Glendale City Council
March 1, 2022

Its essential questions should be:

Is there a historical resource that may be affected by the proposed project; and Will the project result in a substantial adverse change to the extent that the resource’s historical value is materially impaired or lost?
Evaluations for historic significance are not normally “negative” as stated in the document, historical resources either exist or they do not. Negative findings are an archaic term that was used in solely archaeological investigations and do not apply to the built environment. That paragraph, along with the section title, the evaluation and analysis contained therein alerts informed readers to the fact that the entire section may have been prepared primarily by archaeologists practicing outside of their fields of expertise.

The Tribal Cultural Resources title implies that only archaeological resources and tribal concerns were considered. Under CEQA, Initial Studies and EIRs address Cultural Resources, not merely “Tribal Cultural Resources.”
Preparer Qualifications
The preparer qualifications presented in the Initial Study (1.4 Cultural Resources Project Staff Qualifications) do not demonstrate that any staff meet the Secretary of the Interior’s Professional Qualifications Standards. A statement in the closing paragraph claims “The Stantec Cultural Resources Program Manager and Senior Architectural Historians directing the survey meet the Professional Qualification Standards of the Department of the Interior” but provides no particulars regarding degrees attained and more importantly does not identify any staff members’ fields of expertise (emphasis added). Each provides numbers of years preparing reports but none of the brief biographies provides evidence to corroborate meeting the Secretary of the Interior’s Professional Qualifications Standards codified in CFR Part 61.

The guidance in Archeology And Historic Preservation: Secretary of the Interior's Standards and Guidelines [as Amended and Annotated] directs “The qualifications define minimum education and experience required to perform identification, evaluation, registration, and treatment activities. In some cases, additional areas or levels of expertise may be needed, depending on the complexity of the task and the nature of the historic properties involved”. The website for the Historical Architect responsible for the report states that he specializes “in custom residential architecture, and also do[es] commercial projects” (http://www.johnterryarch.com/Introduction-1). Enumerated experience on that website includes two “renovations” but no rehabilitations or restorations are listed. No evidence of a year or more of graduate study or of professional experience including “detailed investigations of historic structures, preparation of historic structures research reports, and preparation of plans and specifications for preservation projects” as cited in the Professional Qualifications Standards is provided. We submit that this evaluation for historic significance is a complex case, and that the preparers provide no evidence of additional levels or areas of expertise and shows no demonstrated experience with successful evaluations for the National, California or Glendale Registers.

Archaeologists are not normally qualified to prepare built environment evaluations, and historians are not interchangeable with historic architects. In the FEIR revised cultural resources technical report all preparers’ professional qualifications should be clearly stated otherwise the reviewers suspect that it was prepared by staff who have generated reports for specific numbers of years rather than persons with demonstrated expertise necessary to perform the tasks required for this evaluation of historic significance and analysis of effects.
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Laws, Ordinances, Regulations and Standards
The introductory “Laws, Ordinances, Regulations and Standards (LORS)” section is fatally flawed. The applying LORS enumerated are not demonstrated to have any specific application to the project. If federal regulations apply to the proposed project, then Section 106 of the National Historic Preservation Act (as amended) would pertain to the project. If the project has any federal nexus, the proper environmental document would likely be an Environmental Impact Statement/Environmental Impact Report (EIS/EIR) rather than merely an EIR.

It is not clear that Section 106 of the National Historic Preservation Act does or does not apply to the proposed project. We expect that a project of this type requires federal permits, licenses or other approvals. If so, Section 106 applies and the appropriate clearance document may be an Environmental Impact Study and well as an Environmental Impact Report.

The federal Environmental Protection Agency (EPA) promulgated the Steam Electric Power Generating Effluent Guidelines and Standards (40 CFR Part 423) in 1974, and amended the regulations in 1977, 1978, 1980, 1982 and 2015. The regulations cover wastewater discharges from power plants operating as utilities. The steam electric regulations are incorporated into National Pollutant Discharge Elimination System (NPDES) permits. If a NPDES permit or any other federal approval or license is required for the proposed project, there is a federal nexus and Section 106 applies.

Further, the EPA released a final rule to limit greenhouse gas emissions from new power plants on August 3, 2015. The final “Carbon Pollution Standard for New Power Plants” establishes New Source Performance Standards to limit emissions of carbon dioxide from fossil fuel-fired power plants. If the “Carbon Pollution Standard for New Power Plants” applies to the proposed project or any other federal approval or license is required for the proposed project, there is a federal nexus and Section 106 applies.

Please explain how the National Environmental Policy Act would or would not apply to the proposed project. Can the proposed project be considered a major federal action that would be determined to significantly affect the quality of the human environment? The “Applicable Federal, State, Local LORS for Tribal [sic] Cultural Resources” table and section notably contains no discussion of whether or not the listed LORS apply and why, which is an obvious necessity in such documents. Merely listing the language in LORS does not inform the public or decision-makers in making their decisions regarding the proposed project.

In the “Applicable Federal, State, Local LORS for Tribal [sic] Cultural Resources” table, there are significant errors and omissions. The administering agency column is incorrect in each entry. For instance, Section 106 is not administered by the Code of Federal Regulations (CFR).

CFR is not and has never been an administering agency; it is codification of the general and permanent rules and regulations (or administrative law) published in the Federal Register by the executive departments and agencies of the federal government. Applicable Federal Agency Programs administer Section 106 with the Advisory Council on Historic Preservation. If that table, which provides no of information of value to the analysis, remains, it must be corrected in the Final EIR or a supplemental EIS/EIR. We strongly recommend that it be completed (most of it is blank) and corrected to list correct administering agencies.

Further, where each of the LORS is enumerated in the narrative sections below, applicable language was merely cut-and-pasted into the document. There is notably no description of how 230 of 296

the listed LORS apply to the proposed project, and why, or what it means to the project or analysis, which is critical to understanding what the document is and why preparers came to whatever conclusions they did. Absent this information, the “Tribal Cultural Resources” section of the document is useless, devoid of worthwhile information for decision makers and the public.

Reviewers are left wondering what laws, ordinances and regulations apply to the proposed project, why and how that fits into the analysis at hand.

Archaeology
Neither the “Existing Conditions” section nor the other parts of the larger “Tribal Cultural Resources” [sic] chapter make reference to an archaeological surveys being performed, presenting the property only above-ground when whatever does or does not exist below grade is undeniably part of the subject property’s cultural resources existing conditions. No reference was made to any archaeological surveys being performed for the proposed project, of the likelihood for encountering archaeological resources or what the expected impacts of effects would be on those resources.

Review of the Initial Study, where the technical reports are sequestered, provides an overview of archaeological surveys being performed in 2003 and 2016, providing no further details. What methods were used? How much of the subject property was surveyed? More importantly, who at the City of Glendale has the appropriate credentials (meeting the Secretary of the Interior’s Professional Qualifications Standards in Archaeology) to critically review the reports that ostensibly resulted? Was a subcontractor engaged to review whatever reports resulted from those surveys? Provide the name and professional qualifications of the archaeologist who reviewed the confidential section of the Initial Study.

The archaeological survey reports were requested of the City by Francesca Smith, a cultural resources professional who is approved by the South Central Coastal Information Center to perform records searches and to review archaeological surveys. It was denied pending City Attorney review. Subsequently, the same request was made on behalf of a professionally qualified archaeologist, but no response has been received to date. The archaeological surveys on which the “Tribal Cultural Resources” section and Initial Study conclusions were based should be made available to qualified reviewers on request. TGHS, the public and decision makers can’t provide any comments on the adequacy of those studies without being provided those reports for review.

Methodology
The “Methodology” section of the EIR is inadequate as well. The two sentences describing Senate Bill 52 efforts is not equivalent to what should be a description of how project Cultural Resources procedures were carried out. Inserting words that do not apply into a section does not satisfy the requirements of CEQA. The methodology section is intended to explain how the evaluation and analysis were prepared that lead the preparers to arrive at the conclusions they did.

Evaluation for Historic Significance
We additionally submit that because the evaluation of the subject property’s historic significance is not included in the document or the appended technical reports, decision makers cannot review the evaluation. Because of that omission, decision-makers and the public cannot make their own conclusions based on information presented as to whether or not the Grayson Steam-Electric Power Plant is historically significant. In addition, because that information is not provided, 231 of 296

decision-makers and public are not able to judge whether substantial adverse change to a historical resources would be materially impaired or entirely lost. The California Code of Regulations (CCR) directs under Technical Detail:

The information contained in an EIR shall include summarized technical data, maps, plot plans, diagrams, and similar relevant information sufficient to permit full assessment of significant environmental impacts by reviewing agencies and members of the public.

Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through inclusion of supporting information and analyses as appendices to the main body of the EIR. Appendices to the EIR may be prepared in volumes separate from the basic EIR document, but shall be readily available for public examination and shall be submitted to all clearinghouses which assist in public review (emphasis added, CCR Section 15147).

The applicable cultural resources analysis is not contained in the technical report section, or in an appendix, but was secreted in the Notice of Preparation. Once TGHS was able to locate the “Architectural Resource Evaluation of The Grayson Power Plant For City of Glendale, California” it was reviewed for adequacy by a professional qualified under the Secretary of the Interior’s Qualifications Standards in both history and architectural history and was found not to be correct in its conclusions.

Other EIR reviewers will not know where to find the evaluation for historic significance.

Because that analysis is not “readily available for public examination” it does not “assist in public review” as required. We strongly stress that the conclusion, that the Grayson Steam- Electric Power is not historically significant is was made in error and that the revised, corrected evaluation should be a technical appendix to the FEIR and that the FEIR should address alternatives to the project that would retain the historical resource and or mitigate its loss if it were proven not to be feasible, based on facts.

Like the archaeological investigation, no evidence is provided of any lead agency review of the conclusions in the report being performed by qualified staff or consultants for the City of Glendale. The conclusions the EIR that are based in incorrect finding in the Initial Study must be peer-reviewed for accuracy by professionally qualified professionals with demonstrated expertise in the applicable fields.

Reconnaissance Survey
The evaluators note in the survey type on the DPR form that the evaluation is an “Architectural Inventory and Evaluation Reconnaissance Survey.” We strongly assert that an intensive evaluation must be prepared by local qualified architectural historians with has clear understanding of the Grayson Steam-Electric Power Plant’s place in local and regional history and who has demonstrated experience in applying the criteria for Glendale Register of Historic Resources to evaluations for significance. We assert that the property’s National, California Register and local significance were not properly considered and that its conclusions are incorrect.

National Register guidance prepared by the Department of the Interior provides a definition in “Guidelines for Local Surveys A Basis For Reservation Planning: “Reconnaissance may be thought of as a ‘once over lightly’ inspection of an area, most useful for characterizing its resources in general and for developing a basis for deciding how to organize and orient more detailed survey efforts.”
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Likewise directions in “The Secretary of the Interior's Guidelines for Identification” state Reconnaissance survey might be most profitably employed when gathering data to refine a developed historic context—such as checking on the presence or absence of expected property types, to define specific property types or to estimate the distribution of historic properties in an area… In most cases, areas surveyed in this way will require resurvey if more complete information is needed about specific properties” (emphasis added, Archaeology and Historic Preservation: Secretary of The Interior's Standards and Guidelines, as Amended and Annotated, 48 Federal Register 44716, effective 1983).

We believe a reconnaissance survey, buried in the Initial Study was not the correct level of evaluation and should rightly be an intensive survey in a technical appendix to the EIR that would allow reviewers the opportunity to consider the logic of a full evaluation for historic significance.

Is the Grayson Steam-Electric Plant a Historical Resource? The “Tribal Cultural Resources” [sic] EIR section commences with a statement where the authors refute their own justification for finding the Grayson Steam-Electric Power not to be historically significant:

While the [Grayson Steam-Electric Power] Plant does possess potential significance under the… [California Register] and Glendale Register of Historic Resources Criterions [sic] 1, 2, 3, and 4, a lack of integrity under all aspects of integrity recognized by the… [California Register], and implemented for the City of Glendale Register… which is silent on aspects of integrity, undermines the property’s ability to convey importance/significance for either the state or local registers.

The Glendale Register has no requirement for integrity. Finding a property not eligible for the Glendale Register because of supposed alterations is not supported in the stated requirements for designation on the local register. Because the Glendale Register has no specific requirements for integrity a property’s significance should not be dismissed because of alterations, particularly when the facility being evaluated remains absolutely recognizable to its original appearance.

When properties are significant for associations with the development of the community or with important persons they need not retain the same aspects or level of integrity as a property that is significant only for its design. That concept is a fundamental principle in evaluating properties for historic significance and was markedly not recognized by the document preparers.

Furthermore, the addition of separate cooling towers, maintenance and storage buildings, oil tanks and trailers over time would be essential to its continued use as a power plant and would be well-known to qualified, experienced practitioners.

The inadequate evaluation in the Initial Study does not make clear where the described, overly emphasized alterations are, or how they would collectively reduce the property’s integrity of design. Table 4 in the Initial Study curiously lists more than 57 building permits (only post 1964), but after review, it is discovered that few, if any are actual alterations to the Grayson Steam-Electric Power Plant that would affect its integrity. The document states “Some of the projects associated with these permits are visible in the aerials…” but no connection between listed building permits and actual alterations that would affect the ability of the property to 233 of 296

convey its significance, which is central to the claim of the property not being eligible has been made.

Supposed alterations such as “Constructed a new concrete block chemical pump house with concrete roof” (1964), “Constructed one metal shed” (1970) and “Constructed a foundation (only) for a temporary modular trailer” (2012) demonstrate the consultant’s lack of understanding of the crux of an evaluation for historic significance. Does the property have historic significance and if it does, is it recognizable, depending on the type of significance? None of those predominately separate actions described as alterations in the Initial Study table or annotated aerials affected the design, location, materials, workmanship, feeling or association of the power plant. Its setting may have changed since it was completed, but its setting in an industrial yard is not as essential to its significance as would the setting of other buildings such as a barn in an open field or adjacent to a barnyard. The subject property remains in a utility yard setting as it has been historically. The additional small buildings and other structures and objects that have been added to the subject property are located on the northwest and southwest, non-character-defining, secondary and rear sides of the plant as demonstrated in Figure 1.

Figure 1: Excerpted and annotated from Architectural Resource Evaluation of The Grayson Power Plant For City of Glendale, California, showing only a ramp and trailer on the northwest (left-hand) side of the main building and various additional facilities at the back or southwest side of the Grayson Steam-Power Plant Building. Note that very few alterations in this figure are connected to the main, Grayson Steam-Power Plant Building, which is highlighted in yellow.

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Figure 1 makes evident the fact that there are no alterations on the façade or northeast side, none are shown on the southeast end wall (a carport was added sometime after 1950 that does not affect its integrity), various small additions on the non-character-defining southwest side and only a ramp was added on the northwest side.1 Further text will describe why other small changes do not affect its integrity. The building’s principal cladding materials remain, its original ribbon, hopper-type and glass block, multi-story windows remain, the original metal sign on stand-outs and the distinctive, staggered, horizontal corner fillets remain intact. An experienced architectural historian would have exercised appropriate professional judgment and omitted items that were not alterations that affected the actual resource under consideration. The Grayson Steam-Electric Power Plant structure retains more than adequate integrity to its original design by Daniel A. Elliott, AIA, and remains recognizable.

Grayson Steam-Electric Power Plant Significance
The Grayson Steam-Electric Power Plant is significant for its association with the development of the community, for its direct association with Lauren W. Grayson, likely for its Streamline Moderne-Stripped Classicism design, as the work of a master architect and as the first earthquake-proof power plant. Its integrity of design remains, clearly visible from nearby streets, the large, metal and stucco-clad building is visible and is the inventive, original design remains easily distinguishable.

Association with the Development of the Community
The power plant’s connection to the development of Glendale is reasonably straightforward and is undeniable. Almost immediately after Glendale’s incorporation, locals recognized the importance and costs savings of establishing independent utilities. Once street lighting became an issue, the new city government took action to establish a “light and power” entity, holding a bond election to acquire and construct an electric works system for the city by 1909 (Winston W. Crouch and Beatrice Dinerman, Southern California Metropolis: A Study of Development of a Government for a Metropolitan Area 1964). An expanded distribution service and the establishment of the Glendale Light and Power Company were the part of the consequences of that election. Without the existence of the subject property power plant, the community would not have had the necessary utility capacity to grow as it did after the second World War. In 1938, the Los Angeles Times substantiated the assertion that the power plant made development of the community possible, reporting “City officials have maintained steadily that there are no available sources of power and that erection of the generating plant is necessary” (“City Officials Deny Charges in Glendale Power Plant Plan” 26 May 1938:14). The resulting power plant was built at an estimated cost of $1.5 million.

In the two decades spanning its construction, the population of modern Glendale increased by more than 50 percent between 1930 and 1950, from approximately 63,000 to 96,000 (U.S.

Census). Neighboring Pasadena and other comparable communities’ populations did not grow by nearly as great a percentage as Glendale’s unfettered growth during that period. The stratospheric evolution of Glendale as a population and business center was spurred partly by annexation but as much by its increased ability to independently provide inexpensive power to newly expanding and establishing businesses and the thousands of new homes and apartments that were built during that time. That tendency continued “between 1980 and 2000, Glendale grew significantly more than neighboring areas” (City of Glendale, Government Departments, Economic Development, “Great Demographics,” “Top 10 Reasons You Want Your Business in

1 An “addition to boiler room” at the southwest corner is noted in the Initial Study Figure 15 annotated aerial photographs incorrectly as being added around 1979 (Aerial 4). That small addition is clearly evident in Aerial 2, the 1964 aerial photograph.
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Glendale” at http://www.glendaleca.gov/government/departments/glendale-economic- development-corporation-/top-10-reasons-you-want-your-business-in-glendale/analytic- information). Sustaining that trend that was made partly possible by the existence of an independent power source, the population of Glendale soared by nearly 40 percent during that 20-year period, significantly more than any other single city in Los Angeles County and more than the county itself. Without an autonomous power source providing economical electricity, the unbridled population growth and expansion of Glendale after World War II would not have been possible. The power plant shaped that development rather than merely reflecting it.

Because of that direct connection between Glendale’s growth and the Grayson Steam-Electric Power Plant, it is eligible for listing in the California and Glendale Register under each Criterion 1 for its essential role making the Postwar development of the community possible.

Distinctive Stripped Classicism Design, Work of a Master and Engineering Significance Stripped Classicism was a twentieth century architectural style that reduced all, or nearly all superfluous ornamentation. It was favored primarily by government agencies for public building designs and was widely used by the Works Progress Administration during the Depression. The style embraced simplified but recognizable classicism in its overall massing, scale and proportions while eliminating traditional decorative detailing.

The significance of the design by architect Daniel Anthony Elliot, A.I.A. for the main building remains plainly visible and recognizable is not adequately explored in the reconnaissance level evaluation. The original, remaining design placed a large amount of equipment inside a metal- clad, deftly stepped shell that articulated a large volume from what could have been an ungainly multi-street block shape into human-scaled units, reducing its apparent mass and creating an elegant solution to what could well be an entirely utilitarian facility. In addition the electrical turbines, which are entirely functional apparatuses used to drive generators to transform mechanical energy into electrical energy by electromagnetic induction are cloaked in cleverly designed covers that supplement the large scale Stripped Classicism design elements of the facility into smaller units. At least three pencil-drawn renderings were made to demonstrate design alternatives that would camouflage the practical features.

It would be helpful to reviewers to understand the architect’s remarkable career. He was a designer for Gilbert Stanley Underwood, a recognized master architect, between the years 1925 and 1932, was a contributor to the Colorado Aqueduct Project (1932-‘41) and Elliott was responsible for the designs of various other water and power plants (see “Experience Record,” Daniel A. Elliott, AIA, Architect at
http://dbase1.lapl.org/webpics/calindex/documents/04/515676.pdf). Elliott designed the Burbank Water & Power Building (1949, 164 W. Magnolia Bl, Burbank) which is a noted example of Late Moderne design, as illustrated by the Los Angeles Conservancy on its website (Explore LA, Historic Places <https://www.laconservancy.org/locations/burbank-water-and-power>). His utility portfolio was described in the “Public Imagery and Its Uses” section of Los Angeles In the Thirties: 1931-1941, which considered an expert source on local architecture during that period (Gebhard and Von Bretton 1989).
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Figure 2: Pencil rendering of Glendale “Steam Electric Generating Plant” by Daniel A. Elliott, AIA excerpted from Initial Study, Architectural Resource Evaluation of The Grayson Power Plant For City of Glendale, California, Figure 9 (page 4.5). Compare with the recent photograph in Figure 3 that shows a series of multi- story, glass block windows in the boiler building portion of the Grayson Steam-Electric Power Plant building. If the crane in the foreground was at the south rather than the north end, the rendering and the power plant as it exists today would appear nearly the same, clearly expressing its distinctive Stripped Classicism design. The design treatment for the endwall in the above rendering was ultimately executed without the cartouche or the inset entrance. It is mistakenly called an “architectural drawing” rather than a rendering in the Initial Study.

The still-recognizable, Stripped Classicism design of the Grayson Steam-Electric Power Plant is understated, exquisitely proportioned and was undeniably futuristic for its time. The three staggered, dimensioned green, horizontal strokes that wrap around the southeast corner skillfully punctuate the otherwise staid building composition and assert the Modernism of the design. At the north façade, left-justified bronze letters on stand-outs primly identify the facility: “City of Glendale Public Service Department Steam Electric Generating Plant.” Most power plans in the 1930s and now have no architectural design imposed reducing their aesthetic effects on the community, which is part of the significance of the Grayson Steam-Electric Power Plant’s design.
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Figure 3: Excerpted, cropped photograph from Initial Study, Architectural Resource Evaluation of The Grayson Power Plant For City of Glendale, California, Figure 18 (page 6.6). View is of the northwest, main façade, no date (estimated 2016). Note the staggered green horizontal bands at the left corner, the sign at the right side, sets of multi-story glass block windows of the boiler portion of the building, original, riveted “Cyclops” crane at left foreground and Units 3, 2 and 1 (left-to-right) in the foreground. The turbine covers for Units 1-3 have radiused roof-wall connections on the main volumes at each endwall, modulating the appearances of otherwise entirely utilitarian structures. Double fillet bands wrap around their lower cornices and corners, emphasizing the carefully expressed scale and proportion.

At the cornice of the main volume, a simple, dimensioned band interposes the roof-wall junctions. The band motif is repeated in pairs on the turbine covers for Units 1-3, the small, utilitarian structures in the foreground on the main elevation. In the design for the Grayson Steam-Electric Power Plant, different volumes are manipulated using varying scale and proportion strategies. The factory-painted, metal exterior of the main tower is clad in small rectangles that together form a grid. The lower, “Boiler Building” main portion of the plant is divided by stacked horizontal scoring lines. The turbine covers for Units 1-5 are painted metal, single-story housings with curved ends and lower, filleted endwalls. The Initial Study cultural resources evaluation mistakenly identified the exterior metal panel material as asbestos, which is likely incorrect as well as needlessly alarming (Figure 20, 6.7). Nearly 15 years after its completion, the unique exterior shell on the turbine covers at Glendale Power Plant was described in Power Plant Management, “the housing is fabricated of steel and is lifted in a piece from over the turbine- generator”(Robert Henderson Emerick 1955). We assert that the Stripped Classicism design of the power plant is an outstanding example of a rare type of architecture, the architect-designed power plant. The Stripped Classicism design should be considered the work of a master architect, Daniel A.

Elliot, AIA (1998-1978). California Register Criterion 3 includes properties that “…represent… the work of an important creative individual.” The Grayson Steam-Electric Power Plant is eligible for listing

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in the California and Glendale Register under each Criterion 3 for Stripped Classicism design and as work of master architect, Daniel Anthony.

The subject property is further significant for its engineering and construction methods. The Grayson Steam-Electric Power Plant was described in the Los Angeles Times as “the world’s first completely earthquake-proof … plant… Among its unique features is the location of the huge turbo-generator on an uncovered deck… the only building is a shell built of light steel and stucco filter walls that will more or less cover the unsightly appearance of boilers.”2 R.R. Martel, a Caltech professor and widely recognized international authority on seismic engineering collaborated on the design. Martel (1890-1965) was among the first engineers in the nation to concentrate on earthquake-resistant buildings and is considered the first in California.3 He was one of two founders of the Earthquake Engineering Research Institute, an independent, nonprofit organization which was established “to promote research on safe and economical earthquake resistant structures” worldwide and continues to thrive, providing that service on an international scale to this day.

Its earthquake-proof structure was prescient for the late 1930s. An engineering periodical by the Earthquake Engineering Research Institute focused on seismic safety “Earthquake Spectra: The Professional Journal of the Earthquake Engineering Research Institute” ran numerous articles specifically describing earthquake-related damage to power plants in the greater Los Angeles area fifty years later, between 1987 and 1994. While the Glendale’s Power Plant is listed in data and tables with plants that sustained significant damage, no damage to Grayson Steam-Electric Power Plant from those events is enumerated. Similarly, “Seismic Experience Data--Nuclear And Other Plants: Proceedings Of A Session” prepared by the American Society of Civil Engineers describes Glendale’s Power Plant remaining “on-line” during the 1971 earthquake, despite its proximity to Sylmar, which was considered the epicenter (1985). We are not saying the subject property building can withstand all earthquakes; in the past it demonstrated superior seismic strength compared to its peers in the Los Angeles area. The Grayson Steam-Electric Power Plant was designed to be “earthquake-proof” before any other facilities of its type were which is overridingly consequential in California engineering. The property possesses significance as the earliest known example of an earthquake-proof power plant in California or anywhere else.

Both the California and the local register recognize construction and engineering innovation. California Register Criterion 3 states “It embodies the distinctive characteristics of a type, period, region, or method of construction; represents the work of an important creative individual.” The Grayson Steam-Electric Power Plant is eligible for listing in the California and Glendale Registers under Criteria 3 and C for its method of early earthquake proof construction. None of those avenues of its significance was addressed in the reconnaissance level survey prepared for the Grayson Steam-Electric Power Plant.

Direct Association with Lauren W. Grayson
The significance of Chief Engineer and General Manger Lauren W. Grayson (1907-1972) is also not adequately evaluated. When Grayson retired in 1970, he had served the city for nearly two decades, expanded water and power capacity by 400 percent and the budget by an even higher percentage during his tenure (“Public Services Head in Glendale to Retire” Los Angeles Times. 25 January, 1970: SG- B2). The visionary civil servant was responsible for bringing together other agencies for collaboration with other such agencies in the northwest. That joint power alliance was considered monumental in the field, and brought electrical capacity diversification, as well as lower costs, to Glendale-based users. He oversaw both water and power utilities, constantly interpreting and planning for future community needs.

2 “Power Plant Built In Open: Glendale Will Have First Completely Quake-Proof Setup.” Los Angeles Times.

June 30, 1940: A10.
3 “R. R. Martel, Professor of Structural Engineering Staff” Engineering and Science, Volume 19, 1956: 22-

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Lauren Grayson was responsible for the addition of cleaner technologies, including a steam- electric generating unit (1965) and the nation’s first gas turbine peaking unit in his final year.

Grayson served as president of American Water Works and California Municipal Utilities associations and was elected American Water Works Man of the Year (1959). He was considered a national leading authority on public utilities and delivered academic papers on a wide variety of utility-based subjects throughout his career. Grayson was published on subjects ranging from visionary long-range planning to the unique needs of car wash and drive-in usage in a number of national and regional industry periodicals, including The American City, Engineering News & Record, Western City and Aqueduct News. Under his leadership, Glendale was one of the first local communities to require subterranean power lines. The Times succinctly described his career at retirement as an “outstanding achievement in the field of water and power” (Don Snyder “Glendale Official: Public Service Chief to End Long Career” Los Angeles Times. 6 July 1970:B9). It was named in his honor in 1972. Mr. Grayson lived in Glendale after 1951 was buried at Forest Lawn. The Grayson Steam-Electric Power Plant is eligible for listing in the California and Glendale Registers under each Criteria 2 for its direct association with Lauren W. Grayson during his period of significant, local utility-related achievements.

The period of significance of the Grayson Steam-Electric Power Plant commenced in 1941 when it was completed and ended in 1970, when Loren W. Grayson retired. Neither the California nor the Glendale Register has requirements that a property be completed more than 50 years ago. For the purposes of National Register eligibility, the period of significance would end in 1967, because it does not meet the requirements in Criterion Consideration G for properties that have achieved exceptional significance in the past 50 years.

Because the California Register Technical Assistance Bulletin 7, is currently under review for updates and revisions, there is no current state guidance for nominating California Register properties and National Register of Historic Places guidance is used in its place. In the National Park Service-prepared National Register Bulletin: “How to Prepare the National Register Criteria for Evaluation” under “Determining the Relevant Aspects of Integrity” for properties associated with important events or persons it states:

A property important for association with an event, historical pattern, or person(s) ideally might retain some features of all seven aspects of integrity: location, design, setting, materials, workmanship, feeling, and association. Integrity of design and workmanship, however, might not be as important to the significance, and would not be relevant if the property were a site. A basic integrity test for a property associated with an important event or person is whether a historical contemporary would recognize the property as it exists today.

Grayson Steam-Electric Power Plant retains integrity to its location. The building remains on the original site where it was completed in 1940. The power plant building’s original Stripped Classicism design is intact, the painted metal panels that camouflage day-to-day operations of the facility, including the three staggered, green bands that wrap around the southeast corner and original signage are visible and recognizable to the general public from the public right of way.

Its setting in an essentially flat yard among other large utility apparatuses has changed over time, reflecting upgrades, increases in capacity and new technologies, but continues to be the basic, recognizable surroundings of a power plant. Its distinctive painted metal exterior materials endure, as do other visible elements from its original design including multi-story glass block banks of windows, awning-type steel sash windows, decorative fillets, metal sign letters, 240 of 296

decorative turbine covers and the essential building configuration. The condition of those materials reflect the passage of 77 years, as should be expected. The fit, finish and connections of those original materials remains impeccable, revealing its inventive, Depression-era workmanship. Because the other aspects of integrity remain intact, the feeling and associations of the Grayson Steam-Electric Power Plant, while somewhat reduced by the additions of new outbuildings and facilities remains. The property maintains its original, intended use, and judging by publicly visible portions of the building, it building retains essential qualities that evoke its aesthetic and historic senses it would have had in 1941 when it was completed.

Despite the enumeration of every new building and feature ever built at the larger surrounding property, National Register guidance clearly states “A property that has lost some historic materials or details can be eligible if it retains the majority of the features that illustrate its style in terms of the massing, spatial relationships, proportion, pattern of windows and doors, texture of materials, and ornamentation.” The Grayson Steam-Electric Power Plant retains its original inventive massing, its essential spatial relationship with the larger yard, the carefully designed proportions, the original, visible, main fenestration, the textures of painted metal, stucco and other materials and its distinctive, austere ornamentation (Figures 2-5) The exhaustive, improperly prepared evaluation for historic significance in the Initial Study expended an inordinate amount of research to justify the misguided point that the power plant has impaired integrity because of alterations. The architect-designed power plant is the resource in question- not the not the entire surrounding yard. The Initial Study ardently describes the addition of switching yards, additional units, cooling tanks and towers, sheds, a warehouse, storage buildings and a garage which are not connected to the Grayson Power Plant and are immaterial to the evaluation of the building. Those non-contributing features comprise the setting of the subject property and do not affect its integrity or significance. To the average reader, hurrying through the document to achieve a basic understanding, their assertion that the power plant is not historically significant would seem well justified. Professionally qualified reviewers who are experienced as performing such evaluations arrive at entirely different conclusions as described in this letter.

We assert that if Lauren W. Grayson, for whom the property was named were able to see the subject property today, he would plainly recognize the Grayson Steam-Electric Power Plant.

Whether or not a person associated with the property during its period of significance is among the National Register thresholds for integrity. It remains clearly recognizable to its original appearance. The addition of buildings, cooling towers, fuel tanks and other equipment is typical of and are necessities to continuously operating a power plant, particularly in a community where its existence made population growth possible. It can be assumed that no public power plant dating from 1941 that remains in operation would be devoid of any alterations made since its completion. Keeping up with requirements, particularly those for life safety require inevitable alterations to buildings and structures. Comparison between the photographs in Figures 3 and 4 as well as others validates that the building is absolutely recognizable to its original design and claims of its loss of integrity are exaggerated and not based in facts. 241 of 296

Figure 4: Grayson Steam-Power Plant Building, view northwest of south endwall, circa 1950s. Source:
https://commons.wikimedia.org/wiki/File:Grayson_Power_Plant.jpg, not for publication.

Figure 5: Excerpt from Initial Study, Architectural Resource Evaluation Of The Grayson Power Plant For City of Glendale, California, undated photograph estimated 2016,(Figure 26 Grayson Boiler Building page 6.10, same view as Figure 4 above). Note all visible awning-type, steel sash windows, exterior materials, the building configuration and Stripped Classicist design remain recognizable. Carport at lower center is an addition (year unknown). Note the stucco scoring bands at the right-hand boiler building tower and the dimensioned continuous sill and header on the left-hand bank of ribbon windows that enunciate the endwalls, providing visual interest and relief. Other than the carport, no alterations are visible.
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A brief review of National Register-listed power plants in the United States revealed that all remaining in use contain non-contributing buildings and structures and that nearly all of the main buildings had been altered.4 In Pasadena, the Glenarm Power Plant was determined eligible for the National Register for its associative and design significance, despite hundreds of alterations made to the building and larger power plant complex over time and numerous changes to the building since it was completed in 1928. The very visible, east facing, rear side of the Glenarm Power Plant is entirely concealed by alterations made in the past 20 years. Comparison against like types is one of many tests for significance and the Grayson Steam-Power Plant stacks up favorably against its significant peers in terms of it importance to the development of the community, its design significance, and its retention of integrity. We believe that the Grayson Steam-Electric Power Plant is eligible for listing in the National Register as well as the California and local registers, but the property is not publicly accessible to make site visits and perform a complete, intensive evaluation of its significance.

While the 29-page DPR does provide a narrative paragraph on “Locational Data,” which are normally reserved for properties that have no street addresses, such as archaeology sites in the desert, the evaluation notably does not address the engineering importance of the Grayson Steam-Electric Power Plant.

Previously Recorded Resources
In the Initial Study, the preparers included a list of “previously recorded” built environment resources, mistakenly applying what is normally archaeological methodology to the built environment. Not only does the section not inform the evaluation, it demonstrates their misunderstanding of the task. The absence or presence of built environment resources within a half a mile is not a predicator as it can be in archaeology, of whether or not built environment resources can be expected to be encountered. Moreover, the list provided does not enumerate whether or not the studied properties were found to be significant or not rendering it even less useful.

The only “previously recorded resources” that should be considered in this evaluation would be on the subject property (including any previous evaluations), or would be other power plants against which this property should rightly have been compared. See National Register guidance on “Comparing Similar Properties” in “VIII. How to Evaluate The Integrity of A Property” (National Park Service, “How to Apply the National Register Criteria For Evaluation”) Project Description
We note that the Grayson Steam-Electric Power Plant has a 22-foot deep basement as described in the 1940 Los Angeles Times article, while the proposed project description cites only an eight-foot-depth of disturbance. As described, the additional 14-foot depth of remaining concrete, rebar and whatever other other materials would remain should be proposed removed, which would probably result in an approximately 23 to 25-foot depth of disturbance. The project description and all applicable analyses must be revised accordingly.

4 National Register-listed power plants include: Adams Power Plant Transformer House (Niagara Falls, NY); American Falls Power Plant Transformer House (American Falls, IA); Moran Municipal Generating Station (Burlington, VT); Murray City Diesel Power Plant (Murray City, UT); Pratt Street Power Plant (Baltimore, MD); Power Plant No. 1 (McPherson, KS); Seaholm Power Plant (Austin, TX) and Spaulding Power Plant and Dam (Greely City, NB). The Adams Power Plant Transformer House is no longer is use; its contributing buildings are notably no longer extant. Seaholm Power Plant contained a non-contributing structure when it was listed in the National Register. It has since been redeveloped and is no longer used as a power plant. 243 of 296

CEQA strongly encourages early consultation with interested or affected parties, which includes local historic advocacy groups. No consultation efforts were made with TGHS. We were asked for information early in the process but have not otherwise been consulted on the project.

Predicated on the facts and issues presented above, TGHS believes that the Grayson Steam-Electric Power Plant must be re-evaluated for historic significance in a supplementary document and that the Cultural Resources section of the environmental document must be revised to reflect a good faith and more reasoned analysis of the property’s historic significance. We have presented “substantial evidence” for the lead agency to change its conclusion and find that the Grayson Steam-Eclectic Power Plant building is a historical resource for the purposes of CEQA.

Thank you for your consideration.

Sincerely,

Greg Grammer

President
The Glendale Historical Society

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770 L Street, Suite 620, Sacramento, CA 95814 • T: (916) 324 -1541 • F: (916) 322- 0827 • www.hsr .ca.gov

November 3, 2020

Julianne Polanco
State Historic Preservation Officer
Attention: Tristan Tozer
Office of Historic Preservation
1725 23rd Street, Suite 100
Sacramento, CA 95816

OHP Project #FRA_2017_0516_001

Subject: High-Speed Rail Program, Burbank to Los Angeles Project Section – additional information and request for review and concurrence on revised determination of National Register of Historic Places eligibility for Grayson Steam-Electric Generating Station (Grayson Power Plant)

Dear Ms. Polanco:

The California High- Speed Rail Authority (Authority) is continuing consultation with the State Historic Preservation Officer (SHPO) and other consulting parties regarding the Burbank to Los Angeles Project Section of the California High- Speed Rail (HSR) Program. This consultation is undertaken in accordance with the 2011 Programmatic Agreement Among the Federal Railroad Administration, the Advisory Council on Historic Preservation, the California State Historic Preservation Officer, and the California High- Speed Rail Authority (PA). In support of this consultation, the Authority is providing the enclosed documentation:

Updated California Department of Parks and Recreation Site Record Form (DPR 523) for Grayson Power Plant, 2015 (revised 2017)

City of Glendale Community Development Department Comment Letter on the California High-Speed Rail Program Burbank to Los Angeles Project Section Draft Environmental Impact Report/Environmental Impact Statement, August 31, 2020

On December 12, 2016, the Authority provided your office and consulting parties the Burbank to Los Angeles Project Section Historic Architectural Survey Report, which evaluated the eligibility of properties for listing in the National Register of Historic Places (NRHP). In a letter dated May 2, 2019, you concurred with the Authority’s findings, including the Authority’s determination that the Grayson Steam-Electric Generating Station (Grayson Power Plant) in Glendale was eligible for listing in the NRHP.

On August 31, 2020, in response to the circulation of the Burbank to Los Angeles Project Section Public Draft EIR/EIS, the Glendale Community Development Department provided the Authority additional information on the Grayson Power Plant. 245 of 296
Julianne Polanco, November 3, 2020, Page 2

The information provided included an updated DPR form for the Grayson Power Plant recommending the power plant ineligible for listing in the NRHP. The DPR form provided information previously unknown to the Authority including documentation of substantial physical alterations to the power plant that have diminished its integrity and ability to convey its historical significance. The Authority has reviewed the additional information, has reevaluated its previous NRHP eligibility determination, and now considers Grayson Power Plant ineligible for listing in the NRHP.

REQUEST FOR CONCURRENCE

The Authority is requesting SHPO concurrence with the determination that Grayson Power Plant is ineligible for listing in the NRHP. While the PA does not specify review duration for NRHP reevaluations, we respectfully request your response within 30 days of receipt of this submittal.

By copy of this letter, this report is also being transmitted to the Burbank to Los Angeles Consulting Parties for review and comment. If you require any additional information, please contact Jeff Carr by phone at (213) 443-7458 or by email at [email protected]. Thank you very much for your ongoing assistance with this undertaking.

Sincerely,

Brett Rushing
Cultural Resources Program Manager
California High-Speed Rail Authority
(916) 403-0061
[email protected]

Encl: Updated California Department of Parks and Recreation Site Record Form (DPR 523) for Grayson Power Plant, 2015 (revised 2017)

City of Glendale Community Development Department Comment Letter on the California High-Speed Rail Program Burbank to Los Angeles Project Section Draft Environmental Impact Report/Environmental Impact Statement, August 31, 2020

cc: Stephanie Perez, Federal Railroad Administration
Sarah Stokely, Advisory Council on Historic Preservation David Navecky, Surface Transportation Board
Danielle Storey, U.S. Army Corps of Engineers, Los Angeles District Claudia Harbert, Caltrans District 7
Ken Bernstein, Office of Historic Resources, Los Angeles Department of City Planning Steve Fox, Southern California Association of Governments Adrian Scott Fine, Los Angeles Conservancy
Erik Krause, City of Glendale Community Development Department

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August 31, 2020

Mr. Mark McLoughlin
California High-Speed Rail Authority
770 L Street, Suite 620 MS-1
Sacramento, CA 95814
[email protected]
On behalf of the City of Glendale (City), we are providing comments on the California High Speed Rail (HSR) Authority’s “California High-Speed Rail Project, Burbank to Los Angeles Project Section Draft EIR.” (Project).
1 We understand, GPA Consulting prepared a Historic Architectural Survey Report (Report) for the Project which was completed in March 2019. Using the HSR Section 106 Programmatic Agreement in the Cultural Resources Technical Memorandum #1, GPA defined the Project Area of Potential Effect (APE) based on the November 2018 footprint. Through delineation of the APE, the City of Glendale’s Grayson Power Plant (Power Plant) was included within the defined APE.

We recognize the Power Plant had no listings for previous studies and no historical determination under any criteria for either the National Register of Historic Places (NRHP) or California Register of Historical Resources (CRHR). Therefore, the Power Plant was surveyed and recorded by GPA on a DPR-523 Series Form in which they identified the boiler building as being constructed in 1941. GPA recommended
“…the main building located at 901 Fairmont Avenue2 meets the criteria for listing in the [NRHP] and the [CRHR] as a locally significant example of a property associated with developmental history of power generation in Glendale under NRHP Criterion A and CRHR Criterion 1, with a period of significance of 1941-1955 (its years of operation prior to the redevelopment of the Grand Central Air Terminal to the Grand Central Industrial Center).” We understand that, based on this recommendation, the EIR considers the Power Plant to be an historical resource for the purposes of CEQA. GPA’s prepared DPR-523 Form included a detailed physical description of the Power Plant, as well as, a short historic context, brief property history, historical photographs, and aerials, limited contemporary photographs from the public right-of-way, and full evaluation per the NRHP and CRHR criteria. Based on their data, GPA considered the Power Plant a California Historical Resource Status Code of 2S2, which represents “Individual property determined eligible for [NRHP] by a consensus through Section 106 process. Listed in the [CRHR].” On October 9, 2018, the “California High-Speed Rail Authority, Burbank to Los Angeles Project Station Historic Architectural Survey Report” was submitted to the California State Historic Preservation Officer (SHPO) for review. The report was reviewed and revised multiple times, in October 2018, March 2019,

1 California High-Speed Rail Project, Burbank to Los Angeles Project Section, State Clearing House 2014071073, https://ceqanet.opr.ca.gov/2014071073/2 (accessed 8/29/2020). 2 The correct address is 800 Air Way.
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and on April 3, 2019, for a final SHPO review and concurrence.3 On May 2, 2019, Kathleen Forrest, acting on behalf of California SHPO Julianne Polanco , concurred with the findings presented in the April 2019 submittal. This included the finding that the Grayson Power Plant is eligible for the NRHP as a locally significant example of a property associated with developmental history of power generation in Glendale under NRHP Criterion A.4
In 2016, prior to the High Speed Rail Study, the City of Glendale contracted, Stantec Consulting Services Inc. to prepare a Historic Resources Inventory and Evaluation Report (attached) and DPR-523 Forms for Grayson Power Plant in support of an EIR (Grayson Repowering Project) on the Grayson Power Plant. In 2018, this report was revised to reflect comments received during the public review of the draft EIR and preparation of the final EIR. The report documents the entire property, rather than just the boiler buildings. The 2018 revised report included an introduction with the project location and description, identified APE for the redevelopment project, team qualifications, research and field methods, and an in-depth historic context which covers the history of electricity in California, steam generation in Los Angeles County, Glendale history, and the history and evolution of the power plant.

Additionally, the report included an in-depth discussion of the power plant, boiler building, boiler units, cooling towers, switchyards, as well as adjacent and new construction. The extensive written documentation was supported by photographic documentation, crucial for identification of property modifications and included tables chronologically illustrating modifications, citing building information provided by the City and through aerial photography to show change over time. The property includes an evaluation of potential eligibility for the NRHP, CRHR, and the City of Glendale Register based upon full evaluations per the applicable significance criteria.

The 2018 effort recommended the Grayson Power Plant not eligible for listing on the NRHP, CRHR, or the Glendale Register of Historic Resources. The report found the Grayson Power Plant significant under Criteria C and 3; however, it lacks sufficient integrity to convey that significance. The report states:
“The Grayson Power Plant property as first constructed in 1941 represented the designs of the 1920s, this was soon realized as the plant underwent numerous upgrades and additions through the 1940s, 1950s, 1960s, 1970s, and 1980s to keep pace with the larger, semi- outdoor boiler types that proliferated across California in the 1950s and 1960s. Therefore, Grayson Power Plant is ineligible, under NRHP Criteria A, CRHR Criterion 1 and GRHR as it is not associated with important events in national, state, or city history, or exemplifies significant contributions to the broad cultural, political, economic, social, or historic heritage of the nation, state, or city. Rather, the plant is a continuation of electrical generation themes in a city that had been using electricity for 32 years…. There is no evidence that Grayson Power Plant has any important association with any person or persons who made significant contributions to history at the local, state, or national level. The power plant is not eligible

3 Brett Rushing, Cultural Resources Program Manager for the California High-Speed Rail Authority to Kathleen Forrest, State Historic Preservation Officer California Office of Historic Preservation re: “High-Speed Rail Program, Burbank to Los Angeles Project Section (FRA_2017_0516_001), request for review and concurrence on revised Historic Architectural Survey Report; Notification of Modification to the Area of Potential Effects,” April 3, 2019. 4 Julianne Polanco, SHPO to Brett Rushing, Cultural Resource Program Manager for the California High-Speed Rail Authority, re: “Historical Architectural Survey Report (HASR) Burbank to Los Angeles Project Section High-Speed Train Project, County of Los Angeles, California,” FRA_2017_0516_001, May 2, 2019. 248 of 296
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under NRHP Criteria B, CRHR Criterion 2 or for the GRHR… An article noted its design as earthquake resistant meaning its generators were located outside on a concrete foundation that was resistant to earthquakes with metal coverings to protect it from weather. R.R. Martell noted earthquake engineer consulted on the project stating the generator could be constructed outside the main boiler building. Through time the power plant has withstood earthquakes, as have other power plants with varied designs. This design is important in the greater advancement of power plant designs. Unfortunately, multiple additions and modifications have degraded its integrity and it can no longer convey this significance under NRHP Criteria C or CRHR Criterion 3. As noted, before, the GRHR does not assess integrity. The evolution of earthquake resistant power plant is important to the context of power plant design in California, however it is within the context of Glendale is lessened… The property does not appear likely to yield significant informational associations under NRHP Criteria D, CRHR Criterion 4 or the GRHR as the plant does not yield information important to archaeological pre-history or history of the nation, state, region, or city.
5 It continues, through
…numerous building additions and continued evolution of the property there has been a loss of integrity of design, materials, workmanship, and feeling. The property retains integrity of location, setting, and association. The power plant has not moved, the overall setting has remained industrial, and it maintains its association as a power plant. However, numerous alterations have removed its integrity of design to the original plant conceived by Elliott, materials as the building materials, while similar are different in type and massing from the original section. The plant has lost its association of workmanship as the additions have fundamentally altered the physical characteristics of the building as original constructed in 1941 and finally the plant has lost its original feeling. Aside from the numerous building additions continued addition of non-attached boiler units with modern cooling towers and ancillary buildings have removed the original feeling of the property. Therefore, the building has lost integrity coupled with lack of significance the building is not eligible for the NRHP or CRHR under any criterion.
6 These findings were preliminary and were included in, and frame the discussion in, the City’s EIR for the proposed redevelopment Grayson Repowering Project. The EIR concluded that the proposed Project would not result in potentially significant and unavoidable environmental impacts relating to historical resources.

The City has recognized some data gaps and/or inaccuracies in the GPA preparation; of importance is that the GPA study mischaracterized the period of significance, 1941-1955, as it correlates to the identified historic property. The earliest iteration of the boiler building dates to 1941; however, the building identified by GPA was constructed between 1941 and 1964, with a significant portion of the building constructed between 1959 and 1964. This is relevant because the modifications, would constitute a loss of integrity as most of the building was constructed after 1955. 5 Stantec Consulting Services (Stantec), Historic Resources Inventory and Evaluation, Grayson Power Plant, City of Glendale, California 2016, (revised 2018).
6 Stantec, Historic Resources Inventory and Evaluation, Grayson Power Plant (revised 2018). 249 of 296
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The map in the DPR-523 Building, Structure, Object (BSO) Form identifies the “NRHP-Eligible Historic Property Boundary highlighted in white.” GPA expands stating “The boundaries of the historic property are limited to the main building. The later additions, such as the modern buildings and infrastructure as well as the replaced steam turbines, do not contribute to the property because they were most likely constructed outside the period of significance, 1941-1955, at which point the Grand Central Air Terminal was redeveloped as the Grand Central Industrial Center. This redevelopment incited major alterations throughout the subject property, bust most noticeable the northern portion of the property which was formerly part of the airfield.”
The challenge is, the identified property was constructed between 1941 and 1964, not 1955. The original boiler building which housed Unit 1 was completed in 1941, with Unit 2 added in 1948. In 1953 the building was expanded to accommodate Unit 3, with the design remaining consistent with the original building. Between 1959 and 1964 a multi-story addition on the north end of the building was added to accommodate Unit 4 in 1959 and Unit 5 in 1964. Additions to the property continued with Unit 6 in 1972 and Unit 7 in 1974, they were separate structures constructed north of the main boiler building.

Up until 1959, the Power Plant remained a single-story-structure. In 1959, the addition of Unit 4 and 5 resulted in the much larger and taller structure which remains today. Despite these alterations, GPA inaccurately states that the “main building marked by signage stating ‘City of Glendale Public Service Department Steam Electric Generating Plant,’ retains integrity of location, materials, design, workmanship, feeling, and association; however, the integrity has been diminished by ongoing development on the site and in the area since the property’s construction according to historic aerials maps.”
GPA provides that the entire building identified dates from 1941 to 1955 and that it retains the integrity of a building competed in 1955, when in actuality a significant portion of the building dates from 1959 to 1964. These modifications should have been identified as a loss of integrity as the building clearly no longer retains the design, materials, and workmanship of a building constructed between 1941 and 1955. With this, the loss of four of the seven aspects (setting, design, materials, and workmanship), they could have concluded the building was significant under Criteria A and 1, but because of a loss of integrity unable to convey this significance and thusly ineligible for the NRHP and CRHR.

Additionally, the historic context considered in the GPA study does not address the significance of this end date. By choosing 1955, it would suggest that the Power Plant’s significance is derived to its association with the Grand Central Air Terminal. However, there is no historic context to support this assertion; the airfield was developed in 1928, whereas the Power Plant was constructed 13 years later.

In addition, the report states that it retains all aspects of integrity, despite the Power Plant having undergone multiple additions since the original plan construction in 1941. Most notably, the GPA report does not include the fact that the two story-addition was added in 1959, with ongoing work occurring into 1964. Given this, the structure cannot convey its significance from 1941 through 1955 since the northernmost portion of the building is an addition constructed outside the identified period of significance, 1941-1955.

A detailed review of the 2016 DPR revealed the evaluation conducted GPA does not address several key aspects in developing a proper historic resource evaluation, as outlined in National Register 250 of 296
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Bulletin No.15. Primarily, the historic context included in the DPR-523 Form is largely incomplete, and does not provide sufficient information to form the basis for an accurate historical significance evaluation of the property, specifically under Criterion A/1 for the property’s association with the Grand Central Air Terminal, nor does it fully support the assertion that construction of a steam plant benefited the region. It does not explain the history of electrical generation in the region or place the construction of the Grayson Power Plant within that context. Second, the GPA report does not provide a well- developed analysis of historical integrity. While the report does provide a cursory list of alternations, which appear to be based upon the included historic aerials, it does not identify or account for many of the modifications to the property, which largely occurred outside the period of significance. This does not adhere to the integrity analysis outlined in National Register Bulletin No.15.

We ask the HSR Authority, given this new information, to reconsider the previous determination. We ask that, based on the lack of integrity through multiple additions from 1959 through 1964, outside the GPA period of significance, the authority find Grayson Power Plant ineligible for listing on the CRHR and as a historical resource for the purposes of CEQA. Further, we ask the Authority reconsult with SHPO regarding the property’s status on the NRHP.

S
incerely,
Eri
k Krause
Deputy Director of Community Development
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P1. Other Identifier: ____
DPR 523A (9/2013) *Required information
State of California - The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI #
PRIMARY RECORD T rinomial
N RHP Status Code 6Z
O ther Listings
R eview Code Rev iewer D ate
*P2. Location: Not for Publication  Unrestricted *a. County Los Angeles and (P2c, P2e, and P2b or P2d. Attach a Location Map as necessary.) b. USGS 7.5' Quad Burbank, CA
Date 2015 T 1N; R 13W Sec 7 S.B. B.M.
c. Address 800 Air Way City Glendale Zip 91201
d. UTM: (Give more than one for large and/or linear resources) Zone, 10S 382154 mE/ 3780132 mN e. O
ther Locational Data: (e.g., parcel #, directions to resource, elevation, decimal degrees, etc., as appropriate) From downtown Glendale, travel 2.3 miles west on Elk Avenue to San Fernando Road, proceed northwest of 2.8 miles on San Fernando Road to Flower Street. Travel southwest on Flower Street to Air Way, the power plant is located on Air Way at the convergence of the Los Angeles River and Fairmont Avenue. APN: 5593-003-906. *P3a. Description: (Describe resource and its major elements. Include design, materials, condition, alterations, size, setting, and boundaries) G
lendale Water and Power’s Grayson Power Plant is a steam electric power plant located in Glendale, CA. The approximately 11-acre property is bounded by Union Pacific Railroad tracks and San Fernando Road to the northeast, Fairmont Avenue to the southwest, south, and southeast. The property contains numerous elements of power generating infrastructure including a boiler building with nine boilers, generators, five cooling towers, two switch yards, an d multiple auxiliary buildings amounting to a
pproximately 17 permanent buildings and structures (Photograph 1) (see Continuation Sheet). *P3b.Resource Attributes: (List attributes and codes) HP8 – Industrial Building, HP11 – Engineering Feature *P4. Resources Present:  Building  Structure Object Site District Element of District Other (Isolates, etc.) P5b. Description of Photo: (view, date, accession #)
Photograph 1: Grayson Power Plant, camera
facing southwest, August 17, 2015.
*P6. Date Constructed/Age and Source:
 His toric Prehistoric B oth
1941, Glendale Water and Power
*P7. Owner and Address:

City of Glendale, Glendale Water and Power
800 Air Way
Glendale, CA 91201
*P8. Recorded by: (Name, affiliation, and address)
Meagan Kersten and John Terry
Stantec, Inc.
555 Capitol Avenue, Suite 650
Sacramento, CA 95814
*P9. Date Recorded: August 17, 2015
*P10. Survey Type: (Describe) Intensive
*P11. Report Citation : (Cite survey report and other
sources, or enter "none.")
Historic Resource Inventory and Evaluation Report, Grayson Power Plant, Glendale, CA, Stantec, 2015 (Revised 2017) *Attachments: NONE Location Map Continuation Sheet Building, Structure, and Object RecordArchaeological Record District Record Linear Feature Record Milling Station Record Rock Art Record Artifact Record Photograph Record Other (List):

P5a. Photograph or Drawing (Photograph required for buildings, structures, and objects.) 252 of 296

*Resource Name or # (Assigned by recorder) Grayson Power Plant *NRHP Status Code 6Z

DPR 523B (9/2013) *Required information
State of California - The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI#

BUILDING, STRUCTURE, AND OBJECT RECORD
B1. Historic Name: Glendale Public Service Department, Steam Electric Generating Plant B2. Common Name: Grayson Power Plant
B3. Original Use: Power Plant B4. Present Use: Power Plant *B5. Architectural Style: Streamline Moderne
*B6. Construction History: (Construction date, alterations, and date of alterations) Grayson Power Plant was constructed in 1941 with additions added to the main boiler building in 1952, 1963, 1972, and 1977. The site has continuously evolved as technology changed and more units were brought online (see detailed history below) *B7. Moved? No Yes Unknown Date: Original Location: ___________ *B8. Related Features: none
B9a. Architect: Daniel A. Elliott b. Builder: Glendale Public Service Department *B10. Significance: Theme n/a Area n/a
Period of Significance n/a Property Type n/a Applicable Criteria n/a (Discuss importance in terms of historical or architectural This intensive level survey and evaluation finds that Grayson Power Plant, while significant, lacks integrity to convey this significance for listing in the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR) or Glendale Register of Historic Resources (GRHR). The property has been evaluated in accordance with Section 15064.5(a)(2)- (3) of the California Environmental Quality Act Guidelines (CEQA), using the criteria outlined in Section 5024.1 of the California Public Resources Code and does not appear to be a historical resource for the purpose of CEQA (see continuation sheet).

B11. Additional Resource Attributes:
(List attributes and codes) _________

*B12. References: See footnotes

B13. Remarks:

*B14. Evaluator:

Corri Jimenez and
Garret Root, Stantec Inc.
*Date of Evaluation: December 2015
and December 2017

This space reserved for official
comments.

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DPR 523J (9/2013) *Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial

CONTINUATION SHEET
Property Name: Grayson Power Plant

P3a. Description (Continued):

Grayson Power Plant’s boiler building faces southeast, on a northwest -southeast axis and massing is predominantly rectangular divided into three levels and each elevation asymmetrical (Photograph 2 and 3).

Architecturally, the boiler building is 2 -3-stories high and is framed with structural steel set on a poure d concrete pier foundation ( Photograph 4). The lower floor extends up a floor level on a poured concrete structure with a steel-framed superstructure set on top of the concrete walls; a second steel-framed structure is set on the northwest corner, which houses Unit 3. Streamline Moderne character-defining details are evident as linear lines in the cementitious paneling, illuminating stringcourses on the building’s upper southeast corner addition, added during a 1953 expansion to building for Unit #3.

The building has a flat roof with metal coping at the top. The exterior of the building is clad with multiple building materials that include horizontal asbestos siding and horizontal metal sheathing that are bolted to the steel framing. The cementitious siding are visible on the interior of the building as well. A Streamline Moderne style-rolling directional crane, which services the boilers, turbines, and generators, is located on the northeast elevation. Each of the five turbines is covered with a Streamline Moderne enclosure (Photograph 5). Copper box lettering in the same style are located on the corner and state: “CITY OF GLENDALE/PUBLIC SERVICE DEPARTMENT/STEAM ELECTRIC GENERATING PLANT” (see Figure 20-21). The northeast elevation of the building has a dock with boilers and equipment located on the northwest elevation (Photograph 6). The northwest elevation is where all the mechanical equipment and numerous boiler stacks for Boilers 1, 2, and 3.

New equipment is evident for Boiler Unit #3 on the northwest corner.

Multiple openings punctuate the elevations of the boiler building on all elevations. The boiler building retains its original windows, which include structural glass blocks on the northeast elevation a nd metal-framed industrial awning windows on the southeast elevation (Photograph 7). Currently the building houses six boilers and is centrally located near the control room. The interior of the building is open with a catwalk or mezzanine floor of metal grating constructed on the west wall in operating the power equipment that include the boilers above and turbines, which attached to the concrete floor platforms. The corresponding boiler stacks and scrubbers are located on the exterior of building along the west wall (Photograph 8).

The Grayson Power Plant had eleven boiler units with seven intact. Units 1 and 2 are located within the boiler building and have been mothballed. Units 3, 4, and 5 are located along the southwest elevation of the boiler building. Units 6 and 7 , built between 1972-1974, have since been demolished. Units 8A, 8B, and 8C, were constructed in 1977 and Unit 9, built in 2003. Units 1 through 4 are housed in the main boiler building with additions. Structures 8A, 8B, 8C, and 9 are located within utilitarian metal structures (Photograph 9 and 10).

Located west of Grayson Power Plant’s boiler units are five cooling towers. Each cooling tower correlates to one boiler. The cooling towers consists of a sub grade water tank is enclosed by two-to-three-foot-thick concrete walls. Each cooling unit has a series of vent stacks. Cooling Towers 1 and 2 are designed with four stacks, which has splayed concrete sidewalls, while Cooling Tower 3 is constructed with six stacks, Cooling Tower 4 has eight stacks, and Cooling Tower 5 with five stacks (Photograph 12, 13, and 14). Additional features of the cooling towers include a louvered wall, which provides air circulation to cool the water from the boilers and wooden roof decks. There are two switching yards, east of the boiler building and are labeled as Kellogg and the Glendale switching yards. The yards are not historic and are not part of this inventory. Five miscellaneous utilitarian buildings are located on the property northwest of the boiler building. These buildings were not inventoried or evaluated as part of this study.
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B10. Significance (Continued):

Historic Context
The Glendale Public Service Department steam electric generation plant, renamed Grayson Power Plant in 1972, was constructed in Glendale in 1941, Since construction the power plant has undergone numerous alterations and expansions. The Streamline Moderne boiler building has more than tripled in size since originally conceived by architect Daniel A. Elliott. Fuel fired steam electric units have been common power generators in California since the 1920s. The design and power output changed dramatically by the end of World War II as municipalities and utilities moved towards semi- outdoor fuel fired steam plant. This reduction in building material cost drove exponential growth in the post -war years, becoming common fixtures across California. The Grayson Power Plant represents a transition in fuel fired power plant design that is more associative with the early 1920s designs rather than the more prominent post-war designs.

Electricity in California
California’s growth in the first half of the twentieth century was due in part to the development of ambitious hydroelectric systems. Long-distance transmission lines linked the power generating mountainous regions with valley farms, coastal centers, and distant cities, allowing a pace and scale of development that was previously unimaginable. By the 1920s, this intricate system of hydroelectric facilities, coupled with a growing number of fuel -fired steam plants, fed into long distance transmission lines and a series of substations that transferred and distributed power to locations throughout the state for widespread public use (Root and Herbert 2013: 1; Department of Energy 2015). Within this burgeoning energy context, the long- distance transmission lines were of vital importance, serving as the nexus between the state’s abundant hydro supplies and the distant urban and agricultural markets. The technological advancement an d development of transmission technology enabled greater and greater supplies of readily available energy, occurring with striking rapidity during the period (Root and Herbert 2013: 1-2).

In the late nineteenth century and into the twentieth, electrical transmission covered small distances, typically limited to tens of miles. During this period, the technological debate raged between two key concepts: Direct Current (DC), championed by General Electric and Thomas Edison, and Alternating Current (AC), champ ioned by Westinghouse and electrical engineer Nikola Tesla (Department of Energy 2015; Williams 1997: 90). The critical limitation to DC was its inability to be transmitted over great distances, as the current could not be converted to higher and lower voltages and rapidly lost energy along any distances. In contrast, Tesla’s AC stepped up voltage for transmission and stepped down voltages for local distribution, creating a system that avoided the energy seepage of DC. Ultimately, Tesla’s vision of AC prevailed and soon transmission lines could carry more power over greater distances, a development that undergirded much of the state and nation’s early twentieth century growth. Rapid innovation during the first decades of the twentieth century allowed for increasingly higher voltages, with heavier insulators, multi-phase lines, and other mechanical methods adapted to carry greater supplies more efficiently, following the adoption of AC. By the early-1910s, California’s hydroelectric industry was carrying hundreds of kV of electrical power over hundreds of miles ( Figure 1) (Root and Herbert 2013: 1 -3; Hayes 2014: 237- 270).

In the 1880s, hydroelectric plants provided small -scale electrical development to only isolated companies, such as Standard Consolidated Mining Company in Bodie, CA and other localized concerns (Hubbard 2006). 255 of 296

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However, by the early 1890s AC technological advancement allowed for a more effective means of transmitting electricity over ever-increasing distances. At the outset of this development, the San Antonio Light and Power Company constructed a 13 mile, 5,000 -volt, transmission line in 1892, with PG&E constructing the Folsom Hydroelectric Plant’s 22 mile, 11,000-volt transmission line in 1895 (Coleman 1952:
138-140). These distances soon gave way to ever larger transmission capability, with Pacific Light and Power Company’s Big Creek Hydroelectric Project running at 150 kV by 1913. Several small companies began constructing independent and local power plants a transmission systems (JRP 2004).

Figure 1. A 1925 map depicting the growth of the transmission system (Vincent 1925). 256 of 296

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Rise of Fuel-Fired Steam Electric
British designer Sir Charles Parsons built the first steam turbine -generator in 1884. At the beginning of the twentieth century, engineers designed steam turbines to replace the aging steam engine power plants.

Aegidius Elling of Norway is credited in 1903-1904 as being the first to apply the method of injecting steam into the combustion chambers of a gas turbine engine (Termuehlen 2001: 11, 21-28; Beck and Wilson 1996:
30). The greater Los Angeles region had multiple examples of early fuel fired steam plants including the Banning Street Electrical Plant in Los Angles completed in 1883, Los Angeles Steam Plant No. 1 constructed in 1896, Pacific Light and Power Company’s steam plant in Redondo Beach was completed in 1902 and the Glenram Power Plant constructed in Pasadena in 1906 (Water and Power Associates 2017; City of Pasadena 2015). Within a relatively short time, the technology and capacity of these engines to supply power and electricity grew exponentially. These advances brought electricity to a wide range of industrial and domestic applications; however, the materials needed to withstand the high temperatures of modern turbines were not yet available. Improvements in steam turbines advanced throughout the 1920s and 1930s, leading to a generation of more efficient turbine power plants in the 1950s. During this time, utilities closed or replaced many of the older steam-electric plant generators and constructed more modern units (Myers 1984: 8).

Steam power generation was part of California’s power production throughout the twentieth century, though it declined considerably in the period leading up to World War II as large hydroelectric generating plants came online throughout the state. As early as 1920, hydroelectric power accounted for 69% of all electrical power generated. In 1930, that figure had risen to 76%, and by 1940 hydroelectric sources provided 89% of California’s electricity. After World War II this trend revers ed and construction of steam -powered electric generating units grew, accounting for most of the new construction. By 1950, hydroele ctricity accounted for only 59% of the total power generated, falling to 27% in 1960. Some new hydroelectric plants were buil t during the 1960s, chiefly associated with federal and sta te water projects, but by 1970, hydroelectric plants accounted for only 31% of all electricity generated in California. A combination of drought, discovery and tapping of natural gas, and lack of new hydroelectric sites led to its decline (Williams 1997: 374).

A persistent drought in California caused the major utilities to question the reliability of systems dependent on abundant water flows, like hydroelectricity. This drought began in 1924 and continued, on and off, for a decade. Concurrently, in the 1920s new natural gas discoveries were made and provided both Northern and Southern California with ample fuel for steam electric power generation.

The confluence of these various
factors – drought, new steam generator technologies, and new supplies of natural gas – prompted California utilities to begin constructing large steam plants. S team plants built across the state shared design characteristics including locations close to load centers to reduce transmission costs, easy and efficient access to fuel supplies, near a water supply, on inexpensive land, and on geological formations that could provide a good foundation (Steele 1950: 17-21). By 1920, the cities of Burbank, Pasadena, Los Angeles, and Glendale restructured their original charters to allow municipality owned power generation facilities and distribution lines (Williams 1997:261; Water and Power Associates 2015 ; Electrical West 1929). In 1928, LA Gas and Electric Corporation constructed the Seal Bach Power Plant and PG&E constructed Station C in Oakland. In 1929, Great Western Power Company built a large steam plant on San Francisco Bay, near the Hunters Point shipyard, fitted with two 55 MW generators. In 1930, fuel-fired steam power plant accounted for more than 257 of 296

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half of all new plants under construction in California. The fuel -fired steam generation capacity jumped from 1924 at 407,000 kW to over 1 million kW a mere six years later. (Williams 1997: 279-280; Ci ty of Pasadena 2015; Burbank Water & Power 2015 ; Water and Power Associates 2017 ; Spencer 1961). These factors prompted many municipalities, like Glendale to construct power plants of their own.

Early Glendale History
By the turn of the twentieth century, Glendale had already experienced rapid growth resulting, in part, from the promotional efforts of Edgar D. Goode and Dr. D. W. Hunt and their Glendale Improvement Society in 1902 (City of Glendale 2012a). The growth continued with the opening of the Pacific Elect ric Railroad in 1904, connecting Glendale to Los Ange les (City of Glendale 2012a). Glendale incorporated in 1906 and by 1910 had a population of 2,742 residents (Glendale News-Press 1953c; Los Angeles Almanac 2015). Power generation in the City of Glendale began in earnest early when the citizens voted in favor of a $60,000 bond to create the Glendale Public Service Di vision that purchased the Glendale Light & Power Company generating facility in 1909. By 1910, the system was already strained as power output was a mere 107,000 kilowatts. To supplement, the city purchased additional electricity from Pacific Power & Light, now part of the Southern California Edison Company (Glendale Public Service Commission 1951).

By 1920, Glendale began annexing neighboring communities boasting the city’s population to over 13,000 residents (City of Glendale 2012b; Los Angeles Almanac 2015). From 1930 to 1952, Glendale added Whiting Woods and Verdugo Mountains to their city limits a total of 23.6 square miles; two major annexations included New York Avenue (in the La Crescenta area) and Upper Chevy Chase Canyon, and several smaller annexations, which enlarged the city to 29.2 square miles by 1952. By 1950 the population was over 95,700 residents and was considered at the time to be “the fastest growing city in America” (City of Glendale 2012b; Los Angeles Almanac 2015). However, by the late 1930s the Glendale Public Service Commission, Electric Division could not keep pace with the population increases (Glendale Public S ervice Commission 1951).

Prior to 1937, Glendale purchased their power from Southern California Edison Company. This supply was supplemented with completion Hoover Dam however, continued growth indicated another plant would be necessary to supplement demand [Glendale News-Press 1953a; Glendale Public Services Department 1974).

Glendale Steam Electric Generating Plant
Building off the success of the 1920s and early -1930s and seeing the impending probability of an outbreak of hostilities, utilities and municipalities began constructing a series of fuel- fired steam plants across California. Northern California PG&E began construction of three, fuel-fired steam -plants located adjacent to oil refineries, in 1939. Southern California municipalities, in Burbank, Glendale (study property), and San Diego each completed power plants, in 1941 (Williams 1997: 279-280). The City of Glendale began planning for construction of a new power plant in 1937. However, the city’s plans were met with immediate opposition by Los Angeles Bureau of Power and Light and the Southern California Edison Company, both which supplied the city with electricity and claimed had surplus electricity which could be sold to the city (Los Angeles Times 1938). Despite these assertions, the city, led by industrial entities pushed forward with their plan for construction of a $1.8 million-dollar plant. The City secured the services of Architect Daniel A.

Elliott to design the power plant , referred as the “Glendale Power & Light” or “Steam Electric Generating Plant” (Figure 2) (LA Conservancy 2015).
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Figure 2. Original Daniel Elliott renderings show the exaggerated streamline moderne details, much of which did not make it onto the building.

Elliott designed the boiler structure in the Streamline Moderne-style, built to house two boilers (Boilers 1A and 1B). Located outside on a full length concrete pedestal were the generators, manufactured by Combustion Engineering Company Inc., New York and with Streamline Moderne detailing. Elliott was born in Las Vegas, New Mexico in 1898. He attended University of California at Berkley, earning an architecture degree in 1925. From 1925 through 1932 he served as a designer at the Los Angeles architecture firm of Gilbert Stanley Underwood before getting his architecture license and becoming an architect at the Metropolitan Water District of Southern California. He remained at the water district from 1932 through 1939. During World War II he worked at Hoover and Montgomery, a firm that specialized in water-related construction projects. Following the end of the war he formed his own architecture practice, one he 259 of 296

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maintained until his retirement in 1962. Principle examples of his work are water focused designs most notably the Colorado River Aqueduct Pumping Plants and F.E. Weymouth Memorial Water Softening and Filtration Plant completed in 1939 (Figure 3 ) and the Burbank Water & Power a dministrative building in 1949 (LA Conservancy 2015; AIA 1956: 155).

Elliott’s original design laid claim to being the world’s first earthquake -proof plant, with a 22 foot deep concrete basement, turbo-generator on an uncovered open deck with a metal covering over the generator from to protect from inclement weather, and a building shell built of light steel and stucco filler walls (Los Angeles Times 1940). At its start -up in 1941, the plant produ ced 20,000 kilowatts of power . The city had already secured funding for a second unit set to be added in 1945 (Lost Angeles Times 1941; Glendale Public Service Commission 1951). To meet increasing demands for electricity, a second unit was added in 1947, which included an additional 20,000 -kilowatt generator and single boiler increasing the plant’s combined kilowatt capacity of 40,000 kilowatts (Glendale News Press 1953e; Glendale News Press 1953f; and Glendale Public Service Commission 1951).

Figure 3. Top, the 1939 Metropolitan Water District of Southern California Water Softening Plant in La Verne and below the Burbank Water Light and Power Administration building built in 1949. 260 of 296

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As demand increased a third unit were added in 1953, which constituted the first of several additions to the boiler building on its north end; the third unit at the plant was completed at a cost of over $3 million. The integral furnace boiler and superheater steam boiler was manufactured by the Babcock & Wilcox Company and the turbine generator by General Electric. The company of Foster & Wheeler constructed the cooling tower and provided the condenser for Unit 3. Unit 3 also utilized the most up-to date engineering replicated in fuel-fired plants across California. The turbine for Unit 3 is located outside the main building under a removable housing (Glendale News Press 1953e).

California utility companies’ steam generating capacity expanded dur ing the period of 1950 through 1970.

PG&E operated 15 steam electric plants in 1950 . Conversely, Southern California utilities built large steam plants at a much slower rate than with Northern California, constructing the Valley Steam Plant in 1953 and Scattergood Steam Plant in 1957. By the late 1970s, there were more than 20 fossil fuel steam-generatin g plants in California owned by various power companies and clustered near urban areas such as San Francisco Bay, the greater Los Angeles area, San Diego County, along with a few interior plants in San Bernardino, Riverside, and Imperial Counties. Happening concurrently, in the mid-1960s large scale intertie projects such as the 500 kV California Oregon Intertie (also known as Path 66) were completed. Additionally, utility companies began to pool their resources, creating a larger interconnected grid. Dictated by Federal power policy, utility companies came together to form bulk transmission entities. In 1967, the Western Systems Coordinating Council formed, consisting of 40 p ower systems located in western states and remained in existence until 2002 when it merged with three regional transmission associations forming the Western System Coordinating Council (WSCC). In addition to WSCC in the mid -1960s was the California Power Pool. This entity gave rise to the current California Independent Service Operator (CAISO). These large intertie projects brought the death of independent, locally sourced electricity as CAISO and its predecessors controlled operation of the various plants (Transmission Agency of Northern California 2017; Water and Power Associates 2017); Southwest Builder and Contractor 1962).

Between 1953-54, the plant generated a total of 122,649,440 kilowatts per hour, supplemented by electricity generated at Hoover Dam, supplied all the power needed for the City (Glendale Public Service Commission 1951). Five more units were constructed after 1953 including Unit 4 (1959), Unit 5 (1964), Unit 6 (1972), and Unit 7 (1974). The boiler for Unit 4 was manufactured by Riley Stoker Corporation; Unit 6 was manufactured by General Electric; and Unit 7 by the Curtiss -Wright Company. Units 1 through 3 maintain Elliott’s the style aesthetics, however the structure shape and detailing shifts with the addition of Units 4 & Unit 5, to a significantly taller, less detailed utilitarian structure that we see to the north. As the building was expanded north, lower level fenestration of the first three phas es was repeated but without the vertical glass block panels. Little significant architectural detail was included in Unit 4 & Unit 5’s building expansion. In 1972 The plant was renamed the “L.W. Grayson Steam- Electric Generating Station” after the City of Glendale General Manager and Chief Engineer, Lauren W. (L.W.) Grayson who at the time was the longest serving employee. Grayson accepted a position at the City of Glendale in 1951 (City of Glendale 1972; Glendale News-Press 1972). His most notable achievement was in bringing power to Southern California through the Pacific Northwest Intertie (Glendale News-Press 1972).

Unit 8 (Unit 8A, 8B, and 8C) was constructed in 1977 and was one of the last to be installed at the power plant and the most efficient of the group while producing fewer emissions than the earlier generators at the plant (Cook 1977). Initially, it was called a “combined cycle repowering unit” in producing more energy and fewer emissions with conventional units that provide better combustion controls and higher efficiency 261 of 296

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(Cook 1977). The new system cost $20 million dollars and at the time, lesse ned air pollution (Ralph 1977).

Further environmental improvements to the plant resulted from the construction of a phosphate removal and treatment plant in 1978. The treatment plant was connected to the steam plant by a pipeline, which directly pumps the reclaimed water into the Grayson Power Plant’s cooling towers (Rees 1978). In addition, since 1994 the plant has utilized methane gas from the Sc holl Canyon Landfill mixed with natural gas to generate power in Units 3, 4, and 5 (Scholl Canyon Landfill 2015).

Continuous improvements in efficiency and power generation capacity have been one of the priorities at the Grayson Power Plant throughout its history including the construction of a new 50 megawatt power generator was completed in 2004, at a cost of $33.5 million dollars, replaced two of the older, outdated units.

The new structure consists of a generator, a gas turbine and compressor, and an emissions control tower to filter out pollutants throughout the system. The generator runs entirely on computers and operates during peak hours (Moskowitz 2004).

In July 2010, a fire at Cooling Tower 3 caused severe damage to the structure, although service was not effected (Wells 2010). Repairs to other portions of the plant included the replacement of the superheater tubes in Boiler No. 4 in 2001, wall tubes in Boiler No. 4 in 2011, an upgrade of the burner management and boiler control systems, also i n Unit 4 in 2011, among other updates (City of Glendale 2011). According to the City of Glendale, California Report to the City Council in April 2014, the boilers for Units 1 and 2 have been mothballed (City of Glendale 2014). In 2015, the Glendale City Council commissioned plans to upgrade Grayson Power Plant to make the plant more efficient, reliable and cost effective. According to the June article in the Glendale News-Press, seven of the eight turbines would be decommissioned and replaced by 4 more efficient turbines, which would be able to produce power more quickly (Mikailian 2015). Currently the power plant generates approximately 18% of the power needed for the City of Glendale with the remaining power coming from a combination of both local and r emote generation (owned and leased), coupled with spot market purchases from a variety of suppliers throughout the Western United States (Mikailian 2015).

Evaluation
Glendale’s Grayson Power Plant served as a regional power source since construction. While the power plant has maintained this role, it has not directly contributed to the early growth of the city, further it only supplemented electricity supplied by other utilities and by the 1937 constructed Hoover Dam. The power plant did supply the re gion with localized power, however, it is just a continuation of existing power supplies. By the time the power plant came online, in 1941, the city had been electrified for 32 years. Further, articles exaggerated the need for a localized power plant to su stain growth. Supply was high, the city , understandably preferred control of their own power supply. California, like much of the west had begun interconnection a series of previously independent transmission systems into an interconnected grid. When originally conceived, the plant would provide a localized source of power, however by the 1940s the state had already begun interconnection. Further, fuel-fired steam plants were well established across California by 1941, that utilized proven technologies. The Grayson Power Plant as first constructed in 1941 represented the designs of the 1920s, this was soon realized as the plant underwent numerous upgrades and addition s through the 1940 s, 1950s, 1980s, 1970s, and 1980s to keep pace with the larger, semi -outdoor boiler types that proliferated across California in the 1950s and 1960s. Therefore, Grayson Power Plant is ineligible, under NRHP Criteria A, CRHR Criterion 1 and GRHR as it is not associated with important events in national, 262 of 296

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state, or city history, or exemplifies significant contributions to the broad cultural, political, economic, social, or historic heritage of the nation, state, or city . Rather, the plant is a continuation of electrical generation themes in a city that had been using electricity for 32 years.

There is no evidence that Grayson Power Plant has any important association with any person or persons who made significant contributions to history at the local, state, or national level. It was designed to supplement and create a localized power source that involved several key institutions and individuals.

Research did not reveal any notable figures specifically associated with the alignment or its related infrastructure, and research did not indicate the potential for significant associati ons in this regard. While the power plant is currently named Grayson Power Plant for L.W Grayson, a longtime Glendale employee.

The name change, occurred in 1972, was in recognition of Grayson 19 years of service to the city. Grayson was important in management of the city but had no association with development, construction, or early operation of the plant. The power plant is not eligible under NRHP Criteria B, CRHR Criterion 2 or for the GRHR.

The subject property is not eligible for NRHP Criteria C, CRHR Criterion 3 nor the GRHR. Grayson Power Plant when originally constructed as a small, two-unit boiler house with Streamline Moderene styling. Since originally constructed, the power plant main boiler building has undergone numerous additions and alterations. These additions , mimic Elliott’s design but with each addition are farther removed from the original (Figure 4 and 5).

Figure 4. Glendale Steam Electric Power Plant Property in 1944.

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Figure 5. A graphic showing the numerous plant modifications since construction in 1941. The information is overlaid on a 1976 aerial with changes noted on historic aerials in 1944, 195, 1960, 1965,1971, and 1976.

Daniel Anthony Elliott, who is arguably a master architect. His noteworthy designs focus on water related infrastructure including the Colorado River Aqueduct Pumping Plants and F.E. Weymouth Memorial Water Softening and Filtration Plant completed in 1939 ( Figure 3, above) and later the Burbank Water & Power administrative building in 1949. The F.E. Weymouth Memorial Water Softening and Filtration Plant is the earliest extant example of Elliott’s work, further it is the best example of monumental water and power architecture. Built in a Spanish Revival design, this building exemplifies the style, prominent of the time and best showcases Elliott’s ability to make infrastructure into beautiful architecture. They original design of the Grayson Power Plant followed these design tenants. Elliott used prominent architectural styles on infrastructure. Elliott’s design followed established power plant and substation design principles emblematic of the 1910s and 1920s. Power company architects designed substations and powerhouses in prominent public-building architectural styles like Beaux-Arts and Classical Revival. Urban power houses and substations housed the electrical equipment within buildings in order to accommodate the congested urban surroundings and to buffer the public from the sounds and activities associated with operation. The power plants and substations were constructed to meet both aesthetic and functional mandates (Frickstad 1916). Elliott’s design of the Streamline Moderne power plant is a 1940s continuation of these design principles. Further, the 1941 building designed by Elliott has been manipulated and changed beyond his original vision through multiple building modifications. Further, the F.E. Weymouth Memorial Water Softening and Filtration Plant is far more intact example of his early designs. 264 of 296

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An article noted its design as earthquake resistant meaning its generators were located outside on a concrete foundation that was resistant to earthquakes with metal coverings to protect it from weather. R.R. Martell, noted earthquake engineer consulted on the project stating the generator could be constructed outside the main boiler building. Through time the power plant has withstood earthquakes, as have other power plants with varied designs. This design is important in the greater advancement of power plant designs .

Unfortunately, multiple additions and modifications have degraded its integrity and it can no longer convey this significance under NRHP Criteria C or CRHR Criterion 3. As noted before, the GRHR does not assess integrity. The evolution of earthquake resistant power plant is important to the context of power plant design in California, however it’s within the context of Glendale is lessened.

The property does not appear likely to yield significant informational associations under NRHP Criteria D, CRHR Criterion 4 or the GRHR as the plant does not yield information important to archaeological pre - history or history of the nation, state, region, or city. In contrast, the extant archival record regarding the site presents a wealth of specific and informative material, including maps, photographs, aerials, and building permits that provides significant material for interpretation. Thus, the extant physical structures of the site do not convey significant informational material that would inform t he rather robust archival record regarding the Grayson Power Plant.

The Grayson Power Plant was constructed approximately 60 years after the early development of the City of Glendale and 35 years after the City incorporated electricity in 1906. Due to this passage of time it is not associated with the early heritage of the City and not eligible for listing on the GRHR.

While the GRHR does not account for integrity, both the NRHP and CRHR do. Due to numerous building additions and continued evolution of the property there has been a loss of integrity of design, materials, workmanship, and feeling. The property retains integrity of location, setting, and association. The power plant has not moved, the overall setting has remained industrial, and it maintains its association as a power plant. However, numerous alterations have removed its integrity of design to the original plant conceived by Elliott, materials as the building materials, while sim ilar are different in type and massing from the original section. The plant has lost its association of workmanship as the additions have fundamentally altered the physical characteristics of the building as original constructed in 1941 and finally the pla nt has lost its original feeling. Aside from the numerous building additions continued addition of non -attached boiler units with modern cooling towers and ancillary buildings have removed the original feeling of the property. Therefore, the building has l ost integrity coupled with lack of significance the building is not eligible for the NRHP or CRHR under any criterion.
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Photographs (Continued):

Photograph 2. Grayson Boiler Building, View Looking Northwest (Photo by J. Terry).

Photograph 3. Grayson Boiler Building, View Looking Northwest (Photo by J. Terry). 266 of 296

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Photograph 4. Grayson Boiler Building, View Looking Southwest (Photo by J. Terry).

Photograph 5. Grayson Boiler Building, View Looking Southeast (Photo by J. Terry).

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Photograph 6. Boiler Stacks (Boilers 1 and 2 Center Rear of Photograph; Boiler 3 to Left), View Looking South. (Photo by J. Terry).

Photograph 7. Overview of Basement Floor Level, View Looking North (Photo by J. Terry). 268 of 296

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Photograph 8. View of Boiler 1B, Looking West (Photo by J. Terry).

Photograph 9. Unit 8A, Looking West (Photo by J. Terry).

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Photograph 10. Units 8A & 8B, View Looking Northeast (Photo by J. Terry).

Photograph 12. Cooling Tower No. 2 (No. 1 in background), View Looking Southeast (Photo by J. Terry). 270 of 296

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Photograph 13. Cooling Tower No. 3 (No. 5 in Background), View Looking Northwest (Photo by J. Terry).

Photograph 14. Cooling Tower No. 4, View Looking Northeast (Photo by J. Terry).

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B12. References, Continued.

American Institute of Architects
1956 “E Architects.” American Architects Directory.

Beck, Douglas Stephen and David Gordon Wilson
1996 Gas Turbine Regenerators Chapman & Hall
California Energy Commission
2014 “Database of California Power Plants.” File date May 1, 2014. Accessed November 19, 2015:
http://www.energyalmanac.ca.gov/powerplants/index.html. 2015 “List of Inactive/Retired Power Plants (1915-2004). Accessed on November 19, 2015:
http://www.energyalmanac.ca.gov/electricity/inactive_plants.html.

California Office of Historic Preservation
1999 “California Register and National Register: A Comparison (for purposes of determining eligibility for the California Register).” Technical Assistance Series, No. 6. Sacramento: California Department of Parks and Recreation.

City of Glendale
1972 “Resolution in designating steam plant to L.W. Grayson.” October 10, 1972. 2010 “Approval to Issue a Request for Proposals (RFP) for the Grayson Power Plant Unit No. 3 Cooling Tower Replacement.” Report to the City Council. 28 September 2010. Accessed December 30, 2015 at: http://www.ci.glendale.ca.us/government/council_packets/Reports_092810/CC_5g_092810.pdf .
2011 “Approval to Issue a Request for Proposal (RFP) for the Grayson Power Plant Unit No. 4 Burner Management System and Boiler Control System Upgrade.” Report to the City Council, February 11, 2011. Accessed December 30, 2015 at:
http://www.ci.glendale.ca.us/government/council_packets/Reports_021511/CC_5a_021511.pdf .
2012a Popular Annual Financial Report. June 20, 2012. Accessed December 25, 2015 at:
http://www.glendaleca.gov/home/showdocument?id=9653
.
2012b “Overview of Glendale History.” May 17, 2012. Accessed on December 25, 2015 at:
http://www.ci.glendale.ca.us/history_overview.aspx
.
2012c “How to Get Your Property Listed on the Glendale Register of Historic Resources.” November 2012.

Accessed 25 December 2015 at: http://www.glendaleca.gov/home/showdocument?id=12454 .
2014 Glendale Register of Historic Resources. Updated February 2014. Accessed at:
http://www.ci.glendale.ca.us/planning/HPGlendaleRegister.asp .
2014 “Specification No. 3541 to Provide Mechanical and Field Services for the Grayson Power Plant (GPP).” Report to the City Council. April 29, 2014. Accessed December 30, 2015 at:
http://www.ci.glendale.ca.us/government/council_packets/Reports_042914/CC_5e_042914.pdf .

City of Pasadena
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Property Name: Grayson Power Plant

2015 “Pasadena Water and Power” Accessed on November 19, 2015:
http://cityofpasadena.net/waterandpower/Our_History/.

Coleman, Charles M.
1952 PG and E of California The Centennial Story of Pacific Gas and Electric Company 1852-1952, (New York: McGraw-Hill Book Company, Inc.

Cook, Jack
1977 “Power Plant Director Keeps a Close Watch over Glendale’s Lifeline.” Daily News. Located at the City of Glendale’s Central Library, Special Collection.

Cowan, Robert C.
1977 Ranchos of California a list of Spanish Concessions 1775-1822 and Mexican Grants 1822-1846. Los Angeles:

Published by the Historical Society of Southern California.

Department of Energy
2015 “The War of the Currents: AC vs. DC Power.” Accessed January 30, 2015, http://energy.gov/articles/war-currents-ac-vs-dc-power.

Environmental Data Resources, Inc. (EDR)
2015 EDR Aerial Photo Decade Package: Grayson Power Plant, 800 Air Way, Glendale, California. (Inquiry Number: 443851.9). October 13, 2015.

Frickstad, Ivan.
1916 “ the Development of ‘Pacific Service’ Architecture as Exemplified in Its Modern Power Houses and Substations,” Pacific Service Magazine, 8 no. 6.

Galvin Preservation Associates (GPA)
2007 City of Glendale Reconnaissance Survey and Historic Context Statement of Craftsman Style Architecture 2 006-2007, Certified Local Government Grant. Prepared for the City of Glendale. October 2007 Glendale Public Service Commission
1951 Annual Report of the Public Service Commission. Report on file at the Glendale Public Service Commission.

Glendale Public Services Department
1974 “History.” April 1974. Manuscript on File at the Glendale Public Service Department, Glendale, CA.

Glendale News-Press
1953a “Purchased Power—city Makes Own Energy Since 1941.” November 13,1953, Page 7-C. 1953b “City to Glow—7-yar Light Program Starts.” November 13,1953, Page 5-C. 1953c “More Demand for Energy Anticipated.” November 23, 1953, Page 8-C. 1953d “New Unit Keeps Pace with Science—Third Turbine Uses More Heat, Pressure.” November 13, 1953, Page 3-C.
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Property Name: Grayson Power Plant

1953e “Third Generating Unit—Plant set to Operate Next April.” November 12, 1953. 1953f “Steam Plant Third Unit Completed—20,000 kilowatt hours more energy available.” 1972 “Lauren Grayson, longtime city official, dies.” May 22, 1972.

Hayes, Brian
2014 Infrastructure A Guide to the Industrial Landscape. W.W. Norton and Company.

Hubbard, Steve
2006 “Hydropower in California,” Sacramento History Journal VI JRP Historical Consulting Services
2000 “Water Conveyance Systems in California,” California Department of Transportation Environmental Program/Cultural Studies Office.

LA Conservancy
2015 “Burbank Water & Power Company.” Accessed on December 28, 2015 at:
https://www.laconservancy.org/locations/burbank-water-and-power.

Los Angeles Times
1940 “Power Plant Built in Open: Glendale Will have First Completed Quake-Proof Setup.” June 30, 1940.

Provided to Stantec from ProQuest Historical Newspapers by Greg Grammer of the Glendale Historical Society.

Los Angeles Almanac
2015 “General Population of the City of Los Angeles County, 1910–1950.” Accessed at September 3, 2015: http://www.laalmanac.com/population/po26.htm.

Mikailian, Arin
2015 “Plans Ordered to Redo Facility.” Glendale News-Press, June 6, 2015.

Moskowitz, Gary
2004 “Glendale Gets Power Boost.” Glendale News-Press, April 13, 2004.

Myers, William A.
1984 Iron Men and Copper Wires: A Centennial History of the Southern California Edison Company Trans-Anglo Books
National Park Service
2002 “Bulletin #15, How to Apply the National Register Criteria for Evaluation.” Edited by Patrick W.

Andrus and Rebecca H. Shrimpton. Washington D.C.: National Park Service, National Register Program. Accessed December 30, 2015 at:
http://www.nps.gov/nr/publications/bulletins/nrb15/index.htm .

Nationwide Environmental Title Research, LLC (NETR Online) 2015 Historic Aerials from 2015-1952. Accessed on December 30 2015 at: www.historicaerials.com. 274 of 296

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CONTINUATION SHEET
Property Name: Grayson Power Plant

Perez, Cristotomo
1996 Land Grants in Alta California: A Compilation of Spanish and Mexican private land claims in the State of California. Rancho Cordova: Landmark Enterprises.

Perry, E. Caswell, and Carroll W. Parcher
1981 Glendale Area History. Second Edition. Glendale: Eric Schneirsohn, Xanadu Galleries. Pp. 59-61.

Ralph, Mason
1977 “City Installing New Generators.” Burbank Ledger January 1, 1977.

Rees, Julie
1978 “Reclaimed Water Brings Power to the People.” Glendale News-Press March 31, 1978.

Root, Garret and Rand Herbert
2013 From Sawdust to Uranium: The History of Electrical Power Generation in Humboldt County and Pacific Gas and electric Company’s Humboldt Bay Power Plant 1883-2019. Pacific Gas and Electric Company.

Scholl Canyon Landfill
2015 “Scholl Canyon Landfill.” Accessed August 31, 2015:
http://schollcanyonlandfill.org/#!clients/ServicesPage-bmmaq7o0 Steele, I.C.
1950 “Steam Power Gains on Hydro in California,” Civil Engineering (January 1950). Transmission Agency of Northern California.
2017 “ California-Oregon Transmission Project,” Accessed December 17, 2017. http://www.tanc.us/cotp.html
Spencer, R.W.
1961 “Cooling Water For Steam Electric Stations in Tidewater.” Transactions of the American Society of Civil Engineers
Termuehlen, Heinz
2001 100 Years of Power Plant Development: Focus on Steam and Gas Turbines as Prime Movers. ASME Press.

URS Corporation (URS)
2003 City of Glendale Water & Power Grayson Unit 9 Project: Cultural Resources. Prepared for the City of Glendale. January 2003.

Vincent, Jr, W.G
1925 “The Interconnected Transmission System of California,” Journal of Electricity LIV Water and Power Associates
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CONTINUATION SHEET
Property Name: Grayson Power Plant

2015 “First Electricity in Los Angeles.” Accessed November 19, 2015:
http://waterandpower.org/museum/First%20Electricity%20in%20Los%20Angeles.html. 2017 “Early Power Generation.” Accessed December 17, 2017:
http://waterandpower.org/museum/Early_Power_Generation.html Watts, John T.
1954 “City Started Power Service in ’09.” Glendale News-Press. August 16, 1954.

Wells, Jason
2010 “Fire Breaks Out at Plant.” Glendale News-Press July 16, 2010.

Williams, James C.
1997 Energy and the Making of Modern California. Akron, Ohio: University of Akron Press.

Yamada, Katherine
2008 “Power Plant Still Serves the City Well.” Glendale News-Press November 21, 2008.

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FRANCESCA SMITH

February 13, 2022

Mayor Paula Devine and City Council Members
City of Glendale
633 East Broadway
Glendale, CA 91206
Sent via e-mail

RE: City Council Meeting February 15, 2022, Item 8.c
Comments on Final Environmental Impact Report, Grayson Repowering Project

Dear Mayor Devine and Council Persons:

On behalf of Glendale Residents Against Environmental Destruction (GRAED), I reviewed the Final Environmental Impact Report, Grayson Repowering Project (FEIR, January 20, 2022) and still see many significant shortcomings, errors, omissions and discrepancies with the California Environmental Quality Act (CEQA) requirements and the City of Glendale’s own Historic Preservation Ordinance (Ordinance) in the new document. Those problems include the persistent lack of a supplemental or updated Cultural Resources Technical Report that supports the Boiler Building eligibility as a historic resource, coupled with the Lead Agency’s dogged insistence not to intensively re-evaluate the entire property for local and California Register historic district eligibility to understand its significance; the weak, one-sided discussion of the potential future reuse of the Boiler Building; the unfounded dismissal of a mitigation measure formed to avoid future problems (which might have avoided this protracted eligibility debate); the excessively selective and improper cumulative impacts analysis and failure to follow the required sequence for reviews and approvals by the Historic Preservation Commission directed in the Glendale Municipal Code. Please ensure that this letter is entered in the Administrative Record for this project.

It was amusing to read the descriptions of how the Lead Agency elaborately sequestered their actions to reverse the property’s previous determination of National Register eligibility. The Lead Agency stopped short of admitting that The Glendale Historical Society (TGHS) and its members have been certain of the Boiler Building’s historic significance since at least 2017, and provided that information in research and expert professional opinion presented in letters. That should have been noted and almost certainly would have affected the State Historic Preservation’s opinion. The description further glossed over the fact that California Office of Historic Preservation supervisory staff agreed in 2021, based on information provided by TGHS and its members that the Boiler Building was indeed eligible for the California Register. That reviewer plainly said that that the entire property should rightly be re-evaluated as a historic district, following professional historic preservation practice for any properties that are intensely surveyed. California Office of Historic Preservation supervisory staff went so far as to say that the entire property appeared to be eligible for listing in the National Register of Historic Places based on the information previously withheld by city staff. 278 of 296

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Absence of Supplemental or Updated Cultural Resources Technical Report While the Lead Agency has, at long last, conceded that the Grayson Power Plant Boiler Building is a historical resource for the purposes of CEQA, we continue to assert that no updated Cultural Resources Technical Report was prepared to support those findings. It is not out of “a reasonable abundance of caution” that the Lead Agency is considering the Boiler Building historically significant as portrayed on page xvii; it was because the City had no choice. TGHS and its members proved in 2017 that the Boiler Building was and is historically significant.

Without a thorough and impartial “good faith” re-evaluation of the entire property, which would include its direct connection to the Glendale Switch Rack that was constructed roughly concurrently with the Boiler Building, both the identification of historical resources (which has wasted seven years thus far) and the analysis of impacts on the historical resource are inadequate.

The Lead Agency continues to claim there is no historic district on the subject property. We remind you that state guidance on recording historical resources directs Districts may be recognized and documented at the time a survey is conducted, or they may become apparent only after several survey efforts reveal the historical relationships among the individually recorded resources in a given geographic region… Because the recognition of a district hinges on an understanding of its historic context, evaluation is required on the District Record (“Instructions For Recording Historical Resources” 1995).

Previous evaluations prepared by the Lead Agency’s consultants found none of the properties at Grayson Power Plant to be historically significant (“Neither the Boiler Building nor Grayson Power Plant were identified as contributors to a historic district” pages 4.5 and 7.56 in FEIR). In light of the fact that the FEIR recognizes the Boiler Building to be historically significant, it would be entirely logical that the evaluation was updated and the entire property re-evaluated for the potential for a historic district. Without that complete identification of historical resources on the property and its consideration as a potential historic district that was directly connected to the establishment and development of Glendale as an independent city and as a Pre-War power plant, the analysis of impacts has no foundation or which to base its conclusions.

We note that the “Historic Context” in the FEIR (pages 4.9 through 4.22) is described as “an in- depth historic context which covers the history of electricity in California, steam generation in Los Angeles County, Glendale history, and the history and evolution of the power plant.” That Historic Context contains no references or footnotes, so both its legitimacy as well as its reliability are in question. Without the existence of the subject property, Glendale would not have an independent source of electrical power to enable the growth that occurred since 1941.

As previously stated, because the now FEIR is not even partially based on the results of a supplemental or updated Cultural Resources Technical Report that supports the current findings, the conclusions regarding Cultural Resources impacts are not supported. We strongly recommend that the City comply with CEQA as it relates to cultural resources in that the future environmental clearance documents for this and other projects would include preparation of reliable, unbiased, supplemental, updated information. Those should at minimum re-evaluate the entire property for historic significance, including as a potential historic district. Such a technical report would rely on a more balanced approach, including facts, actual references and its conclusions would not be predicated on alterations made to other parts of the property (as the most recent technical report did), and would fully consider the effect the independent 279 of 296

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power source had in shaping the development of the City of Glendale as well as its architecture, engineering and novel earthquake-resistant design.

Reuse Analysis by Black &Veatch
The “structural review” alluded to, that was “studied to understand [the Boiler Building’s ]… potential for re-use” is inadequate on every level. Firstly, Black & Veatch has no demonstrated experience in historic preservation projects or in the specialized field of structural engineering for historic buildings (https://www.bv.com/search?search=Historic+preservation). Their single example of a previous project hypothetically connected to historic preservation enabled cell phone towers to be built in historic districts in New York (Landmark Sites Wireless Development Services). That project is far different from analyzing a specialized building’s potential for reuse. To emphasize that point, the explanation that “The Boiler Building was designed to older codes and does not meet current Building & Safety codes for seismic safety and would not be acceptable under today’s building standards” on page 7.52 is embarrassing and highlights their inexperience in any such evaluations. At the very least, the City should have explained to their consultants that the California Historical Building Code (Title 24, Part 8) would apply to any projects at this building, and is successfully used throughout the state on all types of resources. Moreover, there is no mention of the type of use proposed, which could well trigger different requirements. There is no mention of any review of the Boiler Building’s structural plans, which demonstrates further inadequacy, and their mysterious report is not appended to the FEIR.

The assertion “with respect to hazardous materials,” that “Stantec also performed a hazardous materials review of the Boiler Building” with descriptions of Transite siding, “significant quantities of asbestos within the building itself in the form of thermal insulation on the piping and boilers as well as insulation on electrical cabling” (page 7.52). Perhaps Stantec’s hazardous materials experts who likely described “Leadbased paints are also prevalent within the building as well as heavy metal contaminants in the Boiler Building fire brick. Equipment that contains PCBs has also been identified in the building” (ibid) are unaware that the Boiler Building has numerous employees who spend long shifts in it every day. It would be more than surprising to learn that none of those sources had been remediated or encapsulated despite the fact that the Boiler Building is in use. Following the fearsome descriptions of those materials, the conclusion is that “All of these hazardous materials will need to be (and can be) safely mitigated and remediated.” So the alarming litany was a needless exaggeration. Hazardous materials exist in most older buildings, many are used as offices, residences, museums and libraries and most were even built using then-applicable older codes.
“Collaboration” between the Lead Agency and The Glendale Historical Society CEQA ensures full public disclosure of the likely impacts of significant projects and provides part of the system through which community members can participate in a meaningful way in environmental review.

On page 5.57, the document asserts that “The City did consult with TGHS although such consultation with TGHS is not mandatory under CEQA.” We note that “Early Public Consultation” as outlined in 14 CCR Section 15083 directs Prior to completing the draft EIR, the lead agency may also consult directly with any person or organization it believes will be concerned with the environmental effects of the project. Many public agencies have found that early consultation solves many potential problems that would arise in more serious forms later in the review process. 280 of 296

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This early consultation may be called scoping. Scoping will be necessary when preparing an EIR/EIS jointly with a federal agency.
(a) Scoping has been helpful to agencies in identifying the range of actions, alternatives, mitigation measures, and significant effects to be analyzed in depth in an EIR and in eliminating from detailed study issues found not to be important. (b) Scoping has been found to be an effective way to bring together and resolve the concerns of affected federal, state, and local agencies, the proponent of the action, and other interested persons including those who might not be in accord with the action on environmental grounds.
(c) Where scoping is used, it should be combined to the extent possible with consultation under Section 15082.

While Scoping is not mandatory, it is considered a “best practice.” TGHS first requested information on the proposed project and copies of Cultural Resources Technical Reports in December of 2015 (e-mail from Greg Grammer, TGHS to Michele Cross, Stantec). No such information was ever provided.

Those discussions were incorrectly described in the PE-EIR and FEIR as “collaboration” which would have meant that the Lead Agency did not pick or choose what its staff would consider to reduce the considerable on-going Cultural Resources problem evidenced in the proposed project. “ The few paragraphs describing those meetings with representatives of TGHS notably contain no records of when those meetings took place, who attended, what was discussed and what, if anything, was agreed. That information is germane to this project’s decision makers and should have been included in more complete detail in future and/or final environmental clearance documents for this project. In those discussions TGHS provided reasonable Mitigation Measures to the Lead Agency that would have ensured problems of this magnitude relating to City-owned historic resources were not repeated in the future (see Attachment 4 and pages 10- 14 of this letter, Cultural Resources Mitigation Measure B- Historic Resources Survey of City- Owned Properties).

On December 15, 2020 the Glendale City Council discussed an Amendment of Contracts with Stantec Consulting Services, Inc. and Black & Veatch Corporation for Additional Professional Services Pertaining to the Limited Notice to Proceed Phase of the Proposed Grayson Repowering Project Alternatives.1 During that item’s public testimony at least one officer of TGHS and two members provided information in that recorded meeting by telephone to decision makers explaining the elaborate circumvention of the eligibility determination made by High-Speed Rail (HSR) for Grayson Power Plant.

Grayson Power Plant was determined eligible for the National Register of Historic Places in 2019. Although the City of Glendale (Lead Agency) was copied on all technical reports as a by- right consulting party, staff took no action until August 31, 2020 after I let them know of the determination via e-mail. At that point the City prepared a letter to HSR outlining the reasons that Grayson Steam-Electric Power Plant should not be considered a historic resource. The 25- page justification included photographs of structures that are not part of the main Boiler Building and notably omitted a map or diagram that would have clarified the locations of those structures (Attachment 1, pages 3-33). In that letter, the City notably excluded any reference to the evidence presented by TGHS and members of the public, including qualified judgment

1 Item 8c from the Agenda at
https://glendaleca.primegov.com/Portal/Meeting?compiledMeetingDocumentFileId=30739. 281 of 296

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establishing that the main Boiler Building was historically significant at both state and local levels (Attachment 2, pages 4-16).

In Attachment 2, TGHS reminded the Lead Agency that “CEQA strongly encourages early consultation with interested or affected parties, which includes local historic advocacy groups.

No consultation efforts were made with TGHS. We were asked for information early in the process [December 2015] but have not otherwise been consulted on the project” (page 17). No consultation effort with TGHS was made by the Lead Agency until January 2021, at the request of City Council, and in the few months following. Rather than collaboration, where both sides listen to each other, those meetings could better be described as a one-way street, where City staff offered carrots but proffered only sticks in return.

Despite TGHS’s demonstrated interest in the proposed project as described above, the non- profit and its representative were not copied on the Lead Agency’s Attachment 2 letter to HSR requesting the property’s National Register determination be overturned. Based on the unnecessarily secretive process and partial information provided by the City in Attachment 1, and absent any information and professional opinions to the contrary provided by TGHS regarding the subject property’s historic significance, the State Historic Preservation Officer (SHPO) concurred with the opinion provided by the City of Glendale based on alterations to separate Cooling Tower structures (1, 2, 3, 4 and Units 8A-C) that the Boiler Building was not eligible for listing in the National Register. TGHS was not ever apprised of the request for reversal of the property’s determination of eligibility until the City Council Meeting Agenda was posted for the December 15 meeting despite demonstrated interest in letters regarding its historic significance.

Notably as well, in that December 15 City Council Meeting, City Attorney staff member Gillian van Muyden asserted to Council that the concurrence letter from SHPO found that the property was “not historic.” That is untrue, as was pointed out by a member of the public at the meeting (see Attachment 3, pages 1 and 2). Also in that meeting, the adopted City Council motion included the provision that City staff meet with TGHS to address the historic significance of the Boiler Building and mitigation for its demolition, and voted to move forward, excluding consideration of “Alternative 7.”
We note that the Glendale Switch Rack, which dates from the same year as the Boiler Building (1941) and was central to the property’s operation as a power plant should be considered historically significant as well (see Figure 1 on page 4). 282 of 296

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Figure 1: Annotated excerpt of Sanborn Fire Insurance Co. map of Grayson Power Plant in 1950. Note the outline of irregularly configured Boiler Building on the left side with three exhaust stacks which remain and extant Glendale Switch Rack on right. Both are highlighted in red. Source: Sanborn Fire Insurance Co. Maps of Glendale, CA Volume 2, updated to October 1950, sheet 299B.

Figure 1, above, depicts the Boiler Building and the functionally-related, and currently extant Glendale Switch Rack in 1950. Review of aerial photographs from the same time period reveal the same relationship between the Boiler Building and Glendale Switch Rack. If the property had been appropriately, impartially evaluated for historic significance impacts and effects, we believe the Glendale Switch Rack and likely other part of the property would likely have been identified as contributing features of what may likely be a National or California Register- eligible historic district.

We assert that in failing to re-evaluate the property it was not analyzed for its engineering significance either. In the first addition to the Boiler Building, its architect, Daniel A. Elliott, AIA extended the main rectangular form and repeated the original bay configuration to the northwest. The Lead Agency should know that addition notably included “the first hydrogen- cooled turbine generation for outdoor use,” which was made possible by the “prevailing moderate weather.”2 The then-novel use of hydrogen to power the turbines allowed the plant to maintain its original design program of a narrow block-like building which housed generating units served by exterior turbine engines. Hydrogen is more efficient transferring heat than air is because it can absorb heat and can thus transfer it another medium. Challenges include maintaining the pure hydrogen, ensuring the pure gas has no air leaks and safety.

2 Electric Light and Power, Volume 18, 1940: 74.
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According to industry news, hydrogen cooled generators became the industry standard, which makes that early instance of its use in Glendale all the more important. 3 At the time of the installation of the unique exterior turbine, the concept of making personnel work outside was the subject of wide debate among professionals in the field. Factors in its favor included reducing the necessary size of the main plant buildings (like the Boiler Building) and the obvious benefits of natural ventilation. Minor drawbacks were the requirement for a deep “basement” as is present in the turbine deck, the excessive noise generated inside small turbine covers and the exposure of employees to the elements. In the 1940s, an industry publication held a competition to assess the practicality of such outdoor turbines. The fact that exterior turbines are now common and hydrogen cooling remains the most widely used application seems to ultimately close the discussion.4

Figure 2: Daniel A. Elliott’s’ early rendering of Glendale Power Plant, with one turbine above steps and the crane at left. The rendering was published in Electric Light & Power with the caption: “Architect’s sketch of the Glendale (Calif.) plant where the first hydrogen cooled turbine for outdoor operation will be installed.” Source: Electric Light & Power, Volume. 18 July 1940: 72.

The regional Postwar residential boom in Glendale was enabled, in part, by the fact that the City had an independent power plant. 5 The City could not have developed as rapidly or as widely as it did in the years after 1941 without its own power plant. “Discretionary” Historical Resource
We note as well that in the FEIR and PR-EIR text, every mention of the single identified historical resource is diluted by repetition of the modifier “discretionary.” That thinly veiled language mannerism, which is a component of CEQA as it relates to historic resources, was repeated more than 50 times in the FEIR. It is intended to lead non-professionals (which will

3 Spring, Nancy. “Hydrogen Cools Well, But Safety is Crucial” Power Engineering . June 1, 2009 and Covertel Power. “How H2 Is Used to Cool Electric Generators” at https://covertelpower.com.au/products-and-services/electrolysers/how-h2-cools-generators/ accessed on June 24, 2021.
4 Maddock, Bill. M.E. “Is the Outdoor Installation Here to Stay?” Power Plant Engineering. United States: Technical Publishing Company, October 1943.
5 Power Plant Engineering. (United States, Technical Publishing Company, 1944): np. 284 of 296

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include most of the public, the Mayor and City Council members) into believing that the historic significance of the Boiler Building is somehow in doubt, which it is not.

Page xviii in the FEIR ambiguously cites “reasonable abundance of caution“in treating the Boiler Building as a discretionary historical resource under CEQA. That description notably passes over the fact that TGHS and its members provided substantial evidence that the Boiler Building is a historical resource, evidence so compelling that the City felt obliged not to provide it to the SHPO through HSR when asking to reverse the finding of National Register eligibility, despite City Attorney Michael Garcia’s claim twice at the December 15, 2020 Council meeting that the City had contacted the SHPO in order to provide “more complete information” about the historic status of the Boiler Building.

It would have been understandable if the Lead Agency had defined the term “discretionary historical resource” once in the text. It is when the Lead Agency determines that a resource meets the criteria for listing in the California Register of Historical Resources (California Code of Regulations or CCR Section 15064.1.a.3); or the Lead Agency uses its discretion to consider any resource as historic for the purposes of CEQA (CCR Section 15064.1.a.4). The document need only explain that detail once. It can be in a footnote, and should explain that its historic significance was clearly proven based on “substantial evidence [because]… substantial evidence supports the conclusion regardless of any official listing in a historical register” as defined in CEQA.

Alternatives Analysis
According to CEQA, the contents of an EIR must describe a reasonable range of alternatives to a proposed project that could feasibly attain most of the basic project objectives and would avoid or substantially lessen any of the proposed project’s significant effects (CEQA Guidelines Section 15126.6(e)). Grayson Power Plant Boiler Building is a historical resource for the purposes of CEQA as described in the FEIR.

An alternative that would have avoided demolition of the Grayson Power Plant Boiler Building and Glendale Switch Rack would have included but not been limited to considering different locations for the proposed project, a smaller or reduced project, and at the very least, consideration of rehabilitation of the Boiler Building in accordance with the Secretary of the Interior’s Standards for Rehabilitation. None of those were presented.

Alternative 3 “The Alternative Energy Project Alternative” is environmentally superior but is entirely conjectural in the reasons for its dismissal. Its undeveloped description e.g. “some combination of photovoltaic or wind power production with energy storage and transmission lines” in not sufficiently developed to adequately analyze anticipated impacts. The description is completely vague and nearly devoid of clear information.

The conclusion that “the Alternative Energy Project Alternative reduces local potential air quality, cultural resources, energy, greenhouse gas emissions, hydrology and water quality, and noise impacts local to the Grayson Power Plant site” is not sufficiently presented either. The Alternative is described as “it increases off-site impacts to aesthetics [not clearly defined as it is unknown where the solar or wind resources would be], agriculture and forestry resources [unfounded with no identification of locations], biological resources [unfounded with no identification of locations], cultural/tribal cultural resources [which ones, if there is no identification of locations], environmental justice [to whom, with no identification of a location], geology and soils, land use and planning [where is there is no identification of locations], and population and housing impacts [these facilities are normally not built in populated areas] due to the need for increased transmission [unfounded with no identification of locations] as well as 285 of 296

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the large area [the locations of which are not disclosed in the FEIR] needed for a wind farm or solar field.”
Other agencies are building solar (771 in California, according to the California Energy Commission, 2022) and wind farms (there are seven in California) at a rapid pace. How is it that Glendale is somehow hampered by conjectural environmental impacts when others are not? The analysis concludes that the alternative is not viable “This determination is reinforced by the results of the Clean Energy RFP, the 2019 IRP, and the 100% Clean by 2030 study” which demonstrates that an infeasible alternative was brought forth as a CEQA “Trojan horse” or untruthful alternative (PR-DEIR “Alternative Energy Project Alternative – Alternative 3” page xx, see also CEQA Guidelines Section 15126.6(e)). If that alternative would cause more impacts than are disclosed, with promises of future impacts to locations unknown, the argument against Alternative 3 is Reducto ad absurduim, the falsity of the premise is demonstrated by showing that its logical consequence is contradictory.

If, as described in the FEIR, “The City is working with an engineering firm to investigate the feasibility of developing solar facilities on City-owned properties, and has preliminarily determined, subject to further analysis, that of the approximately 150 acres of City-owned property under consideration, approximately 40 acres may have some potential for PV development, however this acreage is far below the 1,310 acres necessary to locally power a PV project,” the TGHS-recommended mitigation measure to prepare a -Historic Resources Survey of City-Owned Properties would have been a valuable tool to understanding the potential impacts of such a project and is not ”punitive” as is alleged without providing any facts or basis for the claim.

The omission of this important component of the alternatives analysis, which would have meaningfully considered a reuse alternative for the historical resource, a different location or a smaller project is significant and problematic under the law. While an EIR need not consider every conceivable alternative to a project, alternatives must include consideration of those that would avoid or substantially lessen the significant environmental effects of the project. The FEIR did not include a rationale for the selection or rejection of the absent reuse alternative or of any clear information on which the Lead Agency relied in not making that a viable alternative under consideration. While City Council may have voted not to analyze an alternative that would have retained the historical resource in December of last year, based on the misinformation about SHPO eligibility determination provided by the City Attorney, such local, and unfortunately not fully informed decisions would not supersede the requirements in CEQA which is a state law, especially now that the FEIR recognizes that the Boiler Building is a historical resource.

The FEIR should have clearly identified alternatives considered but rejected as infeasible during the scoping process and briefly explained the reasons for the exclusions. Alternatives may be eliminated from detailed consideration in an EIR if they fail to meet most of the project objectives, are infeasible, or do not avoid any significant environmental effects; however it is legally required that they be described. See additional information under the Mitigation Measures section in this letter, in the following pages.

We have been told that reuse of the Boiler Building would be impossible numerous times. The “analysis” by Black & Veatch proved only they have no expertise in the subject: the reuse of historic buildings. Stantec’s assertions regarding the potential presence of hazardous materials similarly did not prove that the Boiler Building cannot be reused, but may have shown that Glendale Water & Power is unnecessarily exposing their employees to hazardous materials and 286 of 296

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conditions that could be easily mitigated. Power plant buildings have been successfully reused for a numerous purposes throughout the United States and abroad.6 Reuse of power plant facilities is not impossible, as has been implied in meetings between TGHS volunteers and City staff with their consultants (February 2, 9 and 16, March 4, 2021) as well as in public meetings regarding the proposed project. A fair amount of guidance on the subject of reusing power plants exists, including: “Repurposing Retired Power Plants Into Green Neighborhood Centers” (Smart Cities Dive, Kaid Benfield), “Repurposing Legacy Power Plants: Lessons for the Future” (American Clean Skies Foundation) and “Interpreting The Secretary of the Interior’s Standards for Rehabilitation No. 30: Reusing Special Use Structures” (National Park Service). If reuse of power plants for other purposes were impossible as implied by City staff and the embarrassing “analysis,” then how and why would the described guidance and examples of power plant reuse exist?
The description of alternatives in the FEIR fails to provide the necessary information for stakeholders and decision-makers to understand whether or not the historical resource really could be reused under any of the considered alternatives. Because no such meaningful reuse alternative was considered, and the Lead Agency’s dependence on the opinion of an engineering firm with no demonstrated specialty or understanding of the California Historic Building Code, the alternatives analysis is incomplete and deficient. The FEIR is legally inadequate in its description of existing conditions (without a supplemental technical report), as well as in its analysis of alternatives.

The Lead Agency is using the FEIR as a post hoc rationalization for its predetermination that the majority of the Grayson Power Plant, which may be a collection of unrelated historical resources or more likely is a locally and a California Register historic district, should be demolished wholesale, based on the City Attorney’s uncorrected misstatements about the property’s historic status at the December 15 2020 City Council Meeting. Pre-commitment to a project in advance of an adequate environmental review is a violation of CEQA. The FEIR should instead have considered feasible alternatives that would include new construction in some combination with adaptive reuse of the historical resource or resources.

Mitigation Measures
During that referenced December 15, 2020 City Council Meeting, Councilman Ardashes Khassakhian spoke about the importance of the City completing “all remaining” historic surveys. If the mitigation measure prepared and submitted to the Lead Agency by THGS, which was for a Historic Resources Survey of City-Owned Properties, had been implemented before the Grayson Repowering Project was considered, it is assumed that the subject property would have been identified as a historical resource and could have avoided this years-long dispute with TGHS and its members, and now with GREAD, regarding its significance.

Attachment 4, the April 25, 2021 three-page attachment sent via e-mail by TGHS to the Lead Agency directed: “The environmental document prepared for the Grayson Electric-Steam Power Plant must study and analyze historical resource impacts.”

6 Examples of successful power plant reuse projects include Barksdale Power Station (London, UK), City Hospital; Power Plant (Chicago, IL), Pier 4 Power Plant (Baltimore, MD), RJ Reynolds Tobacco Co. Power Plant (Winston Salem, NC), Seaholm Power Pant (Austin, TX), Sears & Roebuck Power Plant (Chicago, IL), South Street Station (Providence, RI) and the State Department West Heating Plant (Washington, D.C.). Additional power plants have been converted other uses in Portland, OR; Queens, NY, and Beloit, WI. 287 of 296

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It stated:

The alternatives analysis component will be especially critical in this this document. It must evaluate the No Project alternative as well as a “reasonable range” of feasible alternatives that would retain the Grayson Electric-Steam Power Plant as described in CEQA Guidelines Section 15126.6(e)).

There must be an essential nexus (i.e. connection) between the mitigation measure and a legitimate governmental interest… Nollan v. California Coastal Commission, 483 U.S. 825 (1987). The mitigation measure must be "roughly proportional" to the impacts of the project. Dolan v. City of Tigard, 512 U.S. 374 (1994). TGHS… believes that the below- listed mitigation measures would be both connected to the expected loss of the Grayson Electric-Steam Power Plant and are relational to the expected loss of that structure to the community. The addition of signage on San Fernando Road near the current location of the Grayson Electric-Steam Power Plant and the future retention and display of components of equipment from the Grayson Electric-Steam Power Plant shall be added to these mitigation measures.

Mitigation of impacts must lessen or eliminate the physical impact that the project will have on the historical resource. This is often accomplished through redesign of a project to eliminate objectionable or damaging aspects of the project. Relocation of a historical resource may constitute an adverse impact as well. However, in situations where relocation is the only feasible alternative to demolition, relocation may mitigate the impact below a level of significance provided such that the new location is compatible with the original character and use of the historical resource and the resource retains its eligibility for listing in the California Register (14 CCR Section 4852(d)(1)).

C[ultural] R[esources] M[itigation] M[easure] B- Historic Resources Survey of City- Owned Properties
The City shall prepare or cause to be prepared [a] comprehensive Historic Resources Survey of (all) City-Owned Properties (Survey) with improvements constructed before 1990, unless the property has previously been evaluated (with a written record of that evaluation) within the past five years or are expected to be evaluated in the planned East-West Survey. All survey work shall conform to the Secretary of the Interior's Standards for Archaeology and Historic Preservation, which include Standards for Evaluation, Identification, and Registration. The survey shall be prepared in accordance with “National Register Bulletin: Guidelines for Local Surveys: A Basis for Preservation Planning” and the California Office of Historic Preservation’s latest guidance. The Survey shall commence within 90 days of the adoption of the environmental clearance document for the Proposed Grayson Power Plant Repowering Project. The survey shall be completed within one-calendar year, be subject to a draft and final survey review and recommendation by the City’s Historic Preservation Commission and adoption by City Council.

The resulting survey shall include, at minimum:

A Summary, enumerating the total number of surveyed resources and districts with levels of significance.
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A Project Description, that clearly describes the purposes of the survey, sources of funding, its overall parameters, a description and map of the survey area and property types.

A Summary of Previous Identification Efforts that clearly describes any previous survey of identification efforts, local designations, National and California Register listings and determinations of eligibility, California Historic Landmarks and California Points of Historic Interest listings and designations and any other related historic preservation planning efforts. It shall include and describe the contents of a current, records search at the South Central Coastal Information Center at California State University Fullerton and provide the final survey and all known Glendale surveys to the Information Center upon completion, in accordance with the Information Center’s requirement.

A Context Statement prepared in compliance with The Secretary of the Interior's Standards for Preservation Planning, “Standard I. Preservation Planning Establishes Historic Contexts,” “Standard II. Preservation Planning Uses Historic Contexts To Develop Goals and Priorities for the Identification, Evaluation, Registration and Treatment of Historic Properties” and the California Office of Historic Preservation-prepared “Writing Historic Contexts” guidance. The Context Statement shall establish clear registration requirements for eligibility.

A clear Methodology section that describes field work techniques and research methods used to conduct the survey, a description of how historic districts are identified in the survey, references to previous surveys, and methodology for re- survey completed as part of this project. It will clearly describe efforts made to contact and involve members of the community and organizations with particular interests in historic properties.

Recommendations for future preservation activities, including: potential updates and/or amendments to existing National, California and Glendale Register designations, as applicable; designation recommendations for potential local historic districts, as applicable; and potential economic development, heritage tourism, and other preservation planning activities;
Survey results shall enumerate the total number of surveyed resources in appropriate categories, tables listing the property types and architectural styles identified, as well as narrative defining the results, with information regarding the levels of integrity and condition of resources, describes character-defining features, past and current development trends.

Appendix 1: Two-page DPR 523 series forms for each City-owned property unless the property is vacant or a paved parking lot which shall be noted in the survey results tables by Los Angeles County Assessor’s Parcel Identification Numbers and address (where assigned). The DPRs shall be fully completed in accordance with the latest edition of the OHP-prepared “Instructions For Recording Historical Resources.” They shall include whether or not the evaluation is an update, assign California Register Status Codes and describe other listings in the header blocks and include at least one clear digital photograph and a sketch map. If a property is [given a] California Register Status Code 1-6L, it shall include a complete architectural description, construction history, related features and under significance, describe why the resource is 289 of 296

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significant within … the relevant historic context and identify character-defining features.

Appendix 2: A survey map that delineates the survey area with all previously identified properties including local landmarks and historic districts and the results of the City owner-Properties Survey.

The results of the final or adopted survey shall be provided to the [California] Office of Historic Preservation, submitted in the specified formats to the Information Center and the result, including the DPR series 523 forms shall be posted, by property in the City’s Glendale Information Property Portal or its successors and in its entirely on the City’s website until it is updated by a subsequent survey, within no more than 90 days of its substantial completion or adoption.

The thoroughly described, recommended mitigation measure for a Historic Resources Survey of City-Owned Properties was not included in the PR-DEIR, despite following an invitation by City staff to prepare mitigation measures; Councilman Khassakian’s direction to complete the City’s historical resources survey; or the recommended mitigation measure’s direct connection to a legitimate governmental interest (maintaining a complete city survey); its approximate proportionality to the historical resources impacts of the project and the relation to the expected historical resources loss to the community. Based on this project’s years-long difficulty recognizing that the subject property is a historical resource, there is a very clear “nexus” linking the project’s expected impact to need for a Historic Resources Survey of City-Owned Properties.

The assertion on page 7.59 and 7.60 that TGHS was making an “attempt to leverage its desired interest in obtaining a City-wide survey of historical buildings based on demolition of one historic building” is insulting. The need for a city-wide survey of city-owned properties has been clearly demonstrated in this project. No mitigation measure was recommended for a blanket city-wide survey as alleged. In the Responses to Comments in the FEIR the City neglected to admit that Jay Platt falsely claimed in a “collaborative” meeting with TGHS on Grayson on February 9, 2021 that he had in his possession a city-wide historic survey of city owned properties that he performed with a former member of the Historic Preservation Commission which made such a mitigation measure unnecessary. He agreed in that meeting when requested to forward the contents of that survey to me “in a few days.” At least one e- mail reminder was sent to Mr. Platt to remind him that TGHS was expecting a copy of the survey as promised (see below), but the agreed-to copy of the City-wide survey that could have alleviated the need for implementation of a mitigation measure directing the propagation of such a survey was never provided.

Figure 3: Copy of e-
mail to Jay Platt from
Francesca Smith sent
on April 13, 2021 at
12:24 PM requesting
that he send the
survey as agreed. It
was never sent.

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We assert that the proposed Grayson Repowering Project would serve the entire City of Glendale, and therefore the recommended Historic Resources Survey of City-Owned Properties mitigation measure would in fact be “roughly proportional” to its impact (i.e., addresses its fair share of total impact). Future environmental clearance documents for this project shall incorporate the recommended city-wide survey mitigation measure in full.

Identify Existing Conditions and Present to Historic Preservation Commission In addition, the City has made a conscious effort to sidestep compliance with its own Ordinance.

Because the City is treating the Boiler Building as a historic resource in the FEIR, the proposed project must come to HPC for the demolition clearance and environmental review under CEQA.

Language from GMC is cited below. The City Attorney argued at the HPC meeting that Grayson would come to the HPC for a demolition permit after Council had approved the new project and certified the FEIR. That would negate the responsibilities of the HPC. The Ordinance assigns the HPC authority for environmental review as part of demolition clearance.

It is obviously wholly wrong to deprive the HPC and the public of this required review.

This project is impermissibly making an effort to separate project review authority and environmental review authority under CEQA. Litigation has proven that “CEQA is violated when the authority to approve or disapprove the project is separated from the responsibility to complete environmental review” (POET, LLC v. State Air Resources Bd. (2013) 218 Cal.App.4 th
681, 731). The HPC could decide whether or not to approve the demolition clearance application, but as the Lead Agency is proceeding, the FEIR would already have been certified.

This state of affairs clearly violates the letter and intent of this decision.

Furthermore, there is no mention in the FEIR of the requirements in the Glendale Municipal Code which addresses demolition of potential historical resources. The ordinance clearly directs under “Demolition clearance and demolition permit required for demolition of designated historic resources and potential historic resources” (15.20.080):

A. No person shall completely demolish a designated historic resource or a potential historic resource without first obtaining a demolition clearance and demolition permit, pursuant to Chapter 15.22 of this code.

B. In the event any designated historic resource or potential historic resource is completely demolished or partially demolished without demolition clearance and issuance of a demolition permit, the provisions of Section 15.20.090 of this chapter shall apply.

C. In the case of a property listed in the Glendale Register of Historic Resources, upon completion of any environmental review required by CEQA and issuance of a demolition permit, the matter will be referred to the historic preservation commission and city council to commence the process of deleting the demolished property for deletion from the Glendale Register of Historic Resources pursuant to Sections

15.20.055 and 15.20.060 of this chapter. (Ord. 5949 § 10, 2020; Ord. 5784 § 11, 2012; Ord. 5110 § 16, 1996; prior code § 21-04).

No demolition clearance or demolition permit for Grayson Power Plant has been presented to the City of Glendale Historic Preservation Commission (HPC) for consideration.

The Powers and Duties of the HPC are clearly set forth in the Glendale Municipal Code as “the following acts”
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A. To consider and recommend to the city council additions to and deletions from the Glendale Register of Historic Resources;
B. To keep current and publish a register of historic resources; C. To make recommendations to the planning commission, and the city council on amendments to the Historic Preservation Element of the city General Plan; D. To grant or deny applications for permits for demolition, or major alterations of historic resources;
E. To grant or deny appeals from decisions of the director of community development as specified in Section 15.20.040 of this code;
F. To encourage public understanding of and involvement in the unique historical, architectural and environmental heritage of the city through educational and interpretative programs;
G. To explore means for the protection, retention and use of any historic resource, historic district, or potential historic resource or district;
H. To make recommendations to the city council on applications for properties to be included in the Mills Act property tax incentives program which may be subject to historic property contracts as set forth in Section 15.20.070 of this code; I. To encourage private efforts to acquire property and raise funding on behalf of historic preservation; however, the commission is specifically denied the power to acquire any property or interest therein for or on behalf of itself or the city; J. To recommend and encourage the protection, enhancement, appreciation and use of structures of historical, cultural, architectural, community or aesthetic value which have not been designated as historic resources but are deserving of recognition; K. To encourage the cooperation between public and private historic preservation groups; L. To advise city council and city boards and commissions as necessary on historic preservation issues;
M. To make recommendations concerning, and render decisions on, design review applications affecting designated historic resources, resources pending designation as historic resources, potential historic resources, protected interiors, and protected landscape features as defined in Section 15.20.020 of this code, and affecting existing or proposed buildings, structures, or objects in designated and pending historic district overlay zones, as defined in Section 30.25.030(C) of this code and pursuant to Chapter 30.47of this code; N. To perform any other functions that may be designated by resolution or motion of the city council;
O. To make environmental determinations under the California Environmental Quality Act on any discretionary project applications the historic preservation commission considers for approval. (emphasis added, Ord. 5949 § 1, 2020; Ord. 5888 § 4, 2016; Ord. 5803 § 10, 2013; Ord. 5783 § 10, 2012; Ord. 5535 § 4, 2006; Ord. 5425 § 3, 2004; Ord. 5110 § 5, 1996; Ord. 4986 § 1, 1992: prior code § 3-139)
The proposed project was presented in January to the HPC but no public comment was accepted. I know because I tried to call twice during that item and received a City recording.

Unfortunately, and notably, actual review of the proposed project by the HPC has not taken place and has not been mentioned in any of environmental clearance documents for the proposed project, most notably in the FEIR, which should have incorporated any HPC findings or opinions regarding the proposed demolition of the historical resource, which would encourage public understanding of the project, particularly with historic preservation groups, explore possible means for protection, retention and future use of the subject property historic resource.
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If HPC’s role, as stated, is “recommending and encouraging the protection, enhancement, appreciation and use of structures of historical, cultural, architectural, community or aesthetic value which have not been designated as historic resources, encouraging cooperation for this project with historic preservation groups, advising city council and other city boards and commissions” regarding the proposed project, which is a historic preservation issue, and to make recommendations concerning, and render decisions on, design review applications affecting designated historic resources, resources pending designation as historic resources, and potential historic resources, then the proposed project must be presented to the HPC for consideration and recommendation to City Council. Any such hearings to address or coordinate with the HPC after the project FEIR was adopted, would be too late to make any findings or recommendations that would be considered for the proposed project. Without HPC’s express participation, this action and environmental clearance of this project would violate the City’s own established, adopted and recently updated Historic Preservation Ordinance.

By-passing the City commission whose stated role is to make decisions regarding historical resources and to advise city council on such matters is unconscionable. At this late date it will, no doubt, make the environmental review process take longer than expected, but it need not extend it by much to do it properly. An expedited review should not be of greater importance to the Lead Agency than making informed decisions on the proposed project or compliance with applicable state laws and local ordinances.

Cumulative Impacts and Effects
The PR-DEIR also failed to adequately analyze the cumulative impacts and effects of currently proposed future and recent projects with the proposed project. The assertion that “There are no known related projects that are expected to impact other previously identified historic resources which are examples of the municipal power property type in Glendale” is an overly restrictive and incomplete view of the expected cumulative impacts in currently proposed future and recent projects. We note that if the Boiler Building were demolished as proposed, then 25 percent of the City’s historic resources which are examples of the municipal power property type in Glendale would be permanently lost. If only one more were damaged or lost as the result of an emergency (e.g. fire, earthquake or other destruction), the count and hence the percentage would be reduced to only two properties and 50 percent remaining. Would the impact only be cumulatively considerable when none were remaining? We do not follow the logic. The Lead Agency’s understanding of cumulative impacts under CEQA is notably not in keeping with the intent of the legislation.

Historical resources impacts in the City of Glendale are not limited to those caused by the City to city-owned properties, such impacts can be caused by any project proponent and would cumulatively affect the community. We are curious how many properties within that narrow context of the “municipal power property type” have ever been evaluated for historic significance in Glendale? Again, we provide more justification for the dismissed mitigation measure: Historic Resources Survey of City-Owned Properties. We remind the Lead Agency that there is no adopted historic context regarding Glendale’s municipal water and power system. If one were prepared, it should include community participation, as well as references.

For example, the expected CEQA impacts expected to be caused by the current GWP “Western Reservoir & Bel Aire Electric Substation Improvements” to the Bel Aire Electric Substation Pump House were addressed in my PE-DEIR comment letter. If that Spanish Colonial Revival 293 of 296

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style, 1920s Bel Aire Electric Substation Pump House (see Figure 4 below) had been evaluated for historic significance in a city-wide survey as proposed by TGHS, that answer would be known.

Figure 4: Bel Aire
Electric Substation
Pump House,
view north.

Source: Google
maps, January
2021, not for
publication.

Nobody knows whether or not the Bel Aire Electric Substation Pump House is a historical resource. The proposed project includes “slope repair, erosion control measures, site drainage improvements, access road repairs, retaining wall repairs, fence replacement, landscape and irrigation improvements” (page 7.57). The Lead Agency described in the FEIR “Activities potentially affecting the Pump House would involve reconfiguring the stairway to avoid a blower [what stairway? Is it a character defining feature?], flattening of the driveway [e.g grading], and modifying the driveway approach [how?] to allow better vehicle access [why?]” but did not offer any proof of CEQA review for the project. Has the Bel Aire Electric Substation Pump House been intensively evaluated for historic significance? Did it historically have a black metal fence as proposed? Was its setting historically in a grove of trees as currently proposed or was it surrounded by lawn during its period of significance? How was the driveway and slope configured? As demonstrated in this example, implementation of the proposed historic resource survey mitigation measure would serve to guide future projects of that type and should avoid future, potential CEQA violations of this type. Refer to the discussion in the previous pages regarding Mitigation Measures and the preparation of a related context statement.

To bring a finer point to the matter, how would the Lead Agency or the public ever know whether or not a city-owned property was historically significant in the absence of the TGHS- recommended intensive historic resources survey of those properties? The Lead Agency’s justification is both exceedingly inward-looking, restricting the analysis of identified historic resources which are known examples of “the municipal power property” type in Glendale, and moreover is circular. If the City of Glendale does not identify city-owned properties that are historically significant to avoid situations like the proposed project, where TGHS has presented substantial evidence for its historic significance, then only unreasonably limited opportunities to analyze historical resources impacts to those properties will exist. 294 of 296

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Because the PRDEIR and FEIR considered neither a comprehensive list of recent and expected future projects that would affect historical resources, nor the combined impacts of those projects considered with the proposed project, cumulative impacts have not been properly analyzed. An analysis of the severity and extent of those impacts is required by CEQA. It is common for a Lead Agency to conclude that a project would not cause significant cumulative impacts because it is assumed that the project’s incremental effect is not cumulatively considerable, i.e., the impacts of the proposed project would be a drop in the bucket compared to the overall view like the Grayson Repowering project. The requirement for an adequate cumulative impact analysis as it relates to historical resources must be properly prepared to ensure the fullest possible protection of the environment as it relates to historical resources.

We appreciate the opportunity to comment and look forward to working with the lead agency in a more constructive and comprehensive way to avoid future problems with CEQA compliance as it relates to historical resources, including the Grayson Repowering Project.

Very truly yours,
Francesca Smith
Francesca Smith

Attachments:

Attachment 1 Letter from High-Speed Rail Authority to Julianne Polanco, State Historic Preservation Officer regarding “High-Speed Rail Program, Burbank to Los Angeles Project Section – additional information and request for review and concurrence on revised determination of National Register of Historic Places eligibility for Grayson Steam-Electric Generating Station (Grayson Power Plant)” November 3, 2020 (pdf pages 1-2); with letter from Erik Krause, City of Glendale to Mark McLoughlin, High-Speed Rail Authority, August 31, 2020 (pages 3-7) and California DPR 523 dated August 17, 2015 and revised 2017 (pages 8-33).

Attachment 2 Letter from The Glendale Historical Society to Erik Krause “Comments on Proposed Grayson Repowering Project Draft Environmental Impact Statement” November 17, 2017.

Attachment 3 Letter from Julianne Polanco, State Historic Preservation Officer to Brett Rushing regarding ”High-Speed Rail Program, Burbank to Los Angeles Project Section, Additional Information and Request for Review and Concurrence on Revised National Register of Historic Places Determination of Eligibility for Grayson Steam-Electric Generating Station (Grayson Power Plant)” December 2, 2020.

Attachment 4 ”Grayson Electric-Steam Power Plant Mitigation Measures” transmitted by The Glendale Historical Society to the Lead Agency dated April 25, 2021. Note: the date may be incorrect, the document was probably transmitted on March 25, 2021. cc: Aram Adjemian, City Clerk
John Schwab-Simms, Vice President of Advocacy, The Glendale Historical Society Alek Bartrosouf, Chair, City of Glendale Sustainability Commission Chris Cragnotti, Chair, City of Glendale Historic Preservation Commission 295 of 296
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