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agenda-report Appeal of Landmarks Commission Decision to Deny Application to Designate 305 San Vicente as a City Landmark Withdrawn at the request of Applicant/Appellant

Santa Monica City Council
May 10, 2022

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agenda-report Appeal of Landmarks Commission Decision to Deny Application to Designate 305 San Vicente as a City Landmark Withdrawn at the request of Applicant/Appellant
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May 10, 2022
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Santa Monica City Council
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City Council
Report
City Council Meeting: May 10, 2022
Agenda Item: 6.B
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To: Mayor and City Council
From: David Martin, Director, Administration
Subject: Appeal of Landmarks Commission Decision to Deny Application to Designate 305 San Vicente as a City Landmark
Recommended Action
Staff recommends that the City Council:

1. Deny Appeal 20ENT-0247, appeal of the Landmarks Commission’s decision to deny the designation of the property at 305 San Vicente Boulevard as a City Landmark; and

2. Deny Designation Application (20ENT-0119) to designate the property located at 305 San Vicente Boulevard as a City Landmark based on the revised findings contained in this report.

Summary
On April 27, 2020, the Appellant, H. Joseph Soleiman submitted Landmark Designation application 20ENT-0015 on behalf of Mid Century SV LP, owner of the property located at 305 San Vicente Boulevard. The application materials included an historic assessment report that was prepared for the subject building by Audrey von Ahrens of GPA Consulting (GPA). (Attachment B). The GPA report concluded that the “building is eligible for designation as a Santa Monica City Landmark under Criterion 5 as a significant and representative example of the work of notable architect, Samuel Reisbord”, and did not analyze whether the property met any of the other six Landmark criteria set forth in Santa Monica Municipal Code (“SMMC”) Section 9.56.100(A). 2 of 25
At the request of the City, and due to a change in process precipitated by the COVID-19 pandemic, Ostashay and Associates Consulting (OAC) prepared a Peer Review Assessment of the GPA report. (Attachment C). The OAC Peer Review Assessment concluded that the property does not appear to be eligible for designation as a Santa Monica Landmark under Criterion 5. Staff evaluated the Appellant’s materials, including the GPA Report, as well as the OAC Peer Review Assessment and recommended the Commission deny designation of the property at 305 San Vicente Boulevard as a Santa Monica Landmark.

On October 12, 2020, Landmarks Commission held a public hearing to discuss the property’s potential eligibility as a Landmark. For consideration in making its decision, the Commission was presented with evidence, including the Appellant’s application materials and materials presented by GPA, oral testimony from GPA, the OAC Peer Review Assessment, the analysis and recommendation included in the oral and written staff reports, and all public correspondence received prior to and during the hearing.

The materials can be found on the Landmarks Commission’s agenda for the October 12, 2020 meeting (Item 10-C).
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After consideration of all the evidence and full discussion, the Landmarks Commission determined that the property does not meet any of the designation criteria for the property to be designated a City Landmark and denied the application for designation.

On October 22, 2020, the Appellant, on behalf of the property owner, Mid Century SV LP, filed a timely appeal of the Landmarks Commission’s decision to deny the application for designation (Appeal 20ENT-0119), attached.

The appellant makes three primary arguments to support its appeal: 1) the application was held to a new and different standard than other applications to designate a Landmark because the City did not obtain a full historic assessment of the property prior to the Landmarks Commission’s hearing; 2) public comments in support of the designation application were not considered; and 3) the Peer Review Assessment prepared by OAC contains inaccurate statements about the information included in the nomination application.

Staff has reviewed the Appellant’s three primary claims. The designation process was conducted in a manner consistent with the Landmarks Ordinance and emergency procedures in place at the time. The comments Appellant claims were omitted from oral public comment were forwarded to the Commission and posted online prior to the meeting in a manner consistent with procedures in place at the time. The statements Appellant claims were inaccurate are supported by the record.

With the appeal, the Appellant submitted a second historic assessment dated December 30, 2020 that was prepared by GPA. In the updated/additional analysis, GPA found the property eligible for designation under four criteria for designation as a City Landmark: Criterion1, as an important example of its type; Criterion 2, as having aesthetic interest; Criterion 4, as embodying distinguishing characteristics of the MidCentury Modern style; and Criterion 5, as a significant example of the work of notable architect Samuel Reisbord.
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As with the assessment that was submitted with the application materials, the City requested that OAC provide a peer review of the updated GPA assessment. OAC conducted a thorough analysis including:
• Reviewed the initial landmarks Designation application; • Reviewed the City’s Landmark Designation Criteria, various ordinances and survey updates;
• Reviewed all the materials considered at the October 12, 2020 Landmarks Commission hearing;
• Conducted additional research on the property history; • Reviewed relevant National Park Service (NPS) guidance; and • Analyzed the assessment report and findings included in the GPA updated assessment.

Based on the materials submitted by the Appellant with the application and the appeal, including the GPA assessments, the analyses provided by OAC, evidence received prior to and during the Commission’s public hearing on October 12, 2020, staff finds the property does not meet any of the City’s designation criteria for a City Landmark set forth in SMMC 9.56.100(A) and recommends that Council 1) deny the appeal; and 2) deny the application to designate the property a Landmark.

Background
Historic Resource Designation Application
The applicant (property owner) for the designation application submitted information to support designating the property located at 305 San Vicente as a City Landmark under criterion SMMC Section 9.56.100(A)(5), “It is a significant or a representative example of the work or product of a notable builder, designer, or architect” as part of their April 27, 2020 application.

After the appeal was filed, GPA provided a revised/additional assessment, dated December 30, 2020. The revised assessment found that the property is eligible under four of the six criteria set forth in SMMC Section 9.56.100(A): 1, 2, 4, and 5. The 5 of 25
appeal/revised assessment asserts that the property is an important example of its type (1), has aesthetic interest (2), embodies distinguishing characteristics of the MidCentury Modern style (4) and is a significant example of the work of notable architect Samuel Reisbord (5).

Upon close analysis, the property appears to have undergone significant changes after the Northridge Earthquake in 1994, and therefore does not retain sufficient integrity to embody the characteristics described in the GPA report. Further, if the property remained fully intact, it would not necessarily be a representative or exceptional example of its type, style, possess aesthetic merit of its style, or represent a significant example of the work of a notable architect.

City of Santa Monica Landmark and Historic District Ordinance Santa Monica Municipal Code (SMMC) 9.56
Adopted in 1976, the stated purpose of the City’s Landmark and Historic District Ordinance (the “Ordinance”) is:
[T]o promote the public health, safety and general welfare by establishing such procedures and providing such regulations as are deemed necessary to:

A. Protect improvements and areas which represent elements of the City’s cultural, social, economic, political and architectural history.

B. Safeguard the City’s historic, aesthetic and cultural heritage as embodied and reflected in such improvements and areas.

C. Foster civic pride in the beauty and noble accomplishments of the past.

D. Protect and enhance the City’s aesthetic and historic attractions to residents, tourists, visitors and others, thereby serving as a stimulus and support to business and industry.

E. Promote the use of Landmarks, Structures of Merit and Historic Districts for the education, pleasure and welfare of the people of this City.

The ordinance further establishes procedures and standards intended to achieve these purposes. Among these procedures, the SMMC grants the Landmarks Commission the 6 of 25
power to designate Landmarks and Structures of Merit. The Commission has the option to designate an improvement as a Landmark or Structure of Merit to allow the City to protect and enhance improvements that are found to meet certain criteria to support either designation. Currently, there are 136 designated City Landmarks, 14 designated Structures of Merit, and 5 Historic Districts within the City.

To guide the exercise of discretion by the Landmarks Commission in designating Landmarks and the Council in approving or disapproving the actions of the Landmarks Commission, SMMC 9.56.100(A), sets forth six Landmark Designation Criteria:
[T]he Landmarks Commission may approve the landmark designation of a structure, improvement, natural feature, or an object if it finds that it meets one or more of the following criteria:

1. It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City.

2. It has aesthetic or artistic interest or value, or other noteworthy interest or value.

3. It is identified with historic personages or with important events in local, state or national history.

4. It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study.

5. It is a significant or a representative example of the work or product of a notable builder, designer or architect.

6. It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City.

In accordance with the Landmarks Ordinance, the City Council reviews the Commission’s designation of a Landmark, as well as any related decisions de novo when an appeal is filed. The Council may review and take action on all determinations, 7 of 25
interpretations, decisions, judgments or similar actions taken that were in the purview of the Commission, and the Council may approve, in whole or in part, or disapprove the prior determinations and decisions of the Commission.

Property Information and Architectural Description
The building, constructed in 1961, is rectangular in plan and organized around a courtyard with a swimming pool in the front setback. While the building contains details in the courtyard that are well-designed, the building at 305 San Vicente Boulevard is of simple design and construction primarily clad in stucco with simple stucco and metal railings, and aluminum windows.

The GPA materials (application and assessment) identifies the building at 305 San Vicente Boulevard as designed in the Mid-Century Modern style. The Mid-Century Modern style was prevalent in the Los Angeles region from the 1930’s through the 1970’s and has experienced a resurgence in popularity over the past 10-15 years.

There are many fine examples of Mid-Century Modern architectural design in singlefamily residential structures. Multi-family structures tend to be primarily characterized by the simplicity of features and construction.

The subject building exhibits the typical features of the ubiquitous podium style Stucco Box apartment typology, popular from the 1950’s thru the 1970’s. The architectural style of the 305 San Vicente Boulevard property is perhaps best characterized as “Vernacular” Mid-Century Modern, a low/simplified style that takes some characteristics of the “classic” Mid-Century Modern idiom and popularizes and dilutes them. The smooth stucco surfaces, clean rectilinear volumes, aluminum frame flush set windows, slider balcony doors, floor-to-ceiling glazing, integrated parking, flat roof with light wells, and the insular stark aspect of the elevated interior courtyard is typical of this style. 8 of 25
Figure 1: Photo of Subject Property
Property History/ Integrity Evaluation
An original key design element of the building along its primary façade featured rows of long, wide geometric fascia boards set as decorative trim at every floor level that spanned the entire front of the building and horizontally connected the balconies and engaged plastered planter boxes in a linear rhythm. This notable design feature; however, is no longer extant on the building, but for the single remaining fascia board trim at the front eave. The loss of this key stylistic feature has greatly impacted the architect’s original Mid-Century Modern design intent, as shown in the original perspective, below.

Figure 2: Original Rendering of Subject Property
In reviewing the original rendering for the building obtained from the Architecture and Design Collection, Design & Architecture Museum at the University of California Santa 9 of 25
Barbara (UCSB) campus as well as the extant fascia board at the front eave line, this unusual architectural feature added some stylistic distinction to the building’s overall design composition and gave some street presence to a rather mundane, typical façade. A review of the permit history on file with the City indicates this series of decorative fascia trim boards was most likely damaged and removed following the 1994 Northridge earthquake. Immediately after the earthquake the City’s emergency response teams began conducting building inspections throughout the community. The building and subterranean parking area of the 305 San Vicente Boulevard apartment building were inspected by the City for structural soundness on January 19, 1994. Notes on the “Rapid Evaluation Safety Assessment Forms” completed by the City’s structural engineer stated the building had severe cracking of walls with obvious severe damage and distress. The property was then “yellow” tagged for limited entry. On February 1, 1994, the building was re-inspected with field notes that stated the anchor bolts on the building had bent and displaced the south (front) wall. The “ornamental wall face at front of building” was also noted as having cracked sufficiently enough to expose additional anchor bolts (this is probably when the “ornamental face” aka geometric fascia boards were removed). The assessment report also notes that the front balcony slabs had displaced, but posed no immediate hazard. Upon concluding the second inspection, the building was issued a “green tag” and in the coming months was stabilized and repaired, as required.

Unfortunately, the extensive seismic repairs made to those areas of the building visible from the public rights-of-way visually and physically impacted the original Mid-Century Modern stylistic design intent as envisioned by its architect Samuel Reisbord. The front elevation at grade level is now dominated by an offset paved area for parking, the driveway leading into the parking garage, and the nondescript solid curving brick wall that encloses the swimming pool from the street. The side and rear elevations of the structure still have planar, unornamented wall surfaces that are punctuated by flush set aluminum sliders and recessed balconies with simple metal rails. In consideration of the prior alterations made to the exterior of the building, its original appearance, and its current lack of street presence, the architecture of the structure does not necessarily appear inventive, unique, or well-articulated. OAC’s peer review states, and staff 10 of 25
agrees, that the property’s historical integrity of design, material, workmanship, and feeling has also been affected. Therefore, the property does not appear to maintain all aspects of integrity. Below are the aspects of integrity:
• Location is the place where the historic property was constructed or the place where the historic event occurred.
• Design is the combination of elements that create the form, plan, space, structure, and style of a property.
• Setting is the physical environment of a historic property. • Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.
• Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.
• Feeling is a property’s expression of the aesthetic or historic sense of a particular period of time.
• Association is the direct link between an important historic event or person and a historic property.

While the property has maintained its location and setting, its design, materials, feeling and association have been significantly compromised.

Architect Samuel Reisbord
The GPA report states that the “building is eligible for designation as a Santa Monica City Landmark under Criterion 5 as a significant and representative example of the work of notable architect, Samuel Reisbord.” However, as the initial OAC peer review found, and staff agrees, that while Mr. Reisbord was a prolific architect whose collaborative work spanned three decades, he does not appear to be a “notable architect” in Santa Monica or the larger Los Angeles region. And while his work has been archived at UCSB, it does not necessarily correlate that Mr. Reisbord was notable, as the collection is expansive, including many California architects over many decades. 11 of 25
Typically, to be identified as a notable or “master” figure in a field (architect, builder, designer, engineer, landscape architect, craftsman artist, etc.), the person is generally recognized because of his or her consummate skill whose work is distinguishable from others by its characteristic style and quality. Depending on the sphere of geographic influence a notable person may be recognized locally for their quality of design and skill or on a broader scale at the state or national levels (such as Frank Lloyd Wright). While Mr. Reisbord was a prolific architect during this period, it does not appear that he was a leader or innovator, or made significant contributions to architecture or the architectural heritage of the local community or elsewhere. As stated in the OAC report(s), there are seven known buildings designed by Mr. Reisbord in Santa Monica, and it does not appear that they should be considered significant or representative works by the architect. If the exterior of the subject property had not been significantly altered, it’s possible it would be a representative example of Mr. Reisbord’s work. However, the building has been altered and does not represent the work of Mr. Reisbord, even if he were to be considered a notable architect.

Historic Context San Vicente Courtyard Apartment Historic District As with much of Southern California and Los Angeles County, Santa Monica’s population skyrocketed during and after World War II. The Douglas Aircraft manufacturing plant in Santa Monica employed thousands of local residents from the 1940’s into the postwar years. Following the war, the RAND Corporation provided employment for hundreds of Santa Monica residents in the fields of mathematics, aerodynamics, engineering, physics, chemistry, economics, and psychology. As housing demands quickly exceeded supply, courtyard apartment complexes replaced smaller multi‐family dwellings and the remaining single‐family residences along San Vicente Boulevard.

Santa Monica’s population boom in the postwar era prompted the restructuring of the City’s zoning ordinance to allow for higher density, multi‐family residential development.

Changes to Santa Monica’s zoning ordinance were further provoked by the rejection of 12 of 25
an application for the construction of a 120‐unit apartment building on San Vicente Boulevard in 1952. Through the 1950s, a contentious battle ensued between homeowners who opposed multi‐family residential development in their neighborhoods, and developers who looked to profit from higher density construction.

By 1960, the block of San Vicente Boulevard between 4th Street and 7th Street was zoned R3, Multiple Residential, limiting buildings to 45 feet (roughly four stories); the block between 4th Street and Ocean Avenue was zoned R4, limiting building height to 12 stories. In 1975, due to concern for the “quality of life” for residents living in areas zoned R3 and R4, new height restrictions enforced a 40‐foot (roughly three story) height limit in R3 zones and a 6‐story height limit in R4 zones. Both R3 and R4 zoning required minimum setbacks and a certain amount of private open space per unit. By the 1970s, condominiums had surpassed lower density courtyard apartments as the most prevalent form of multi‐family housing along San Vicente Boulevard. Today, the District comprises courtyard apartments, apartment houses, and condominiums, dating from the late 1930’s to the mid‐1990’s. The area is currently zoned R2, Low Density Multiple Residential, and building heights are limited to two stories.

The San Vicente Courtyard Apartment Historic District was designated a Historic District by the City Council in 2015. Its period of significance is defined as buildings constructed between 1937 and 1956. As the subject property was constructed in 1961, it is outside the period of significance and therefore a non-contributor to the Historic District.

Landmarks Commission Action
The application was submitted shortly after Federal, State and local declarations of emergency were issued in response to the COVID-19 pandemic. As a result, due to actions taken to promote social distancing, the deadlines for reviewing and taking action the application were extended and the public hearing was conducted remotely. Further, due to the devastating impacts of the pandemic on the City’s budget, rather than 13 of 25
obtaining a separate historic assessment to evaluate of the application, City staff obtained a peer review of the materials Appellant submitted with its application.

Specifically, due to measures taken to implement social distancing in response to the COVID-19 pandemic, deadlines for reviewing and acting on applications governed by SMMC Article IX, including processing timelines for applications to designate a City Landmark, were suspended in accordance with the Revised Fourth Supplement to the Executive Order Declaring the Existence of a Local Emergency (“Executive Order”).

The deadlines were subsequently tolled and then extended for two years under subsequent supplements to the Executive Order due to the continuation of measures to implement social distancing requirements, including the closure of City Hall and other City facilities, that resulted in unavoidable delays in the City’s processing of planning and permit related applications. In accordance with those supplements to the Executive Order, the deadlines for the Landmarks Commission to review and take action on the application were automatically extended.

From the time the application was filed until the matter was heard by the Landmarks Commission, the Landmarks Commission’s meetings were governed, in part, by provisions of Executive Order N-29-20, issued by the Governor on March 17, 2020, which suspended the Brown Act requirements for teleconferencing, provided that notice and accessibility requirements were met, the public was allowed to observe and address the legislative body at the meeting, and the legislative body had a procedure for receiving and swiftly resolving requests for reasonable accommodation for individuals with disabilities, specifying that this suspension would remain in place during the period in which state or local public health officials have imposed or recommended social distancing measures.

Prior to the COVID-19 public health emergency, although not expressly required by the Landmarks Ordinance, the City’s standard practice was to obtain an historic resource assessment for every designation application at the City’s sole cost. Applicants could elect to submit their own assessments, which were considered by both City staff when preparing a recommendation to the Commission, and the Commission when making a determination.
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With the devastating and unprecedented impacts to the local economy and the City’s budget caused by the COVID-19 public health emergency, the City became unable to obtain historic assessments at its own cost. On June 23, 2020, the City Council amended the application fees for designating a property as a City Landmark to include the cost of obtaining an historic assessment. This allowed the City to obtain an historic assessment of a property for which a designation application had been filed at the applicant’s cost.

However, the Appellant submitted its application prior to this change in fees, and during a time when the City’s budget did not permit for obtaining an historic assessment for the property that analyzed all six Landmark criteria. Accordingly, the City elected to obtain a more cost-effective peer review of materials received from the applicant in order to complete its evaluation of the property and make a recommendation to the Landmarks Commission for consideration. Other similarly situated applications were also evaluated through the peer review process.

On October 12, 2020, the Landmarks Commission held a public hearing to discuss the property’s potential eligibility as a Landmark. The Commission was provided with the designation application materials which included GPAs original evaluation and OAC’s peer review, as well as the staff report and written public correspondence that was either provided prior to the meeting or read into the record during the hearing.

In consideration of all evidence, including written and oral testimony from representatives for the Appellant, oral and written staff reports, historic preservation consultant reports, and any other materials introduced into the public record, the Commission voted unanimously to deny the designation of 305 San Vicente Boulevard.

The audio recording of the October 12, 2020 meeting is posted on the City’s webpage:
http://santamonica.granicus.com/MediaPlayer.php?view_id=9&clip_id=4578. 15 of 25
On January 11, 2021, in accordance with SMMC 9.56.120(H), the Landmarks Commission adopted a Statement of Official Action (attached) setting forth the findings to support its decision.

Appeal
On October 22, 2020, the Appellant filed a timely appeal of the Landmarks Commission’s decision. The appellant makes three primary arguments to support its appeal: 1) the application was held to a new and different standard than other applications to designate a Landmark because the City did not obtain a full historic assessment of the property prior to the Landmarks Commission’s hearing;2) public comments in support of the designation application were not considered; and 3) the Peer Review Assessment prepared by OAC contains inaccurate statements about the information included in the application materials.

The Appellant’s materials include an historic assessment prepared GPA dated December 30, 2020 that analyzed whether the property was eligible for designation as a City Landmark under all six of the Landmark criteria. In the updated/additional analysis, GPA found the property eligible for designation under four criteria for designation as a City Landmark: Criterion1, as an important example of its type; Criterion 2, as having aesthetic interest; Criterion 4, as embodying distinguishing characteristics of the MidCentury Modern style; and Criterion 5, as a significant example of the work of notable architect Samuel Reisbord.

Appeal Analysis

1. Application for 305 San Vicente was held to a new and different standard due to process changes that occurred during the COVID-19 pandemic.

The Appellant argues that the application for designation of 305 San Vicente as a City Landmark was held to a new and different standard because the designation process changed due to the COVID-19 pandemic and the City did not obtain an historic assessment that analyzed the property’s eligibility under all six Landmarks criteria. As discussed previously, staff did not solicit an independent assessment by 16 of 25
a historic preservation professional to evaluate the property against all six landmarks criteria due to the impacts of the COVID-19 pandemic on the City’s budget.

However, the Landmarks Ordinance does not require that such a report be obtained by the City as part of the designation process. Rather, SMMC 9.56.120(C) requires staff to “conduct an evaluation of the proposed designation and shall make a recommendation to the Commission as to whether the improvement merits designation.” While the City did not obtain an historic assessment that analyzed each of the six criteria under the Landmarks Ordinance, staff did conduct an evaluation of the proposed designation and made a recommendation to the Landmarks Commission based on the information provided in the application and the OAC Peer Review Assessment of the application materials, including the contention that the property was worthy of designation because of its association with Samuel Reisbord, a notable architect.

Additionally, for the appeal that is before the Council, staff has conducted a full evaluation of additional materials that were submitted by the property owner. And, staff further evaluated information received from the City’s consultant, OAC, who conducted a peer review of the appeal materials and also obtained original renderings and performed an analysis of the building permit history including an analysis of historic integrity of the subject property.

Staff’s evaluation of the application and appeal materials is consistent with the provisions of the Landmarks Ordinance, and the Landmarks Commission’s decision to deny the application for designation was based on substantial evidence presented to staff and the Commission. Nonetheless, Council has been presented with additional evidence for consideration on appeal.

2. Public comments, including multiple letters of support, were not properly considered during the Landmarks Commission’s hearing.
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Consistent with Executive Order N-29-20, all written correspondence received by noon the day of the meeting was posted online and forwarded to the Commission.

Any correspondence received after noon on the day of the meeting was read into the record during the hearing. At the time of the hearing, instead of receiving “real time” oral public comment, the Commission was accepting “real time” written public comment. Members of the public could submit written comments to be read into the record during the hearing in addition to any comment that was received after noon the day of the meeting.

The correspondence identified by the Appellant was received prior to noon on the day of the meeting. In accordance with the procedures in place at the time, the comments were sent to the Landmarks Commissioners for their review prior to the meeting and were not read into the record at the meeting. Therefore, the correspondence was treated according to the protocols for public comment in place since the start of the pandemic, which were consistent with Executive Order N-29-

20. 3. The appeal also contends that OAC’s peer review contains inaccurate statements.

Appellant argues that the Peer Review Assessment provided by OAC, which analyzes the materials provided in the designation application, contains inaccurate information. The Peer Review Assessment concluded that certain statements contained in the GPA report submitted with the initial application are not fully supported by evidence.

In the additional information provided by GPA on appeal, there appears to be explanation of why this supporting evidence was not included with the initial application materials, and the Appellant has provided additional information.

However, the statements made by OAC in the initial peer review were not inaccurate. For example, the OAC peer review states that:
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“…upon reviewing the application’s statement of architectural significance, there is question as to identifying Samuel Reisbord as a notable architect within the city…At this time, there is no analysis or discussion as to how Reisbord, whose office was located in Los Angeles, was accomplished in his field and made contributions to architecture or the architectural heritage of the local community or elsewhere”
The initial application outlines Samuel Reisbord’s career, identifying several wellknown architects he worked with. However, the initial application does not include a substantive argument as to the importance of his contributions to the field of architecture or the local community. While GPA might disagree with this statement, and others included in the OAC report, the Appellant’s assertion that the OAC peer review contains inaccurate statements is not supported by the record GPA provided information regarding the property in the initial application, and it was not a full assessment. Initial applications are not required to be full assessments.

Similarly, the peer review report by OAC was not a full assessment and focused on the information included in the initial application. The OAC provided a peer review of the initial application, based on the information included in the application materials.

The subsequent assessment by GPA dated December 30, 2020 provided grounds for the appeal and additional information regarding the subject property. Additional information was provided as part of the assessment received as part of the appeal, that in part, responded to OAC initial peer review comments. OAC also provided a peer review of the GPA assessment.

Eligibility as Landmark Designation and Proposed Findings To designate a property as a City Landmark, the Landmarks Commission, or the Council on appeal, is required to find that the property meets one or more of the six criteria set forth in SMMC 9.56.100(A) and discussed in detail below.

The City hired OAC to provide a peer review of the GPA historic assessment provided by the appellant/property owner. Based on the findings as provided in the OAC peer 19 of 25
review report, the consultant finds and staff agrees that the property does not appear eligible as a Landmark under the City of Santa Monica Landmark as outlined below.

The following draft findings are provided to support this conclusion:

Criterion 1
SMMC 9.56.100(a)(1). It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City.

The property does not exemplify, symbolize, or manifest elements of the cultural, social, economic, political, or architectural history or development of Santa Monica.

The altered apartment building at 305 San Vicente Boulevard, completed in 1961, is one of numerous multi-family residential properties constructed in the postwar period to meet the demand for housing. The design rational for these ubiquitous postwar multifamily buildings was to provide inexpensive housing using mass-produced building materials. The subject property was part of a trend that was occurring at the time, not only in Santa Monica, but elsewhere throughout Southern California and beyond. The subject property itself was not the impetus for this trend nor was it a seminal representative of large-scale, multi-family postwar development. As such, the building is not an early, rare, or excellent example of its type or of multi-family residential development within the City. It, along with many others in the community, represents a continued and popular residential development pattern in the post-World War II period within the City. Although the construction of the property is associated with City’s postwar development period, it cannot be said that this single building alone exemplifies, symbolizes, or manifests a pivotal multi-family residential development pattern of history in the City. Further, the apartment building has undergone notable modifications to its primary (front, south) façade thereby impacting its historical integrity of design, workmanship, material, and feeling. Therefore, it does not accurately sufficiently convey its original design intent to fully and accurately exemplify, symbolize, or manifest elements of the economic, social, or architectural history of the City. 20 of 25
Therefore, the property at 305 San Vicente Boulevard does not appear to satisfy Criterion 1.

Criterion 2
SMMC 9.56.100(a)(2). It has aesthetic or artistic interest or value, or other noteworthy interest or value.

According to the guidance from the National Park Service (NPS), “a property is eligible for its high artistic value if it so fully articulates a particular concept of design that it expresses an aesthetic ideal. A property is not eligible; however, it if does not express aesthetic ideals or design concepts more fully than other properties of its type.” Although the NPS guidance is not incorporated into the Landmarks Ordinance criteria, it has been the City’s practice to refer to NPS guidance to inform discussion of the criteria.

The subject property does not possess sufficient aesthetic interest or value to render it eligible under Criterion 2. Because of the elevated design of the apartment building and the internal configuration of the courtyard area above street level it is further removed from the public realm and not visible from San Vicente Boulevard or the rear alley.

Further, the courtyard space does not necessarily epitomize any type of uncommon or unique design as to consider having any notable aesthetic or artistic value to the community.

As the podium style Stucco Box apartment building typology from the early 1960’s was designed and built in many communities throughout Southern California it is possible that other internal courtyards with elevated open corridors and integrated planters exist. As for the overall building itself, it lacks any appropriate aesthetic or artistic interest and value necessary for designation under Criterion 2.

Therefore, the property at 305 San Vicente Boulevard does not appear to satisfy Criterion 2.
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Criterion 3
SMMC 9.56.100(a)(3). It is identified with historic personages or with important events in local, state or national history.

No evidence was provided to suggest that any of the prior owners or occupants of the property were persons of significance or made significant contributions to important events in local, state, or national history.

Therefore, the property at 305 San Vicente Boulevard does not appear to satisfy Criterion 3.

Criterion 4
SMMC 9.56.100(a)(4). It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study.

Because of its common exterior design attributes and the loss of original decorative trim features on the front of the structure, the 305 San Vicente Boulevard building appears ineligible for designation under Landmark Criterion 4. It was built during the postwar period, when quick and cost-effective construction was valued to meet the unprecedented demand for housing at that time. As such, the materials and methods used are common to postwar buildings in Santa Monica and throughout the region. The subject property, like many others of this type and period, would not individually be valuable to a study of a period, style, method of construction, or craftsmanship nor would it be considered a rare or unique example of an architectural design, detail, or historical type. From a stylistic perspective, the exterior of the building does not necessarily epitomize any type of uncommon or unique design. From the public right-ofway, it appears to be a typical example of its respective style and is constructed of commonly used materials.

The subject property exhibits the typical features of the ubiquitous and rather common podium style Stucco Box apartment typology, a popular building form of the late 1950’s, 22 of 25
1960’s, and early 1970’s. The architectural style of the 305 San Vicente Boulevard property is perhaps best characterized as “Vernacular” Mid-Century Modern, a low style that takes some characteristics of the “classic” Mid-Century Modern idiom and popularizes and dilutes them. In consideration of the building’s ordinary and ubiquitous appearance, alterations made to the front of the building, and its current lack of street presence, the architecture of the structure does not necessarily appear inventive, unique, or well-articulated. In addition, many of its extant design features, such as the entry lobby and staircase, open courtyards, open-air bridging corridors (walkways), integrated planters, fenestration, and front entries to the apartment units, are integrated internally within the core of the structure and are not visible from the public right-of-way.

As the interior courtyard features (along with many other aspects of the building) are not visible from San Vicente Boulevard or the rear alley they do not have the capacity to elicit any positive (or negative) value or response when experienced by the general public.

The apartment building is neither a unique or rare example of its type and design and as such is not considered valuable to a study of a period, style, method of construction, or architecture. There are many other similar extant examples of this typology and style.

Therefore, the property at 305 San Vicente Boulevard does not appear to satisfy Criterion 4.

Criterion 5
SMMC 9.56.100(a)(5). It is a significant or a representative example of the work or product of a notable builder, designer or architect.

The architect of record for the 305 San Vicente Boulevard apartment building as listed on the original permit is Samuel Reisbord (1904-1985). This property is also included in the archives of the Samuel Reisbord Papers, a collection of his architectural work and associated ephemeral material held at UCSB. Samuel Reisbord is recognized for his prolific work in designing a multitude of apartment buildings throughout the Los Angeles region. His designs covered a broad range of projects and included office buildings, 23 of 25
schools, tract homes, private residences, public housing, motels and hotels, and community centers, as well as apartment buildings. Reisbord had a very diverse and long career and was a prolific architect. However, he was not a leader or innovator and did not substantially contribute to the canon of architecture.

Reisbord’s professional portfolio locally included the design of at least seven known apartment buildings in the Santa Monica area that spanned three decades (1950’s, 1960’s, 1970’s). The subject property is one of those extant examples; however, it does not represent a significant or prominent portion of his career as an architect. With the removal of the original Mid-Century Modern style geometric fascia board trim that was once set horizontally at each floor level of the primary (front) elevation and with the lack of visibility into the building’s interior courtyard area the structure visually and physically “reads” (from the public right-of-way) as a rather typical, undistinguished apartment building with limited, if any, street presence. The property, though designed by Reisbord, is not a significant or prominent example of his work, nor is it a truly intact representative example of his work associated with his prolific career.

If the exterior of the subject property had not been significantly altered, it’s possible it would be a representative example of Mr. Reisbord’s work. However, the building has been altered and does not represent the work of Mr. Reisbord, even if he were to be considered a notable architect.

Therefore, the property at 305 San Vicente Boulevard does not appear to satisfy Criterion 5.

Criterion 6
SMMC 9.56.100(a)(6). It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City.

The subject building is a non-contributor to the San Vicente Courtyard Apartment Historic District, sitting in the middle of the block at 305 San Vicente Boulevard. It does 24 of 25
not have a unique location or singular physical characteristic and is not an established or familiar visual feature of the neighborhood.

Therefore, the property at 305 San Vicente Boulevard does not appear to satisfy Criterion 6.

At its October 12, 2020 meeting, the Landmarks Commission denied the designation of the property commonly known as 305 San Vicente Boulevard. Staff agrees that the property does not merit designation and recommends the City Council deny the appeal and deny the Landmark designation based on the findings set forth above and contained in the draft Statement of Official Action, attached.

Alternatives
As an alternative to the recommended action, the City Council may consider the following if supported by the full evidentiary record:

1. Articulate alternative findings, approving the subject appeal and approving the subject property as a Landmark.

Environmental Analysis
Pursuant to CEQA Guidelines Section 15270, CEQA does not apply to projects that a public agency disapproves. Based on the recommended action, CEQA would not be applicable.

Financial Impacts and Budget Actions
There is no immediate financial impact or budget action as a result of the recommended action.
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Prepared By: Stephanie Reich, Design and Historic Preservation Planner Approved Forwarded to Council
Attachments:

A. STOA 20ENT-0247 305 San Vicente Blvd Council Appeal STOA B. 305 San Vicente City Council Appeal notice
C. 20ENT-0119 (305 San Vicente Blvd) LM Application
D. 20ENT-0247 (305 San Vicente Blvd) APP Application
E. SM_305 San Vicente Bl_OAC Peer Review Memo 1_OCT2020 F. STOA 20ENT-0119 305 San Vicente LMC Denial
G. GPA Landmark Assessment Report - 305 San Vicente Blvd 2020-12-29-reduced H. SM_San Vicente Bl 305_OAC Peer Review_2021-12f.doc
I. 10-12-2020 LC Minutes

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