarfed by the 101-foot development, will remain in shade and shadow for most of, if not all of the day, for just about every day of the year. It does not take an expert (although we do have one) to understand these damaging impacts, including the injuries to the health and safety of these residents both during a two plus year construction several short feet from the adjacent tenants’ doors and windows as well as during the ongoing operational stage.

Appellant is certain that this Council is aware of the recent Superior Court decision in the case of Californians for Homeownership v. City of Beverly Hills (L.A. Super. Ct. Case No. 24STCP02082) (the “Linden Case”). Although the City was found to be acting in good faith, Judge Curtis Kin ruled against Beverly Hills on grounds that are founded in basic fairness and the rationale that in fact supports the position of Appellants in this appeal. The Court found that the Housing Accountability laws were enacted to prevent governments from “’chang[ing] the rules once the housing application is submitted.’” As has been argued by developers on a number 3 of occasions, Courts have found that once the application is filed the rights have become vested and it is unfair to later change the requirements in order “to prevent . . . governments from ‘changing the rules once the housing application is submitted.’ . . . . [The] housing development project will continue to ‘be subject only to the ordinances, policies, and standards adopted and in effect when a preliminary application . . . was submitted’” (Linden Case) What is good for the proverbial goose should be fairly applied to the good faith, conforming gander. Not only does the Linden Case affirm the fairness idea that the rules that governed at the date the application was filed should continue to apply, as discussed below nowhere in AB 130 does the statute say that it should be applied retroactively.

As reviewed in the authorities below, including the Linden case, Appellants submit that the AB 130 exemption from CEQA is not retroactive and has no application to this appeal and the Tower Project. Oddly, the argument for the application of AB 130’s CEQA exemption to this case was volunteered to the developer, without appropriate authority, by a deputy of the Beverly Hills Planning Commission and not at the behest or instigation of the representatives of the developer.1
There are additional strong reasons, including public policy rationale, why CEQA review is necessary. Not only is CEQA an elemental protection for the residents of otherwise HPOZ protected Carthay (whose representative government in the City of Los Angeles was compliant with its Housing Element), CEQA allows this Council to review the cumulative impact of this and other nearby projects on the neighborhood (a major factor in determining the health and safety of this community). This is most notable not only because there are Builders’ Remedy Projects throughout Beverly Hills, including a 90 unit building on nearby Hamilton Drive, but 1 May 28, 2025 – City emails letter “extending the time period to make a determination whether the project at 232 Tower Drive is exempt from CEQA.”
July 17, 2025 – Edgar Arroyo emails Rand: As you may know, Assembly Bill (AB) 130, which became effective on July 1, 2025, created a new exemption from the California Environmental Quality Act (CEQA) for residential development projects meeting certain criteria pursuant to Public Resources Code (PRC) Section 21080.66. City staff has reviewed your proposed project and determined that it satisfies all applicable statutory criteria in PRC Section 21080.66 as outlined below. 4 particularly because of the mammoth project just approximately 500 feet up the street at the corner of Tower Drive and Wilshire.

There is time for a CEQA review in view of the fact that Government Code section 65905.5. (a) provides for five (5) hearings before a final decision is made imperative. (To the best of Appellant’s knowledge this is only the second hearing to date.) By the City ordering an independent CEQA review the Council can await the outcome of that review before making a determination of the environmental impacts of the project on the health and safety of our community as well as decide the important Constitutional questions raised by this unique case, all as discussed below.

Taken at its best, the Builders’ Remedy Law was intended to sanction cities that were delinquent in timely filing their respective Housing Element plans. The charter City of Los Angeles was timely and compliant. It was not the intent of the law to punish residents of a conforming, adjacent city, let alone a neighborhood that is supposed to be protected by its historic HPOZ and National Register status. This and other factors significantly distinguish this case from others previously before this Council, including but not limited to the Linden and Burton Way cases.

Notably, our appeal is earnestly supported by the Los Angeles Conservancy. (See November 5, 2025, letter, previously filed with this appeal.)2 Finally, there is the story of the massive, approved project at the corner of Tower Drive and Wilshire, (8300 Wilshire). The damaging impacts to Tower Drive residents and the surrounding community will, at every phase, be unrelenting. Appellants understand that most if not all the members of this community are horrified by what is planned at 8300. This Council may have felt that their hands were tied by the state law that allowed 8300 to proceed with only 2 “Carthay Circle is one of Los Angeles’ best preserved and most architecturally significant neighborhood(s) . . . . It is unfortunate that the City of Beverly Hills allowed their Housing Element to become noncompliant, putting this neighborhood in the crosshairs of new development, but capriciously exempting others.” Los Angeles Conservancy Letter already filed in support of this appeal.
5 “ministerial” review. The fact is we can mitigate the impact of 8300 (or at least not materially increase it) by granting this appeal in finding that the Tower Project will cause significant, largely un-mitigatable harm to the health and safety of the community and/or finding that CEQA review is dictated by State law.

II. STATEMENT OF FACTS AND PROCEDURAL HISTORY
The Project proposes 55 units (11 affordable) in an 8-story, 101-foot structure on a 50- foot-wide lot (the structure being only approximately 40 feet wide, with only 13 on-site parking spaces (0.24 spaces per unit), requiring approximately two or more years of high-rise construction. The Planning Commission approved the Project on October 23, 2025, and an appeal is now pending before the City Council. As stated above, the Los Angeles Conservancy — the nation's largest local historic preservation organization — has formally filed a letter supporting the appeal, confirming that Carthay Circle has been a City of Los Angeles HPOZ since 1998 and part of the National Register-listed Carthay Neighborhoods Historic District since 2022, and stating that the Project is "out-of-scale and incompatible" even by Beverly Hills' own standards and would inflict "significant negative impact on the historic community outside city limits". The Conservancy has offered to convene a conciliation process among the City, developer, and neighborhood — an offer the Council should not ignore.

In this case, the preliminary application for the Project was submitted on October 5, 2023. The application for the Project was deemed complete by the City on December 27, 2024.

Accordingly, the Project’s application documents, as relevant for “vesting” purposes, predate the Legislature's July 1, 2025, effective date for an AB 130's CEQA exemption (Pub. Res. Code § 21080.66).

III. ARGUMENT
A. AB 130's CEQA Exemption Cannot Be Applied Retroactively to This Application, and Linden Confirms the Rule
An important element of Appellants' legal position is a "vested rules of the game" argument: the rules governing a Builder's Remedy application must be assessed as of the date the 6 complete preliminary application was filed, as explicitly set forth in Government Code §65589.5(o), not as of whatever law happens to be in effect when the City finally acts.

This is not simply Appellants' invention — it is expressly set forth in Government Code §65589.5(o) and is the operative principle underlying the Linden Drive litigation itself. Judge Kin's ruling in Californians for Homeownership v. City of Beverly Hills turned on the proposition that a city may not impose after-the-fact requirements or standards that did not exist when the developer's application was submitted; the court held the City to the law as it existed at the operative filing date. Appellants' argument is the mirror image of the developer's winning argument in Linden: if Beverly Hills cannot retroactively impose new burdens on developers after their applications are complete, neither can the City (or the Legislature, absent clear retroactive intent) retroactively strip neighboring residents and the environment of the CEQA protections that existed when this application was filed. What is unfair to developers under Linden is equally unfair to Appellants here — the principle cuts both ways, and the City should say so on the record (see also Ruegg & Ellsworth v. City of Berkeley (2021) 63 Cal.App.5th (Court of Appeal held that amendments to Government Code § 65913.4 adding Native American tribal cultural resource protections did not apply retroactively to housing development applications submitted before the amendments' effective date reasoning that the amendments lacked language indicating retroactive intent).

California courts presume statutes operate prospectively unless the Legislature clearly expresses a retroactive intent (Evangelatos v. Superior Court (1988) 44 Cal.3d 1188). Unlike some CEQA amendments that the Legislature has explicitly made retroactive to serve important public purposes (see Sagaser v. McCarthy (1986) 176 Cal.App.3d 288) nothing in AB 130's text retroactively extinguishes CEQA obligations that had already attached to a pending, complete preliminary application filed in late 2024, before AB 130's effective date. Indeed, the statute's effective date suggests prospective operation. Where the Legislature intends retroactive application of environmental statutes, it typically includes express language or urgency provisions, as seen in historical CEQA amendments addressing critical public needs. (see Sagaser, above).
7 By appropriately finding that CEQA applies to this Project this Council can defer, rather than foreclose, any ultimate decision on the Project's merits, reserving a ruling on the health and safety and constitutional questions below and perhaps allow for voluntary mediation with the assistance of the LA Conservancy. This does not deny the Project; it merely requires CEQA review, the same environmental review Government Code § 65589.5(e) says the HAA was never meant to eliminate.

B. CEQA Independently Applies and Was Never Properly Waived The onus to comply with CEQA and meet its responsibilities rests squarely with the City.

CEQA Guidelines §15020 (“Each public agency is responsible for complying with CEQA and these Guidelines. A public agency must meet its own responsibilities under CEQA and shall not rely on comments from other public agencies or private citizens as a substitute for work CEQA requires the lead agency to accomplish. For example, a lead agency is responsible for the adequacy of its environmental documents. The lead agency shall not knowingly release a deficient document hoping that public comments will correct defects in the document”).

1. Government Code § 65589.5(e) preserves CEQA in full. The HAA expressly provides that "[n]othing in this section shall be construed to... relieve the local agency from making one or more of the findings required pursuant to Section 21081 of the Public Resources Code or otherwise complying with" CEQA. Builder's Remedy status is not a CEQA exemption in itself. Any exemption must be independently established, on this record, for this Project.

2. The record shows the exemption theory was assumed, not analyzed. Emails between the developer's counsel and City planning staff show the applicant's own advocates assumed CEQA applied — until a City planning deputy summarily concluded, without authority as to its retroactivity, that AB 130 rendered the requirements moot. This misguided input is fundamentally inconsistent with the significant body of law dealing with vested rights and the express provisions of the Housing Accountability laws.

3. Historic-resource impacts on Carthay Circle are exactly what CEQA Guidelines § 15064.5(b) requires the City to study. CEQA defines a "substantial adverse change in the significance of a historical resource" to include physical alteration of a resource's "immediate 8 surroundings," including visual, atmospheric, and contextual impacts — not merely direct demolition. [Emphasis added.] A 101’ tower rising immediately adjacent to a National Registerlisted historic district will visually overwhelm the district's carefully scaled architecture, alter light, shadow and air-circulation patterns integral to its historic setting, and introduce traffic and noise fundamentally inconsistent with the residential tranquility that defines its historic character.

The Los Angeles Conservancy's own letter — filed as part of the administrative record — independently confirms that the Project is incompatible with its surroundings and inflicts a "significant negative impact on the historic community". Categorical exemptions do not apply where substantial evidence, including a recognized preservation organization's expert assessment, shows a reasonable possibility of significant impact on a historical resource, or where there is established evidence that the project will have a significant environmental effect on a historic resource. (Berkeley Hillside Preservation v. City of Berkeley (2015) 60 Cal.4th 1086).

4. Cumulative impacts must be studied together with the 8300 Wilshire AB 2011 project. One of the basic and vital informational functions required by CEQA is a thorough analysis of whether the impacts of the Project, in connection with other related projects, are cumulatively considerable. Banning Ranch Conservancy v. City of Newport Beach (2012) 211 CalApp.4th1209. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time. Bakersfield Citizens for Local Control v.

City of Bakersfield (2004) 124 Cal.App.4th 1184; CEQA Guidelines §15355. Proper cumulative impact analysis is vital because the full environmental impact of a proposed project cannot be gauged in a vacuum. To the contrary, one of the most important environmental lessons that has been learned is that environmental damage often occurs incrementally from a variety of small sources. These sources appear insignificant when considered individually but assume threatening dimensions when considered collectively with other sources with which they interact. Therefore, cumulative effects analysis requires consideration of “reasonably foreseeable probable future projects, if any.” Bakersfield Citizens for Local Control v. City of Bakersfield (2004)124 Cal.App.4th 1184; Gentry v City of Murrieta (1995) 36 Cal.App.4th 1359, 1414.

A separate, massive project is proceeding a short distance away at Wilshire and San Vicente, at the western terminus of Tower Drive, apparently pursued under AB 2011's 9 ministerial approval pathway — meaning it will receive no discretionary review, no CEQA analysis, and no public hearing at all. If the Council concludes CEQA governs 232 Tower Drive, that analysis is the only opportunity for any public body to evaluate the combined burdens these two projects will place on Tower Drive and the surrounding grid. The Appellants have submitted expert evidence that the transportation impacts of this Project, when taken cumulatively, are significant [See Traffic & Parking Review analysis to be submitted by MAT Engineering, Inc.].

There is nothing in the record to the contrary.

CEQA's cumulative-impacts mandate (CEQA Guidelines § 15130) exists precisely for this situation, and, as part of the required CEQA review, the Council should direct staff to commission an independent, Council-selected environmental consulting firm to review cumulative impacts, including but not limited with regard to transportation, aesthetics, air quality, noise, hazards, land use and planning (all as more particularly described in Appendix G which outlines the categories of environmental impacts studied under CEQA for inclusion.] C. Independent, Non-Preempted Grounds for Conditions or Denial Under the HAA Itself Even under Builder's Remedy, Government Code § 65589.5(d)(1) permits denial where the agency makes written findings, based on a preponderance of evidence, that the Project would have a "specific, adverse impact upon the public health or safety" that cannot feasibly be mitigated without rendering the Project unaffordable. Section 65589.5(j)(1) defines this as "a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards... as they existed on the date the application was deemed complete".

Appellants will file in the next two or three days the report of traffic engineers MAT Engineering, Inc. (There was some confusion with the Planning Department on filing dates in order to be included in the Planning Department’s report to the Council). MAT concludes in its report:
“All of the facts that we do know about the planned Tower Project, as well as the existing conditions of the neighborhood, including as well the approved vast project at the end of the block at 8300 Wilshire, will cause severe, negative impacts for the health and safety of 10 the community. These foreseeable transportation hazard impacts will undoubtedly have deleterious, environmental, consequences. I reiterate to a reasonable degree of engineering certainty that the factual conditions planned and existing for this Project will be significantly injurious to the health and safety of the surrounding community and that there is no information in the record that these impacts can be feasibly mitigated.” Appellants identify the following objective, quantifiable impacts:
• Parking deficiency. 13 spaces for 55 units (0.24/unit) falls drastically below Beverly Hills' own objective parking standards and will force overflow parking onto alreadyconstrained residential streets with no collateral capacity. By Beverly Hills own standards, tenants will not be issued permits for Tower parking. The front of the Tower Property is approximately a bare 50 feet wide with an approximately 12-foot driveway bisecting the middle. There is no room for loading and unloading. Tenants who have cars, but no parking spaces will cruise preoccupied and distracted around the neighborhood. (MAT’s report reviews this and many other issues.) In fact, car trips will be multiplied as tenants without automobiles will rely on delivery (Uber Eats, Amazon, Fed Ex, UPS, etc.) and ride services (e.g. Uber, Lyft, Waymo, etc.) for travel. With little or no street parking available services will undoubtedly double park causing significant safety risks for loading and unloading. (Trash pickup is already performed in the middle of the street as trash cans must be rolled into the street on trash mornings since trash trucks cannot reach the curbs. This trash problem will be further exasperated by increasing the density of the property from 8 to 55 units.) The parking impact on health and safety will be further negatively impacted by the construction and operation of the huge building already approved at the corner of Tower and Wilshire.
• Traffic and pedestrian safety. The corridor serves nearby parks and schools; increased vehicle, delivery, and rideshare/Waymo traffic converging on a narrow, 50-foot-wide lot creates quantifiable pedestrian-safety and emergency-access risks. While this overlaps with the parking deficiency it is important to note the risks to health and safety for loading and unloading the elderly, children, and the disabled, particularly when this is necessitated by double parking maneuvers. Again, the huge development approximately 500 feet north of the Tower Property currently plans ingress and egress off of Tower, for both tenant parking (over 200 units, restaurants, guests as well as deliveries.) Reasonably 11 we can only conclude that a significant majority of all tenants, guests, deliveries, ride services, etc. will access 8300 Wilshire to and from Tower Drive, driving past 232 Tower to the immediate south. Wilshire is already backed up with traffic in the southern eastbound lanes stopping at the terminus of the light at San Vicente to the immediate east.

Similarly, overflow at 8300 Wilshire will be cruising for parking around the same area. • Construction-phase safety. A major high-rise excavation on a 50-foot lot, requiring cement trucks, cranes, steel, etc. and deliveries with no on-street staging capacity, will create a sustained chokepoint that impedes emergency-vehicle access for the duration of construction as well as all the other construction related factors to be discussed in MAT’s report. The developer estimated over two years for construction in its short, onedimensional construction management report filed some time ago. As recommended in the MAT Engineering Report the Council will be greatly aided in evaluating the construction impacts on health and safety if the developer provides a detailed report reviewing all the variables recommended by the traffic engineer. This will be further exacerbated by the substantial construction contemplated for 8300 Wilshire which will undoubtedly cause overwhelming negative impacts on Tower Drive (as deliveries of building materials, etc. will have to be made from the Tower side of the property.) • Transportation hazard impacts identified by MAT Engineering, Inc. As set forth in the submitted report, the Project will inhibit safe vehicular and pedestrian traffic flow in the area; increased vehicle/pedestrian/bicyclist conflict (the site is near the existing sports park on Gregory Way, an area that experiences high pedestrian and bicycle activity); does not provide adequate sight distance on a road that is narrow and already limited with regard to sight distance; and will cause spill over into Tower Road and nearby roadways which are already operating at or near capacity. (Appellant believes the Tower Property has planned to have a setback closer to the street than the remainder of the block resulting in further obstruction of sight lines. Finally, the Federal High Administration guidance provides that the increase in cruising vehicles will cause additional congestion, air pollution, time wasted, and driver distraction/frustration. Increased driver distraction/frustration will increase transportation hazards. 12 Separately, and regardless of how the Council resolves the HAA health-and-safety question, the Builder's Remedy preempts only local zoning and general plan denial grounds — it does not, and constitutionally cannot, preempt the City's independent police-power authority to enforce objective fire, life-safety, and building-code standards. Government Code §65913.4. [] Appellants request that the Council require, as a condition precedent to any approval, a fully detailed Construction Management Plan addressing crane placement, material staging, truck routing and delivery windows, tieback shoring methodology, and Fire Department sign-off on emergency access — before any permits issue. If the developer is not willing to produce a substantial Constructive Management Plan, and further if no CEQA study is performed Appellant argues that in the face of the evidence of health and safety impacts we have identified, this Council cannot make a finding of health and safety with supporting substantial evidence.

Indeed, the record only has Appellants’ evidence, evidence of substantial, unmitigable, negative impacts.

D. Due Process and Equal Protection
Appellants have several constitutional arguments. Among other reasons, and perhaps most compelling, Appellants make these arguments because the unusual facts here — an out-ofjurisdiction historic district bearing substantial burdens of a project triggered entirely by a neighboring city's noncompliance. This presents a distinguishable, as-applied scenario that the Legislature likely never contemplated.

We need not decide the constitutional questions at this time if the Council properly finds for Appellants’ right for CEQA review and we can then defer addressing the constitutional and health and safety issues until the CEQA findings are made. Nonetheless it’s important to review the commonsense application of U.S. and California constitutional protections. Everyone is familiar with the relevant language of the 14th Amendment Section 1 which provides in pertinent part, “. . .nor shall any State deprive any person of life, liberty or property without due process of law; nor deny any person . . . the equal protection of the laws.”

1. Procedural due process. Here the unique facts of our case distinguish the unfair plight of the residents of Carthay’s HPOZ. Taken at its best, the Builders’ Remedy Law was intended 13 to sanction cities that were delinquent in timely filing their respective Housing Element plans.

The charter City of Los Angeles was timely and compliant. It was not the intent of the law to punish residents of a conforming, adjacent city, let alone a neighborhood that is supposed to be protected by its historic HPOZ and National Register status. The Builder’s Remedy Law was intended to sanction non-complying jurisdictions. Carthay residents’ representatives did everything right and yet procedurally they were denied the right to participate in the procedure, the process, that is now being used to irreparably injure their presumably protected rights afforded to HPOZ residents. That alone should be grounds for denying Builder’s Remedy Relief to the detriment of residents of a complying, different municipality. The unsupported argument that the Appellants should be denied the otherwise available environmental protection of CEQA review is simply adding unfair insult to injury.

2. Substantive due process —Appellants separately argue an “as-applied” substantive due process objection, distinct from any facial challenge to the Builder's Remedy statute. The Legislature's evident purpose in Government Code § 65589.5 was to pressure a noncompliant jurisdiction into adopting a compliant Housing Element by exposing that jurisdiction's own discretionary land-use authority to Builder's Remedy applications. Here, however, the noncompliant jurisdiction is Beverly Hills, while a principal, concentrated burden of this particular Project — an 8-story, 55-unit tower with 0.24 parking spaces per unit — falls on residents of a National Register historic district in a different city, the City of Los Angeles, which timely complied with its own Housing Element obligations and had no role in, and no ability to cure, Beverly Hills' noncompliance. Appellants do not contend the Builder's Remedy is irrational in the general run of cases; they contend that applying it in a manner that concentrates substantial neighborhood-impact burdens on the residents of an uninvolved, compliant adjoining, historic jurisdiction is not rationally related to the statute's stated purpose as applied to this unique municipal-boundary fact pattern. [A timely as-applied challenge to a specific property development, where the petitioner’s injury does not arise solely from the law’s enactment, may include a facial attack on the applicability of the measure. Travis v. County of Santa Cruz (2004) 33 Cal.4th 757, 769 (in a land-use, project-specific context, the California Supreme Court upholds the ability of a petitioner to challenge not only the enactment or continued existence of a law, but also its application and enforcement to the specific project under consideration). ] 14 3. Equal protection / fundamental fairness. Appellants are residents of the City of Los Angeles, a charter city that timely achieved Housing Element compliance. They had no vote, no representation, and no role whatsoever in Beverly Hills' failure to timely certify its own Housing Element — the precise default that triggered Builder's Remedy exposure for this site. Simply put, it is unfair to treat the Carthay residents any different than other residents of Los Angeles. They did nothing wrong and should not be sanctioned for the failures of third-party jurisdictions.

4. California Constitution, Article I, Section 7. Article I, Section 7 of the California Constitution — which independently guarantees due process and equal protection —affords somewhat more latitude than its federal counterpart in appropriate cases, given California courts' historical willingness to construe state constitutional fairness guarantees to reflect California's particular commitment to meaningful public participation in land-use decision-making. This provides interpretive aid to statutory construction and administrative fairness rather than as an independently dispositive constitutional claim. Not only is this a fairness issue. From a public policy standpoint, it was never the policy of the Legislature to punish residents of complying cities with the Builder’s Remedy sanction. Legislation adopting historical and cultural protections, including the passage of CEQA, represent compelling public interests that far outweigh the inadvertent application of Builder’s remedy punishments to residents of nonoffending city. This is similarly true of the added unsupported effort to erroneously retroactively apply AB 130 to this case.

IV. THE LINDEN AND BURTON WAY PRECEDENTS ARE DISTINGUISHABLE The developer will likely point to the Superior Court's ruling in the Linden Drive matter and the City Council's subsequent approval of the Burton Way tower as evidence that Beverly Hills has no room to resist this Project. Both precedents, however, are readily distinguishable on their facts and legal posture.

The Linden Drive3ruling rested on a finding that the City itself violated the Housing Accountability Act and the Permit Streamlining Act by improperly refusing to process a 3 As noted at pages 2 - 5 above, the Linden Case in fact emphatically supports Appellants’ arguments herein with regard to the inappropriateness of denying CEQA review on behalf of Appellants. 15 complete application. Burton Way, similarly, arose from a City Council reversal of an unsupported Planning Commission denial. Neither case involved a court or council evaluating the kind of record before the City on this Project. Appellants are not asking at this time that the Council to deny this Project outright on the basis of a defective process by the City; they are asking the Council to require legally mandated CEQA review and, with the cooperation of the developer, to provide a detailed Construction Management Plan - a fundamentally different and narrower form of relief. Yes, Appellants believe that the application should be denied due to the obvious harm to health and safety, as well as for the constitutional grounds enumerated above However, a thorough CEQA review will better focus the evaluation of this project for consideration by all the parties. Furthermore, it might provide time for mediation by the LA Conservancy as suggested in their letter of support for Appellants’ appeal.

The site context also differs sharply. Neither Linden Drive nor Burton Way sits adjacent to a designated historic preservation zone or a National Register historic district. This Project does: it directly abuts the Carthay Circle HPOZ and the Carthay Neighborhoods National Register Historic District, and the Los Angeles Conservancy has formally filed an objection in this record specifically because of that adjacency. No comparable third-party preservation authority weighed in on Linden or Burton Way. Furthermore, as stated many times herein, Carthay Circle is in a separate, complying city. Unlike the Burton Way and Linden Properties, the Tower Property has no adjacent alley way for staging, for ingress and egress for deliveries, etc. Tower is also a much more low level, quiet residential street (distinct from Burton Way and Linden’s adjacency to Wilshire) that is about to be severely burdened by a mammoth property that is being designed with entrance and exits directly onto Tower Drive.

The parking disparity further sets this Project apart. Burton Way was approved with a substantially higher parking ratio than what is proposed here; this Project offers only 13 spaces for 55 units, a ratio of roughly 0.24 spaces per unit. That stark deficiency — far below any comparable approved Beverly Hills Builder's Remedy project — is itself a distinguishing, record-worthy fact supporting the heightened scrutiny Appellants request, even though a parking shortfall alone may not be legally sufficient grounds to deny a project outright under the HAA. 16 V. REQUESTED RELIEF
Appellants respectfully request that the City Council: (1) find that CEQA applies to this Project because AB 130's exemption cannot be retroactively applied to a pre-enactment complete application; (2) require a detailed and substantial Construction Management Plan before making a decision on health and safety impacts; (3) accept the Los Angeles Conservancy's offer to convene conciliation among the parties; or, in the alternative (4) expressly grant Appellants' Appeal based upon the significant injury to the communities health and safety from both the construction and operational aspects of the project and/or based upon Appellants’ Constitutional claims.

Respectfully Submitted,
Kenneth B. Dusick
Kenneth Dusick, on behalf of Appellants
ATTACHMENT 14
Project Plans
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139.69
139.40
139.38 138.03
137.78
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Dated: ___________, 2023
___________________________________
Cynthia A. De Leon
RCE 31604 - Exp. 12-31-24
No. C-31604
CYNTHIA A . DE LEON

C I V I L
EXP. 12-31-2024
_____________________
Cynthia A. De Leon (e.signed)
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1/2 MILE RADIUS
232 S

TOWER DR
FUTURE

WILSHIRE /

LA CIENEGA
D-LINE

STATION
FUTURE

WILSHIRE /

FAIRFAX
D-LINE

STATION
28 / 105

BUS ROUTES
11/20/2024  
PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS COMMENTS QTY
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL SIZE WUCOLS COMMENTS QTY
24" BOX STANDARD

BOTANICAL NAME
"COMMON NAME"

BOTANICAL NAME
"COMMON NAME"
1 GAL FULL CAN
3 15
MED

WESTRINGIA FRUTICOSA 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY"

DIANELLA TASMANICA 'VARIEGATA'
"VARIEGATED FLAX LILY" 1 GAL LOW FULL CAN

OLEA EUROPAEA 'LITTLE OLLIE'
"DWARF OLIVE" 5 GAL
5 GAL LOW FULL CAN
4 13
53 LOW FULL CAN
EXISTING TURF PARKWAY TO REMAIN.

PATCH AND REPAIR AS NEEDED. - - - -
- 1 PROTECT IN
PLACE
- STREET TREE TO REMAIN

GEIJERA PARVIFLORA
"AUSTRALIAN WILLOW"
24" BOX MULTI TRUNK 4

1. ALL CLEARANCE DATA PER CITY OF BEVERLY HILLS TREE AND SHRUB PLANTING STANDARDS AND GUIDELINES.

2. RECIRCULATING WATER SYSTEMS SHALL BE USED FOR WATER FEATURES.

3. A MINIMUM 3-INCH LAYER OF MULCH SHALL BE APPLIED ON ALL EXPOSED SOIL SURFACES OF PLANTING AREAS EXCEPT TURF AREAS, CREEPING OR ROOTING GROUNDCOVERS, OR DIRECT SEEDING APPLICATIONS WHERE MULCH IS CONTRAINDICATED.

4. UNLESS CONTRADICTED BY A SOILS TEST, COMPOST AT A RATE OF A MINIMUM OF FOUR CUBIC YARDS PER 1,000 SQUARE FEET OF PERMEABLE AREA SHALL BE INCORPORATED TO A DEPTH OF SIX INCHES INTO THE SOIL.

5. I AGREE TO COMPLY WITH THE REQUIREMENTS OF THE WATER EFFICIENT LANDSCAPE ORDINANCE AND SUBMIT A COMPLETE LANDSCAPE DOCUMENTATION PACKAGE.

6. AT THE TIME OF FINAL INSPECTION, THE PERMIT APPLICANT MUST PROVIDE THE OWNER OF THE PROPERTY WITH A CERTIFICATE OF COMPLETION, CERTIFICATE OF INSTALLATION, IRRIGATION SCHEDULE AND A SCHEDULE OF LANDSCAPE AND IRRIGATION MAINTENANCE.

7. A DIAGRAM OF THE IRRIGATION PLAN SHOWING HYDROZONES SHALL BE KEPT WITH THE IRRIGATION CONTROLLER FOR SUBSEQUENT MANAGEMENT PURPOSES.

8. A CERTIFICATE OF COMPLETION SHALL BE FILLED OUT AND CERTIFIED BY EITHER THE DESIGNER OF THE LANDSCAPE PLANS, IRRIGATION PLANS, OR THE LICENSED LANDSCAPE CONTRACTOR FOR THE PROJECT.

9. AN IRRIGATION AUDIT REPORT SHALL BE COMPLETED AT THE TIME OF FINAL INSPECTION.

PLANTING NOTES
PLANT
FACTOR

0.5 PLANT
FACTOR
-

0.2 0.3

0.2 -
PLANT

FUNCTION
PLANT

FUNCTION

STREET TREE

CANOPY TREE
SHRUB
SHRUB
SHRUB
TURF

PARKWAY

ORNAMENTAL
GRASS

LOPHOSTEMON CONFERTUS
"BRISBANE BOX"
LOW 0.2 FULL CAN LAURUS NOBILIS
"BAY LAUREL"
15 GAL

COLUMNAR
1 GAL MED FULL CAN ASPARAGUS DENSIFLORUS 'MEYERS'
"ASPARAGUS FERN" 0.5 35 SHRUB
36 SHRUB

ORNAMENTAL

PATIO TREE

FICUS PUMILA
"CREEPING FIG" 1 GAL MED 0.5 FULL CAN 8

TRACHELOSPERMUM ASIATICUM
"ASIAN STAR JASMINE" 1 GAL AT 18" O.C. MED 0.5 FULL CAN 620 SF

CLINGING
VINE

GROUNDCOVER

ROSA 'QUEEN MARY'
"QUEEN MARY ROSE" 5 GAL FULL CAN 5 SHRUB

RAPHIOLEPIS INDICA 'CLARA'
"INDIAN HAWTHORNE" 5 GAL LOW 0.3 FULL CAN 47 SHRUB

LAVENDULA X INTERMEDIA 'PROVENCE'
"PROVENCE LAVENDER"

TRACHELOSPERMUM JASMINOIDES
"STAR JASMINE" 5 GAL MED 0.5 FULL CAN 4 CLINGING
VINE
LOW 0.3
MED 0.5
LOW 0.3

TREE CALCULATIONS
TOTAL EXISTING STREET TREES = 1 TREES
TOTAL PROPOSED STREET TREES = 0 TREES
TOTAL PROPOSED TREES = 7 TREES

FINE GRADING NOTES
GROUND FLOOR PLANTING AREA = 2,388.0 SF
ROOFTOP PLANTING AREA = 90.0 SF
TOTAL PLANTING AREA = 2,478.0 SF
TOTAL SITE AREA = 10,041.0 SF
TOTAL BUILDING SF = 6,508.0 SF
TOTAL PLANTING AREA = 2,478.0 SF
TOTAL GROUND HARDSCAPE AREA = 933.0 SF
TOTAL ROOFTOP HARDSCAPE AREA = 2,200.0 SF
TOTAL HARDSCAPE AREA = 3,133.0 SF
TOTAL HARDSCAPE EXCEEDING .30 SRI = 100%
TOTAL PERMEABLE HARDSCAPE % = 0%

SITE AREA CALCULATIONS

PLANTING AREA CALCULATIONS
SHEET INDEX:

SHEET SHEET TITLE
L1.00 LEGEND AND NOTES
L1.10 GROUND FLOOR CONCEPTUAL LANDSCAPE PLAN
L1.11 ROOFTOP TERRACE CONCEPTUAL LANDSCAPE PLAN
L1.12 GROUND FLOOR PLANTING PLAN
L1.13 ROOFTOP TERRACE PLANTING PLAN
TREE PROTECTION NOTES: CONSTRUCTION NOTES:

L1.00
LEGEND AND NOTES 232 S. Tower Drive 232 S. Tower Drive Beverly Hills, CA 90211 Sheet title:

Issue dates
# Date Description
NV
2313
Designed by:

Drawn by:

Checked by:

Project number:

NV
NV
1 7/1/23 Entitlement Submittal
= 10,046.06
NOTE:

NO LANDSCAPE LIGHTING IS PROPOSED
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
S. TOWER DRIVE
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.

L1.10

GROUND FLOOR

CONCEPTUAL

LANDSCAPE PLAN

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
232 S. Tower Drive
232 S. Tower Drive
Beverly Hills, CA 90211
Sheet title:

Issue dates
# Date Description
NV
2313
Designed by:

Drawn by:

Checked by:

Project number:

NV
NV
1 7/1/23 Entitlement Submittal

RESIDENCE

CONCRETE PAVING
COLOR: NATURAL
FINISH: LIGHT BROOM PER CITY

STANDARD

CONCEPT DESIGN IMAGERY

INTEGRAL COLOR CONCRETE PAVING
COLOR: PALOMINO
FINISH: TOPCAST #3
6’ HIGH METAL SECURITY FENCE

TRANSFORMER

NATURAL CONCRETE PAVING WITH LIGHT

BROOM FINISH PER CITY STANDARD

INTEGRAL COLOR CONCRETE DRIVEWAY

WITH TOPCAST FINISH
6’ HIGH METAL SECURITY GATE

EXISTING STREET TREE TO REMAIN

WASHINGTONIA FILIFERA
“CALIFORNIA FAN PALM”
15” CALIPER
6’ HIGH STUCCO CMU WALL. COLOR AND
FINISH TO MATCH RESIDENCE.

VINE POCKET

INTEGRAL COLOR CONCRETE PAVING

WITH TOPCAST FINISH
6’ HIGH STUCCO CMU WALL. COLOR AND
FINISH TO MATCH RESIDENCE.

INTEGRAL COLOR CONCRETE PAVING

WITH TOPCAST FINISH
RAISED STUCCO CMU PLANTER WALL.

COLOR AND FINISH TO MATCH RESIDENCE.
6’ HIGH STUCCO CMU WALL. COLOR AND
FINISH TO MATCH RESIDENCE.
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.

L1.11

ROOFTOP CONCEPTUAL

LANDSCAPE PLAN

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
232 S. Tower Drive
232 S. Tower Drive
Beverly Hills, CA 90211
Sheet title:

Issue dates
# Date Description
NV
2313
Designed by:

Drawn by:

Checked by:

Project number:

NV
NV
1 7/1/23 Entitlement Submittal

STAIR ELEV ELEV
STAIR

COUNTER WITH HIGH STOOLS NATURAL GAS FIRE PIT COOK CENTER

CONCEPT DESIGN IMAGERY

INTEGRAL COLOR CONCRETE PORCELAIN STONE TILE FIBERGLASS PLANTER GREENSCREEN PAVING
COLOR: PALOMINO
FINISH: TOPCAST #3

GREENSCREEN WITH

CLINGING VINES

COOK CENTER

OVERHEAD TRELLIS

SYNTHETIC TURF

DINING TABLE AND CHAIRS
OUTDOOR T.V.

COUNTERTOP ISLAND WITH

BAR STOOL SEATING

PORCELAIN TILE PAVING

FIBERGLASS PLANTER

NATURAL GAS FIRE PIT

PARAPET PER

ARCHTIECT

INTEGRAL COLOR

CONCRETE PAVING

WITH TOPCAST FINISH

SYNTHETIC TURF

LOUNGE FURNITURE

PROPERTY LINE
PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS COMMENTS QTY
24" BOX STANDARD

BOTANICAL NAME
"COMMON NAME"
MED 3
- PROTECT IN 1 PLACE
- STREET TREE TO REMAIN

GEIJERA PARVIFLORA
"AUSTRALIAN WILLOW"
24" BOX MULTI TRUNK 4
PLANT
FACTOR

0.5 -
PLANT

FUNCTION

STREET TREE
LOPHOSTEMON CONFERTUS CANOPY TREE "BRISBANE BOX"
ORNAMENTAL LOW 0.3 PATIO TREE
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL BOTANICAL NAME SIZE WUCOLS COMMENTS QTY
"COMMON NAME"
1 GAL FULL CAN 15

WESTRINGIA FRUTICOSA 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY"

DIANELLA TASMANICA 'VARIEGATA'
"VARIEGATED FLAX LILY" 1 GAL LOW FULL CAN

OLEA EUROPAEA 'LITTLE OLLIE'
"DWARF OLIVE" 5 GAL
5 GAL LOW FULL CAN
4 13
53 LOW FULL CAN
EXISTING TURF PARKWAY TO REMAIN.

PATCH AND REPAIR AS NEEDED. - - - -
PLANT
FACTOR
-

0.2 0.3

0.2 PLANT

FUNCTION
SHRUB
SHRUB
SHRUB
TURF

PARKWAY

ORNAMENTAL
GRASS
LOW 0.2 FULL CAN LAURUS NOBILIS
"BAY LAUREL"
15 GAL

COLUMNAR
1 GAL MED FULL CAN ASPARAGUS DENSIFLORUS 'MEYERS'
"ASPARAGUS FERN" 0.5 35 SHRUB
36 SHRUB

FICUS PUMILA
"CREEPING FIG" 1 GAL MED 0.5 FULL CAN 8

TRACHELOSPERMUM ASIATICUM
"ASIAN STAR JASMINE" 1 GAL AT 18" O.C. MED 0.5 FULL CAN 620 SF

CLINGING
VINE

GROUNDCOVER

ROSA 'QUEEN MARY'
"QUEEN MARY ROSE" 5 GAL FULL CAN 5 SHRUB

RAPHIOLEPIS INDICA 'CLARA'
"INDIAN HAWTHORNE" 5 GAL LOW 0.3 FULL CAN 47 SHRUB

LAVENDULA X INTERMEDIA 'PROVENCE'
"PROVENCE LAVENDER"

TRACHELOSPERMUM JASMINOIDES
"STAR JASMINE" 5 GAL MED 0.5 FULL CAN 4 CLINGING
VINE
MED 0.5
LOW 0.3
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
S. TOWER DRIVE
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.

L1.12

GROUND FLOOR

PLANTING PLAN

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
232 S. Tower Drive
232 S. Tower Drive
Beverly Hills, CA 90211
Sheet title:

Issue dates
# Date Description
NV
2313
Designed by:

Drawn by:

Checked by:

Project number:

NV
NV
1 7/1/23 Entitlement Submittal

RESIDENCE

PLANT DESIGN IMAGERY

LOPHOSTEMON CONFERTUS
“BRISBANE BOX”

FICUS PUMILA
“CREEPING FIG”
LAVENDULA ‘PROVENCE’
“PROVENCE LAVENDER”
TRACHELOSPERMUM A.
“ASIAN STAR JASMINE”
DIANELLA TAS. ‘VARIEGATA’
“VARIEGATED FLAX LILLY”
ASPARAGUS DEN. ‘MYERII’
“FOXTAIL FERN”
RHAPHIOLEPIS I. ‘CLARA’
“INDIAN HAWTHORNE”
WESTRINGIA ‘MORNING LIGHT’
“COASTAL ROSEMARY”

LAURUS NOBILIS
“BAY LAUREL”
ROSA ‘QUEEN MARY’
“QUEEN MARY ROSE”
PLANTING LEGEND: TREES

SYMBOL SIZE WUCOLS COMMENTS QTY
24" BOX STANDARD

BOTANICAL NAME
"COMMON NAME"
MED 3
- 1 PROTECT IN
PLACE
- STREET TREE TO REMAIN

GEIJERA PARVIFLORA
"AUSTRALIAN WILLOW"
24" BOX MULTI TRUNK 4
PLANT
FACTOR

0.5 -
PLANT

FUNCTION

STREET TREE
LOPHOSTEMON CONFERTUS CANOPY TREE "BRISBANE BOX"
ORNAMENTAL LOW 0.3 PATIO TREE
SHRUB, VINE & GROUNDCOVER LEGEND:

SYMBOL BOTANICAL NAME SIZE WUCOLS COMMENTS QTY
"COMMON NAME"
1 GAL FULL CAN 15

WESTRINGIA FRUTICOSA 'MORNING LIGHT'
"MORNING LIGHT COASTAL ROSEMARY"

DIANELLA TASMANICA 'VARIEGATA'
"VARIEGATED FLAX LILY" 1 GAL LOW FULL CAN

OLEA EUROPAEA 'LITTLE OLLIE'
"DWARF OLIVE" 5 GAL
5 GAL LOW FULL CAN
4 13
53 LOW FULL CAN
EXISTING TURF PARKWAY TO REMAIN.

PATCH AND REPAIR AS NEEDED. - - - -
PLANT
FACTOR
-

0.2 0.3

0.2 PLANT

FUNCTION
SHRUB
SHRUB
SHRUB
TURF

PARKWAY

ORNAMENTAL
GRASS
LOW 0.2 FULL CAN LAURUS NOBILIS
"BAY LAUREL"
15 GAL

COLUMNAR
1 GAL MED FULL CAN ASPARAGUS DENSIFLORUS 'MEYERS'
"ASPARAGUS FERN" 0.5 35 SHRUB
36 SHRUB

FICUS PUMILA
"CREEPING FIG" 1 GAL MED 0.5 FULL CAN 8

TRACHELOSPERMUM ASIATICUM
"ASIAN STAR JASMINE" 1 GAL AT 18" O.C. MED 0.5 FULL CAN 620 SF

CLINGING
VINE

GROUNDCOVER

ROSA 'QUEEN MARY'
"QUEEN MARY ROSE" 5 GAL FULL CAN 5 SHRUB

RAPHIOLEPIS INDICA 'CLARA'
"INDIAN HAWTHORNE" 5 GAL LOW 0.3 FULL CAN 47 SHRUB

LAVENDULA X INTERMEDIA 'PROVENCE'
"PROVENCE LAVENDER"

TRACHELOSPERMUM JASMINOIDES
"STAR JASMINE" 5 GAL MED 0.5 FULL CAN 4 CLINGING
VINE
MED 0.5
LOW 0.3
0 SCALE: 1/8" = 1'-0"
4' 8' 16' 32' NORTH
NOTE:

1. SEE SHEET L1.00 FOR LEGEND AND NOTES.

L1.13

ROOFTOP CONCEPTUAL

PLANTING PLAN

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
232 S. Tower Drive
232 S. Tower Drive
Beverly Hills, CA 90211
Sheet title:

Issue dates
# Date Description
NV
2313
Designed by:

Drawn by:

Checked by:

Project number:

NV
NV
1 7/1/23 Entitlement Submittal

STAIR ELEV ELEV
STAIR
OLEA EUROPAEA ‘LITTLE OLLIE’
“DWARF OLIVE”
TRACHELOSPERMUM J.
“STAR JASMINE”

GEIJERA PARVIFLORA
“AUSTRALIAN WILLOW”
LAVENDULA ‘PROVENCE’
“PROVENCE LAVENDER”
ROSA ‘QUEEN MARY’
“QUEEN MARY ROSE”

PLANT DESIGN IMAGERY