City Council
Report
City Council Meeting: June 14, 2022
Agenda Item: 6.B
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To: Mayor and City Council
From: David Martin, Director, Administration
Subject: Appeal of Determination by Landmarks Commission to Designate 631 Colorado Avenue as a City Landmark
Recommended Action
Staff recommends that the City Council:
1. Approve Appeal 22ENT-0015, appeal of the Landmarks Commission’s decision to designate the property located at 631 Colorado Avenue as a City Landmark; and
2. Deny Designation Application 21ENT-0125 to designate the property located at 631 Colorado Avenue as a Landmark or Structure of Merit.
3. If the City Council disapproves the appeal and approves the designation application to designate the property as either a City Landmark or Structure of Merit, as described in Alternative Actions, adopt the alternative findings under “California Environmental Quality Act Compliance”.
Summary
On March 19, 2021, 500 Pounds of Dog, Inc., the owner of the property at 631 Colorado Avenue, filed a demolition permit application. On May 20, 2021, Nina Fresco, on behalf of the Santa Monica Conservancy, submitted historic resource designation application 21ENT-0125 to nominate the property at 631 Colorado Avenue as either a Landmark or a Structure of Merit, with a revised application submitted on January 9, 2022. The designation application includes information to support designating the property as a Landmark based on Landmark designation criteria #1 and #4 as listed in Santa Monica Municipal Code (“SMMC”) Section 9.56.100(A). Staff contracted with GPA Consulting Group (“GPA”) to prepare a landmarks assessment report for the property. GPA’s report found that the property does not appear to meet the criteria necessary to designate the property as a Santa Monica Landmark pursuant to SMMC Section 2 of 24
9.56.100(A) or as a Santa Monica Structure of Merit pursuant to SMMC Section
9.56.080.
On January 10, 2022, in accordance with Interim Zoning Ordinance 2643 (“IZO”) establishing interim demolition review procedures, the Landmarks Commission held a public hearing to discuss the property’s potential eligibility as a Landmark or Structure of Merit. The Commission determined that the property met Landmark designation criteria
9.56.100(A)(1): “It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City” as a pioneer of the industrial commercial phase of development in downtown, and representative of the City’s evolution from the 1930s to the present. Under the IZO, if the Commission designates a property as a Landmark, it is then automatically determined that the building does not merit designation as a Structure of Merit.
On January 20, 2022, 500 Pounds of Dog, Inc. filed a timely appeal (Appeal 22ENT0015) of the Landmarks Commission’s decision. The appellant’s statement is attached and is further discussed in this report. Based on the findings outlined in the GPA report, evidence received prior to and during the Commission’s public hearing on January 10, 2022, and review of the appeal statement, staff recommends that the property be determined as ineligible as a Landmark or Structure of Merit.
Background
Historic Resource Designation Application
The applicant for the designation application submitted information to support designating the property located at 631 Colorado Avenue as a City Landmark. The application asserts that the property meets SMMC Section 9.56.100(A)(1) as an early example of industrial development in the downtown area and the first “beer outlet” in the city. The application further contends that the site is eligible because buildings that existed before the current development, but have since been demolished completely, were associated with Etta Vena Moxley, a prominent African American community member and activist, beginning in the early 1900s. Finally, the application states that the property is also eligible for Landmark designation under SMMC Section 3 of 24
9.56.100(A)(4) due to the use of Groutlock brick, a technical innovation that occurred after the Long Beach earthquake in 1933, and it’s Streamline Moderne/Art Deco styling.
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 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 134 designated City Landmarks, 13 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 4 of 24
Commission, the Ordinance, 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.
A Structure of Merit is an improvement that has been designated as and determined to be appropriate for official recognition by the Landmarks Commission. A Structure of Merit contributes to Santa Monica’s cultural identity but is not sufficiently distinguished to merit designation as a City Landmark. A key difference between Landmark and Structure of Merit designations is the level of historic significance based on their respective designation criterion, as the Landmark criterion are more elevated in comparison. Also, upon an owner’s request to demolish a designated Structure of Merit, the City may negotiate with the property owner in an effort to agree to a means of historically preserving the designated property. However, if no such agreement can be reached within this 180-day period which can be extended by the Landmarks Commission for an additional 180 days, the Structure of Merit could be demolished. 5 of 24
Further, a Structure of Merit designation can also be used for a potential contributor to a potential Historic District. However, the intent of using a potential district as the basis of a Structure of Merit designation initiates a 90-day period where a historic district application must be filed. If such application is not received, then the Structure of Merit designation is automatically nullified. In this manner, the Structure of Merit designation does not provide certainty in the protections of a property that a Landmark designation provides.
The Landmarks Ordinance, SMMC 9.56.080, sets forth the following Structure of Merit Criteria:
A. The property has been identified in the City’s Historic Resources Inventory.
B. The subject building is a minimum of 50 years of age and meets one of the following criteria:
1) It is a unique or rare example of an architectural design, detail or historical type.
2) It is representative of a style in the City that is no longer prevalent. 3) The structure contributes to a potential Historic District.
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.
The Council may review and take action on all determinations, 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.
Discussion
Property Information and Architectural Description
The property at 631 Colorado Avenue is located on a corner parcel bound by Colorado Avenue to the south, 7th Street to the east, a separate parcel to the north, and 6th Court alleyway to the west. The parcel contains two buildings, the Main Building located on the eastern side of the parcel and the Auxiliary Building located in the western corner.
The property features limited landscaped areas with mature trees and hedges planted 6 of 24
directly along the Colorado Avenue property line and around the main entrance of the Main Building and Auxiliary Building for added privacy. The remainder of the parcel is covered in asphalt paving that has been divided into parking spaces which are not visible from the public-right-of way due to the mature landscaping and modern fence with Art Deco-inspired piers and wrought iron posts that runs along Colorado Avenue.
Figure 1: Main Building
The Main Building was built in 1937 on the corner of Colorado Avenue and 7th Street as an industrial vernacular warehouse with Streamline Moderne influences. It is rectangular in plan with its shorter elevation facing Colorado Avenue. The building is one story in height with a two-story addition and barrel truss roof partially obscured by a raised parapet. The building is rectilinear and primarily of brick construction with reinforced concrete piers and divided lite steel windows. While the original brick largely remains, it has been sandblasted twice, and the grout has been poorly repointed, significantly reducing the integrity of workmanship. The building is largely vernacular with minimal adornment related to the Streamline Moderne architectural style; the GPA 7 of 24
analysis finds the property is also influenced by the Art Deco style but there does not appear to be sufficient stylistic influence to identify it as such.
The second-story addition runs the entire length of the north elevation. The north elevation abuts the neighboring property and is not fully visible. The west elevation of the Main Building facing the interior of the property features a projecting one-story addition that was completed c. 1980. The top of the addition is a flat roof deck surrounded by a metal railing. The second-story addition opens onto the roof deck.
Overall, the building appears to be in good condition.
Figure 2: 631 Colorado Avenue
As Viewed from Colorado As Viewed from 7th Street
Auxiliary Building
The Auxiliary Building was originally constructed in 1941 as a loading canopy for the Aztec Brewing Company’s operations. It is a one-story building that is rectangular in plan with a flat, composition roof. Overall, this modified Auxiliary Building appears to be in good condition.
Historic Context
Prior to the construction of 631 Colorado Avenue, the subject property contained four residential cottages and two outbuildings. The City of Santa Monica Designation Application for the subject property notes that Etta Moxley lived in one of the four cottages. Moxley was a prominent African American Santa Monica resident who was 8 of 24
heavily involved in various organizations, clubs, and philanthropic endeavors for the betterment of the African American community throughout her lifetime.
Black settlement in Santa Monica generally followed Los Angeles County-wide trends, including the early establishment of community institutions, residential segregation based on discriminatory practices, and the impacts of the civil rights movement. In the past, African Americans have represented the largest of the ethnic minorities residing in Santa Monica, and the community has a rich history and deeply entrenched roots within the City. The construction of the Santa Monica Freeway (Interstate 10) and the development of the Civic Center all but decimated the postwar African American community, and therefore many resources relating to this theme are no longer extant.
The majority of the extant resources related to this theme are found in the Pico and Ocean Park neighborhoods of the city.
The displacement and removal of African American communities is not unique to Santa Monica and was a pervasive practice throughout the United States with long-lasting and devastating consequences. This property appears to have been sold by the Moxley family and purchased by the Aztec Brewing Company in 1937 for the construction of a 50 by 100-foot brick building, the main building currently occupying the site. None of the buildings or improvements from the time that the Moxley family owned the property remain. Since the existing buildings were constructed after the demolition of the residential cottages, Etta Moxley does not have any association with the subject property at this time. In accordance with national standards, a property can be designated for the existing structures, and not for structures that no longer exist.
Historic preservation planning is just one of many tools for recognizing social, cultural, and historical value. Other strategies to employ may include historical markers, mapping programs, oral history projects, public art, events, walking tours, and close collaboration with advocacy groups. The Belmar History + Art Project is one example of commemoration of the African American Community in recognition of the largely black neighborhood that was razed through eminent domain in the 1950s in order to make way for the Civic Auditorium and Civic Center Campus.
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In the 1920s, Santa Monica’s population jumped from 15,000 to 37,000, the largest increase in the city’s history. Santa Monica had been a distinctly non-industrial city until the 1930s. The aviation industry played a significant role in the growth and development of Santa Monica in the early 20th century. A 1924 map of the Los Angeles area showed no industries in Santa Monica with more than twenty-five employees.
However, beginning in the 1920s, aircraft companies established or relocated operations to Southern California, which offered expanses of open, undeveloped land, favorable climatic conditions, and adequate infrastructure, including water, power, and transportation systems to support development of factories, testing facilities, and new housing for a rapidly expanding workforce. Though most resources from this period no longer exist, Santa Monica’s industrial development during this period provided the foundation for rampant expansion during and after World War II.
In addition to industrial buildings associated with the aviation industry, other light industrial uses from the period can be found in the industrially zoned portions of the city.
These buildings are typically vernacular in style, and early factory buildings may include daylight or controlled-condition factory buildings, warehouse buildings, and other types that support light industrial uses. While there are not many similar industrial buildings in the downtown area, there are many similar buildings remaining in other areas of the city where industrial buildings have been more prevalent throughout the City’s history.
Property History
The property located at 631 Colorado Avenue is currently occupied by the main, industrial warehouse (Main Building, for the purposes of this report) on the eastern portion of the parcel and an auxiliary building (Auxiliary Building, for the purposes of this report) to the west, which were built in 1937 and 1941, respectively. The property originally featured a Wine Storage Building, a wood framed platform, and a wooden addition to the Main Building’s west elevation, forming a U-shaped configuration with open space along Colorado Avenue.
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Figure 3: 1950 Sanborn Map, 631 Colorado Avenue.
The building permit for the Main Building was issued to the “A.B.C. Distribution Co.” (Aztec Brewing Company) in 1937 for the construction of a 50 by 100-foot brick building with composition roofing. Research did not reveal an architect, engineer, or builder. In 1941, the building permit for what is now the Auxiliary Building, located on the corner of Colorado Avenue and a rear alleyway, was issued for the construction of a 25 by 42- foot loading canopy with composition roofing. The maps also indicate that a small wooden platform with composite roofing was present on the fifth bay of the west elevation of the Main Building. In 1947, the canopy that is now the Auxiliary Building was altered to include an interior loading platform and exterior doors.
From 1955-1956, the Aerophysics Development Corporation owned the property and during their ownership, they sandblasted both buildings and made minor interior tenant improvements that did not alter the exterior of either building or the parcel. The following owner, Keystone Body Works, owned the property from 1957-1994. During their ownership, the company added a rear one-story addition to the Main Building along the alleyway in 1957, a free-standing canopy and signage in 1958, a new privacy wall made 11 of 24
of concrete block along the west elevation of the property against the alleyway in 1959 and removed the small wooden platform from the fifth bay of the Main Building sometime between 1950-1963. After 1963, a one-story, scored-stucco clad addition with fenestration consisting of large divided lite windows was added to the rear of the west elevation of the Auxiliary Building.
The addition and canopy on the Main Building were removed in 1996 during a tenant improvement project by new owners, Bandit Films. In 1997, both buildings were sandblasted and in 1998, a 730-square foot, second-story addition was completed along the entire north elevation of the Main Building as well as a contemporary privacy fence along Colorado Avenue and the rear alleyway. In 2002, the current owner of the property, Bay Films (500 Pounds of Dog, Inc.), added landscaping to the north of the main entrance on the Main Building’s west elevation and along both sides of the fence along Colorado Avenue.
Reinforced Brick Masonry
Reinforced brick masonry (RBM) refers to brick masonry construction reinforced with steel to improve the brick’s tensile strength. Different RBM techniques have been utilized for hundreds of years, but some of the most significant advancements in the United States occurred after the Long Beach Earthquake in 1933. Safer and more resilient construction techniques were researched, developed, and later codified in response to the dangers of unreinforced masonry buildings.
As a part of this research and experimentation, masonry units with new, specialized shapes were developed and used for construction. Two of those shapes included Groutlock and Port Costa Key bricks. Groutlock bricks were irregularly shaped with beveled edges on one side which, when stacked, would allow space for both horizontal and vertical reinforcements. Port Costa Key bricks featured two centralized notches along the stretcher. Both types of brick were advertised and used throughout Southern California for institutional and commercial construction following the 1933 earthquake. 12 of 24
Research indicates that the use of these brick shapes fell out of favor in the 1950s when research demonstrated that a structurally sound building depended not only the brick, but the type of mortar used, and proper workmanship and construction techniques. That is, there was no need for these special shaped bricks so long as a skilled bricklayer completed the construction.
While the 1937 building permit identifies the Main Building as being built with Groutlock bricks, no visible Groutlock bricks were observed during a physical assessment of the property; however, a few examples of what appear to be notched Port Costa Key bricks were observed although it does not appear to have been used for the whole of the building. Nevertheless, as the use of this type of brick quickly fell out of favor, this technique was not particularly influential in Santa Monica or throughout the region.
Landmarks Commission Action
On January 10, 2022, the Landmarks Commission held a public hearing to discuss the property’s potential eligibility as a Landmark or Structure of Merit. The Commission was provided with the designation application materials, the GPA landmark assessment report and staff’s analysis in the staff report. The property owner also engaged a consultant, ESA, to prepare an independent historic assessment and submitted that assessment as a part of the record for consideration by the Landmarks Commission.
The assessment concluded that the property does not satisfy the criterion findings as a City Landmark, or Structure of Merit. The ESA report and the appellant’s demolition permit application and appeal application materials are provided attached.
In consideration of all written and oral testimony, staff and historic preservation consultant reports, and materials introduced into the public record, the Commission voted 4-2 to designate the primary building at the corner of 7th St and Colorado Avenue and the entire property as a City Landmark and associated Landmark Parcel. The auxiliary building on the western end of the property was not included in the designation. The Commission designated the Landmark and Landmark Parcel based on criteria #1 and #4 pursuant to SMMC Section 9.56.100(A). The Commission’s findings included:
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• Criterion #1: The building exemplifies, symbolizes or manifests elements of the cultural, social, economic, political or architectural history of the City in that it was the first light industrial commercial building in the south-east portion of Santa Monica’s downtown; that the A.B.C. Distributing Company building was the only building in downtown with characteristics of the Art Deco/Streamline Moderne style, and for its association with Etta Moxley, a dedicated leader in the African American Women’s Club movement who lived on the property prior to its current development.
• Criterion #4: The building embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction or the use of indigenous materials or craftmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study in its use of Groutlock, a technique developed to respond to the long Beach earthquake, and for its characteristics of the Art Deco style rare in commercial industrial buildings in the City.
The Landmarks Commission designated the structure as a City Landmark a process that was a result of a demolition permit application. In accordance with the IZO, a building does not merit designation as a Structure of Merit if the building has been designated as a City Landmark. Therefore, no findings were necessary for the Structure of Merit criteria.
During its deliberations, the Commissioners had substantial disagreement on whether or not the property met the Landmark designation criteria, and whether or not there was sufficient integrity to warrant designation. The Commission focused their discussion on the artfulness of the corner building’s primary façade, the use of Groutlock brick and its association with Etta Moxley in the context of criteria for designation as a City Landmark, and, although no formal vote was taken because none was necessary under the IZO, determined that it did not appear that the property satisfied any of the criteria for a Structure of Merit.
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The January 10, 2022 Landmarks Commission staff report and approved meeting minutes, and the approved Statement of Official Action are attached. The audio recording of the January 10 2022 meeting is posted on the City’s webpage:
https://www.smgov.net/Departments/PCD/Boards-Commissions/LandmarksCommission/.
Appeal
The appellant filed a timely appeal on January 20, 2022. The appellant states that the Landmarks Commission relied on faulty information and did not apply the criteria correctly for this designation, and that the findings were not supported by substantial evidence. The appeal also noted that the staff report, the City’s preservation consultant, and the appellant’s preservation consultant all recommended denial of the property as a designated Landmark.
Staff has analyzed the application materials, the GPA consultant assessment and considered all the testimony and Landmarks Commission discussion and designation.
Staff remains in agreement with GPA that the property does not appear eligible for designation. The property, while one of the first industrial buildings built in this area of Downtown, does not appear to be a significant aspect of the larger trend of industrial development in Downtown or in Santa Monica as a whole. There have also been significant changes to the property over time and currently it is not immediately recognizable as an industrial building.
Appeal Analysis
1. Appellant states that the staff report, the City’s historic preservation consultant report (GPA), and the property owner’s historic preservation consultant report (ESA) finds that the property does not meet the City’s criteria for designation as a City Landmark or Structure of Merit.
The appellant is correct that City Staff and the historic preservation professionals who reviewed the property all agreed that the findings for both the Landmark and Structure 15 of 24
of Merit designations could not be met. The reports noted that there are many other similar buildings in the city and throughout the region, the architectural ornament is not significant or special, that the association with the important personage of Etta Moxley could not be made as no trace of the residential buildings she was associated with currently exist, and there is not sufficient evidence that Groutblock was used or that it was particularly influential.
2. The appeal states that the Landmarks Commission based their decision on faulty information and that the decision is not based on substantial evidence.
As discussed, staff found that there was not sufficient evidence to determine whether or not Groutlock brick was used. While the building permit included reference to Groutblock, a visual inspection revealed the use of some Port Costa Key bricks. Both types of bricks would not have been used in the same building. Additionally, this type of brick construction was not particularly influential in subsequent building. Further, staff has found that there is no meaningful association with Etta Moxley as there is no trace of the buildings she owned or lived in. And finally, under the Landmarks Ordinance, only “improvements” may be designated as either Landmarks or Structure of Merit. For purposes of the Landmarks Ordinance, structures that have been completely demolished, do not appear to meet the definition of “improvement”. Therefore, it does not appear that the Landmarks Ordinance, grants authority to designate buildings that have been completely demolished as either a Landmark or a Structure of Merit. As a practical matter, designating the existing buildings may be confusing as the structures have no connection to Etta Moxley’s residence or contributions to the City.
Eligibility as Landmark or Structure of Merit Designation and Proposed Findings The Interim Zoning Ordinance that governs the demolition permit review process requires the City Council, on appeal, to review the building’s eligibility as a Landmark or Structure of Merit. In order to be designated as a City Landmark, the Council is required to find that the property meets one or more of the six criteria discussed below. 16 of 24
The City hired GPA Consulting to prepare a landmark assessment report. Based on the findings as provided in the Landmark Assessment Report, the consultant finds and staff agrees that the property does not appear eligible as a Landmark or Structure of Merit under the City of Santa Monica Landmark or Structure of Merit criteria, as outlined below. Based on a thorough analysis of all this information, the City’s past practice, and the Secretary of Interior’s Standards, staff respectfully disagrees with the Landmarks Commission conclusion and recommends the City Council uphold the appeal and deny the designation. 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 existing buildings were constructed in what was once an African American residential neighborhood, replacing four residential cottages and two outbuildings. As such, the residential and outbuildings related to the cultural and social history of this area during that period no longer exist, and the buildings located at the subject property do not share the same association.
The subject property is one of the first industrial buildings built in this specific southeast area of downtown but does not appear to be a significant aspect of the larger trend of industrial development in Downtown or Santa Monica as a whole. Industrial buildings were being built throughout the City in the pre-war era, particularly in the nearby Pico neighborhood, in large groupings around and adjacent to transportation outlets.
Furthermore, the property’s original use as a distributor for the Aztec Brewing Company does not exemplify the economic development patterns Santa Monica was experiencing at this time. As mentioned above, Santa Monica’s aviation industry was the primary source of industrial development prior to World War II. The City of Santa Monica was not known for its alcohol distribution nor is this building the headquarters or a notable 17 of 24
location for the Aztec Brewing Company’s operations, which included various distribution warehouses throughout the Southwest. Additionally, the two existing buildings on the parcel were built as part of a collection of three buildings with a woodframed platform that all served a specific purpose in the distribution of alcoholic beverages. As a result of the loss of the third building and rear platform, as well as the infill of the Auxiliary Building that was originally a loading canopy and addition of fencing along Colorado Avenue, the site no longer reads as an alcohol distribution center.
Constructed in the industrial vernacular style, the Main Building lacks the primary character defining features that would qualify it as a light industrial building, such as loading docks and doors, and oversized bays of continuous industrial steel sash on two or more façades. Both buildings appear to be built in the vernacular style with minimal Streamline Modern styling, and neither building on the site is a notable example of the Streamline Moderne style, and there is no evidence to suggest this building was influential to the architectural development of the city.
Therefore, it does not appear that the property at 631 Colorado satisfies Criterion 1.
Criterion 2
SMMC 9.56.100(a)(2). It has aesthetic or artistic interest or value, or other noteworthy interest or value.
Both buildings located at 631 Colorado Avenue were constructed for industrial, utilitarian purposes. Thousands of industrial buildings were constructed throughout Southern California during pre- and post-World War II building booms. As such, the buildings do not possess special aesthetic or artistic interest or value, and it does not appear that they 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.
The existing buildings were constructed in what was once an African American neighborhood, replacing four residential cottages and two outbuildings. The City of Santa Monica Landmark Designation Application for the subject property notes that Etta Moxley, a prominent figure in the African American community, lived in one of the four residential cottages. Since the residential and outbuildings related to this cultural and social history are no longer extant, the existing buildings on the property do not share the same association.
The Aztec Brewing Company obtained the permits for both buildings currently on site.
Following the end of Prohibition, the Aztec Brewing Company had various distribution warehouses throughout the Southwest. Research did not reveal any evidence to suggest that the Aztec Brewing Company was owned or operated by any historic personages. Research did not reveal any evidence to suggest that the remaining businesses associated with the site were owned or operated by historically significant individuals. Research also did not reveal any evidence of association with an important historic event.
Therefore, neither building at 631 Colorado Avenue appears 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.
Both buildings located at 631 Colorado Avenue are examples of industrial vernacular construction in the years prior and during World War II. Industrial buildings constructed during this time featured limited exterior details as they were not intended to attract pedestrians for commercial use and were utilitarian by nature. While the modest use of 19 of 24
Streamline Moderne elements is visible on both buildings, the few features alone do not make these buildings notable examples of the Streamline Moderne style. The construction and features of both structures are not notable in any way and have been modified over time. Lastly, as indicated on 1950 Sanborn Maps around Santa Monica’s industrial cores, such as along rail lines or present-day freeways, brick industrial buildings were not a rarity for the City.
On the original permit for the Main Building, the construction material is indicated as Groutlock brick, a building material produced by the Simons Brick Company. However, a physical assessment of the site indicates that the brick is not an example of Groutlock, but rather another type of grouted masonry, described as Port Costa Key. A few scattered examples of what appear to be the Port Costa Key bricks are visible and have stepped notching at the top of the brick. Although this building material is visible, it was not used for the entire building, or if it was, only a few examples of this type of brick are visible from the exterior. As discussed above, many solutions for increasing the earthquake resistance of masonry buildings were explored in the aftermath of the Long Beach Earthquake, including experimentation with new masonry shapes. These shapes included the Groutlock brick, which had a diagonal or beveled edge, and the Port Costa Key brick, which had interlocking “notches.” However, subsequent engineering studies in the decades after World War II revealed that a special masonry shape was not necessary when good workmanship and an appropriate mortar mix was employed, and the new masonry shapes ostensibly fell out of use. The Groutlock and Port Costa Key bricks were a short-lived experiment in construction technology following the Long Beach earthquake. Research did not indicate that they were ever widely used or influential to later developments in construction technology. As such, it does not appear that the use of these brick shapes was an important building technique.
Therefore, neither building at 631 Colorado Avenue appears to satisfy Criterion 4. 20 of 24
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.
Research into the construction history of 631 Colorado Avenue did not reveal the name of the architect or the builder for the Main Building. The architect for the Auxiliary Building was identified on the 1941 building permit as Frederic Barienbrock. Frederick Barienbrock was a local architect that worked in Santa Monica for 50 years. Barienbrock was responsible for the designs of 1725 Main Street, 827 6th Street, 829 6th Street, and the 1951 addition to the Santa Monica Courthouse and County Building wing of the Santa Monica Civic Center. While Barienbrock appears to have been a successful local architect, his work is not particularly noteworthy and he is not an important architectural figure in the history of the city or the region. Additionally, the utilitarian canopy would not be a notable example of his work, and it no longer conveys its original design intent due to modifications on all elevations.
Therefore, the property at 631 Colorado Avenue 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 property located at 631 Colorado Avenue is located in a portion of Santa Monica’s original township that is now referred to as the Downtown neighborhood. The property is surrounded by residential, commercial, and industrial properties ranging from one to four stories in height. The subject property is an unremarkable infill site that, although part of the original township, does not appear to be an established and familiar visual feature of the neighborhood or City.
Therefore, the property at 631 Colorado Avenue does not appear to satisfy Criterion 6. 21 of 24
Evaluation for Structure of Merit Designation
The City’s historic preservation consultant, GPA, recommends, and staff agrees, that the Commission deny the property as a designated Structure of Merit:
9.56.080(A): The structure has been identified in the City’s Historic Resources Inventory.
The property at 631 Colorado Avenue was individually identified in the 2018 Historic Resources Inventory (HRI) Update and assigned a status code of 5S3, indicating that the property appeared to be individually eligible for local listing or designation through survey evaluation for conveying patterns of industrial development in the Downtown neighborhood of Santa Monica and being one of one of relatively few extant industrial buildings in this area from the pre‐World War II period. However, based on the analysis provided above, the property does not appear to merit designation.
9.56.080(B): The structure is a minimum of 50 years of age and meets one of the following criteria:
The subject property is a minimum of 50 years of age as it was constructed in 1914.
Therefore, the structure is eligible for further consideration under the following criteria:
(B)(1). The structure is a unique or rare example of an architectural design, detail or historical type.
The property at 631 Colorado Avenue is over fifty years of age, but it is not a unique or rare example of an architectural design, detail, or historical type. As discussed above, the buildings are industrial vernacular buildings with utilitarian purposes that are ubiquitous throughout Santa Monica’s industrial areas, such as the Pico neighborhood, and Southern California as a whole. Therefore, it does not appear that the property satisfies this criterion.
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(B)(2). The structure is representative of a style in the City that is no longer prevalent.
The subject property represents the industrial vernacular style which is still represented in the City in large numbers. While the resource is one of the few remaining industrial buildings in the southeastern portion of the Downtown, it is not rare when considered with the larger inventory of buildings in the industrial areas of Santa Monica. Industrial development in this area was not as historically prevalent in Downtown as other areas in the city, such as the Pico neighborhood.
Further north on Colorado Avenue there are numerous extant examples of similarly scaled industrial development. Therefore, it does not appear that the property satisfies this criterion.
(B)(3). The structure contributes to a potential Historic District.
The subject property is not located within any previously identified potential historic district, and a historic district is unlikely to exist in the area surrounding 631 Colorado Avenue. The subject property is surrounded by commercial, industrial, and multi-family buildings of various styles, sizes, and construction dates. They are not visually or historically unified and do not form a significant or cohesive grouping. Therefore, it does not appear that the property satisfies this criterion.
Parcel Designation
The Ordinance grants the Landmarks Commission, and the City Council on appeal, the power to designate a Landmark Parcel to “preserve, maintain, protect or safeguard” a Landmark. SMMC 9.56.060(A); 9.56.030(K). Generally, any proposed alteration, restoration, construction, removal, or relocation that occurs on a Landmark Parcel requires approval of a Certificate of Appropriateness. SMMC 9.56.140. The Landmarks Commission, or the City Council on appeal, also has the power to specify the nature of any alteration, restoration, construction, removal, relocation or demolition of or to a Landmark or Landmark Parcel which may be performed without a Certificate of Appropriateness. SMMC 9.56.120(F).
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At its January 10, 2022 meeting, the Landmarks Commission designated the property commonly known as 631 Colorado as an associated Landmark Parcel. Because staff is not recommending designation of the structures, staff does not recommend designation of the parcel.
Alternatives
As an alternative to the recommended action, the City Council may consider the following if supported by the full evidentiary record:
1. Articulate revised findings resulting in the denial of the subject appeal, approving the subject property as a Landmark or Structure of Merit.
2. Uphold the Landmarks Commission’s decision by adopting the Landmarks Commission’s findings pursuant to Statement of Official Action 21ENT-0125 and designate the property as a City Landmark and the property commonly known as 631 Colorado Avenue as an associated Landmark Parcel.
California Environmental Quality Act Compliance
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.
Alternative findings
Pursuant to CEQA Guidelines Section 15061(b)(3) it can be seen with certainty that there is no possibility that disapproving the appeal and designating the property as either a Landmark or Structure of Merit will result in any significant effect on the environment. This determination is based on the record as a whole, which includes, but is not limited to, evidence that the designation of the property as a Landmark or Structure of Merit will promote the retention and preservation of historic resources, the designation would not result in any physical change to the property, and any future physical changes would be subject to subsequent CEQA review. 24 of 24
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action as a result of the recommended action.
Prepared By: Stephanie Reich, Design and Historic Preservation Planner Approved Forwarded to Council
Attachments:
A. 22ENT-0015 (631 Colorado Ave) APPEAL Application (1) B. 631 Colorado Designation staff report
C. ColoradoAve631-Application amendment
D. Designation Application 631 Colorado
E. GPA Landmark Assessment Report
F. Property Owner's Historic Assessment Report
G. 631 Colorado Appeal Hearing Notice April 12
H. STOA22ENT-0015 631 Colorado Council Appeal STOA
I. 631 Colorado_ Supplement to Appeal Form(15050000.1)
J. Appeal Supplemental Part 2-Snow Memo and qualifications(15049663.1) K. STOA 21ENT-0125 (631 Colorado Ave) LM Designation
L. Written Comments