City of
Santa Monica
Planning and Community Development Department
City Planning Division
(310) 458-8341
City of
Santa Monica™
APPEAL FORM
(Please Type or Print all Information)
Application Number Filed:
By:
APPELLANT NAME: 500 Pounds of Dog, Inc
APPELLANT ADDRESS: 631 Colorado Avenue
CONTACT PERSON: Alexander M. DeGood Phone: 310.284.2205 (all correspondence will be mailed to this address)
Address: 2029 Century Park East, Suite 2100, Los Angeles, CA 90067 PROJECT CASE NUMBER(S) : 21ENT-0125
PROJECT ADDRESS: 631 Colorado Avenue
APPLICANT: Santa Monica Conservancy
ORIGINAL HEARING DATE: January 10, 2022
ACTION BEING APPEALED: The Landmarks Commission's designation of 500 Pound of Dog inc's building at 631 Colorado Avenue at the corner of 7th Street and Colorado Avenue, as a Landmark pursuant to SMMC Sections 9.56.100 and 9.56.120 on January 10, 2022, and the designation of the site as a landmark parcel.
Please state the specific reason(s) for the appeal (use separate sheet if necessary):
Is the appeal related to the discretionary action and findings issued for the proposed project? [X] Yes L No If yes, explain:
The Landmarks Commission failed to properly apply the City's Landmark criteria codified in SMMG Sec. 9.56.100 in designating the building as a Landmark and instead allowed improper and irrelevant considerations to influence its decision. As a result, the Landmark designation does not meet the legal standards for designation and is not supported by substantial evidence and therefore there is no legally adequate basis for the designation and it must be reversed.
Is the appeal related to the conditions of approval? Yes X No If yes, which conditions and why:
Is the appeal related to design issues? Yes • No If yes, explain:
Is the appeal related to compatibility issues such as building height, massing, pedestrian orientation, etc.? Yes No If yes, explain:
Is the appeal related to non-compliance with the Santa Monica Municipal Code? X Yes If yes, which Code section(s) does the project not comply with and why:
The Landmarks Commission misapplied SMMC 9.56.100, considered factors that as a matter of law it cannot consider for a Landmarks application and rendered a decision unsupported by substantial evidence. Among other issues, the evidence in the record discloses that the designated building lacks integrity. and multiple Commissioners admitted that their votes to designate were not based upon an assessment of the actual designated structure or parcel Is the appeal related to environmental impacts associated with the project? Yes X No If yes, explain:
Is the appeal related to other issues? X Yes No If yes, explain:
The Staff report recommended denial, two independent comprehensive landmark assessment reports prepared by well-recognized experts found the property does not meet any landmark designation criteria, and two Commissioners with expert standing detailed why the property does not meet the City's landmark criteria. The appellant will supplement the reasons set forth herein prior to the City Council hearing. including following appellant's receipt of the Landmark Commission's statement of official actions as prescribed by SMMC Sec. 9.56.120.H hilar
APPELLANT SIGNATURE:
NOTE: A hearing date on the appeal will not be scheduled until sufficient information regarding the basis for the appeal has been received to enable City Planning Division staff to prepare the required analysis for the staff report.