City Council
Report
City Council Meeting: June 14, 2022
Agenda Item: 6.A
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To: Mayor and City Council
From: David Martin, Director, Administration
Subject: Appeal of Landmarks Commission Decision to Designate 1665 Appian Way as a City Landmark
Recommended Action
Staff recommends that the City Council:
1. Approve Appeal 21ENT-0253, appeal of the Landmarks Commission’s decision to designate the property located at 1665 Appian Way as a City Landmark; and
2. Deny Designation Application 21ENT-0067 to designate the property located at 1665 Appian Way 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 February 15, 2021, Shyle LP, the owner of the property located at 1665 Appian Way, filed an application for a demolition permit to demolish the multiple-unit residential structure located on the property. On March 18, 2021, in accordance with the procedures set forth in Emergency Interim Zoning Ordinance Number 2643 (CCS) ( “Interim Zoning Ordinance 2643”) Shawn Hugus submitted an application to designate the property at 1665 Appian Way as either a Landmark or a Structure of Merit (Application 21ENT-0067). The designation application included information to support designating the property as a Landmark based on Santa Monica Municipal Code (“SMMC”) Section 9.56.100(A)(1) and (4) (“Landmark Designation Criteria 1 and 4”), as exemplifying elements of the social and urban/design/architectural history of the City 2 of 27
due to its location and rarity and as a rare example of a “double bungalow” building type valuable for study.
Staff contracted with Architectural Resource Group (ARG) to prepare an historic resource assessment report for the property. ARG’s report found that the property appears eligible for Santa Monica Landmark designation under SMMC 9.56.100(A)(1) as an example of Santa Monica’s economic history as associated with multi-family development and its relative rarity. ARG also found that the building may appear eligible for listing as a City of Santa Monica Structure of Merit under 9.56.080(B)(1) as a rare intact example of purpose-built multi-family housing. ARG did not find the property eligible under criterion 9.56.080(B)(4) for its craftmanship or typology. The property owner contracted with GPA Consultants (GPA) to provide an historic resource assessment. GPA’s assessment found the property did not meet any of the City of Santa Monica criteria for a Landmark or Structure of Merit. On September 13 and November 08, 2021, the Landmarks Commission conducted public hearings 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), determining that the property “exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City” due to its early construction date and as a rare and early example of “purpose-built” multi-family residential development, and adopted the findings recommended by the City’s consultant, ARG. The Commission did not find that the property was eligible for designation under 9.56.100(A)(4) as recommended in the designation application.
Under Interim Zoning Ordinance 2643, 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 November 16, 2021, Shyle LP filed a timely appeal (Appeal 21ENT-0253) of the Landmarks Commission’s decision. The appellant’s statement is attached and is further discussed in this report. Based on the evidence outlined in the ARG report, the GPA assessment, evidence received prior to and during the Commission’s public hearings on September 13, 2021 and November 08, 2021, and review of the appeal statement, staff does not believe this information materially 3 of 27
changes the original findings presented to the Landmarks Commission. These original findings, a summary of the Landmarks Commission’s decision, and the appeal statement are presented for the Council’s consideration as part of this de novo hearing.
Staff recommends that the City Council: 1) approve the appeal; and 2) deny the application to designate the property as either a Landmark or Structure of Merit.
Discussion
Property Information and Architectural Description
1665-1671 Appian Way is located in an interstitial zone between the Downtown and Ocean Park neighborhoods of Santa Monica. Located just south of the Santa Monica Pier and about a block west of Santa Monica City Hall, this neighborhood is adjacent to the ocean and exhibits a moderate downward slope as it approaches the water.
Circulation consists of both vehicular streets and pedestrian thoroughfares, most of which are oriented northeast-southwest. Two streets - Ocean Avenue and Appian Way - travel northwest-southeast and transect the neighborhood lengthwise.
Figure 1: Location map/aerial
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The neighborhood contains an eclectic mix of property types dating to multiple periods between the early twentieth century and the present day. Key property types in the vicinity of the subject property include multi-family dwellings of various sizes and scales, and hotels that take advantage of the neighborhood’s adjacency to the ocean and nearby attractions. The neighborhood is anchored by the Santa Monica Pier on the north, and by the Casa del Mar - a historic hotel dating to 1926 - on the south.
Figure 2 VIEW FROM APPIAN WAY LOOKING NORTH TOWARDS PROPERY Additional description and photos of the property is included in the ARG assessment.
The subject property is located on the east side of Appian Way, between Arcadia Terrace (northwest, a pedestrian street) and Pacific Terrace (southeast, an auto street).
The parcel is rectangular, is wider than it is deep, and measures 4,430 square feet. The site is heavily graded. The lot lines abut Arcadia Terrace (northwest), Pacific Terrace (southeast), and Appian Way (southwest). The northeast lot line abuts an adjacent residential parcel that is presently under construction.
The parcel contains a 2,707-square-foot multi-family residential building, consisting of four units that was built in 1914. The building is one story in height, though it reads as slightly taller when viewed from the Appian Way façade due to the grade of the site. The building sits on a concrete foundation and is constructed of wood frame. It consists of two volumes, each of which is roughly rectangular in plan and contains two dwelling units. The volumes are attached on the Appian Way façade by a continuous cornice and parapet. The building is vernacular and lacks characteristics of a particular style. 5 of 27
The building is situated at the center of the primary façade is a narrow pedestrian court.
Access to the court is restricted by a wood gate. Fenestration includes multi-light fixed wood windows and sliding aluminum windows, some of which have metal security bars.
The southeast façade, which faces Pacific Terrace, also has ample street frontage. This façade has an entrance to one of the building’s units, which consists of a single, unarticulated wood door. This entrance is approached by concrete steps with a metal rail, and a concrete stoop. All windows have wood surrounds; some also have metal security bars. The northwest façade faces Arcadia Terrace (a pedestrian street). The northeast façade is obscured from public view. A metal security gate obscures this façade from the public-right-of-way along Pacific Terrace.
Figure 3 Across from Appian Way looking east and from Appian Way looking northeast
Neighborhood Context: Seaside Terrace
1665-1671 Appian Way is located within the Seaside Terrace development tract.
Located immediately south of the Santa Monica Pier, Seaside Terrace was an early attempt on the part of developers to develop prime ocean frontage to capitalize on Santa Monica’s prevailing culture of recreation, leisure, and tourism.
Santa Monica is the third-oldest city in Los Angeles County, having been incorporated in 1886. By virtue of its picturesque location along the coast and its idyllic climate, Santa Monica, as well as the neighboring communities of Ocean Park and Venice, emerged as popular destinations among Southern Californians and tourists alike in the latter 6 of 27
decades of the nineteenth century. Bathhouses, hotels, amusement piers, and various other tourist-oriented developments were erected along the coast in the latter decades of the nineteenth century, many of which were marketed as “Coney Island” style attractions - drawing an overt connection with the popular entertainment destination in New York.
One of the foremost local attractions of this era was the Arcadia Hotel. Built in 1887, and prominently sited astride a bluff between present-day Colorado Avenue and Pico Boulevard, the hotel epitomized luxury and elegance. It was housed within a large, imposing structure designed in the then-fashionable Queen Anne style. In addition to its well-appointed guest rooms, the hotel featured such amenities as “hot and cold running water, electric and gas lights, and indoor bathrooms,” as well as a switchback roller coaster. Beachgoers were known to congregate in droves along the shore adjacent to the hotel.
In 1909, the Santa Monica Municipal Pier, the largest concrete pier in the world, was constructed not far from the central business district to carry sewer pipes to the sea.
Looff’s Pleasure Pier was constructed directly beside it in 1916 and featured a roller coaster, swing ride, bowling alley, carousel, and other attractions. Together, the two piers comprise the present-day Santa Monica Pier.
However, the fortunes of the Arcadia Hotel waxed and waned and the eventually closed. In 1909, developer Carl F. Schader purchased the shuttered hotel as well as several acres of adjoining land, and set out to redevelop his acquisition into a “mixeduse residential and resort area that would make Santa Monica the ‘Atlantic City of the West.’” He razed the hotel in 1909 and subdivided its former grounds into two side-byside tracts: Seaside Terrace and Vicente Terrace, a decision that coincided with the construction of the Pier. Schader foresaw the area around the pier as eventually developing into a recreational hub sought to capitalize on this development. Seaside Terrace included 61 parcels; Vicente Terrace was slightly smaller, tallying in at 44 parcels. Both tracts were created according to a modified rectilinear grid that conformed to the contour of the adjacent coast and bluffs.
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Prominent examples of early development in Seaside Terrace included the Seaside Terrace Apartments (not extant) and the Selkirk Apartments (not extant). Both were built in 1911 along Ocean Front Walk as apartment hotels that catered to tourists and other itinerant tenants seeking alternatives to the conventional single-family house. So too was the Purser Hotel and Apartments (extant, designated as a Santa Monica Landmark), which was constructed in 1913 at Appian Way and Arcadia Terrace.
Smaller, more modest examples of development took place on the blocks east of Appian Way amid the subdivision’s formative period of growth in the 1910s. Sanborn maps from 1918 show that on these eastern blocks, early development was varied and consisted of single-family houses, apartments, and flats. These maps also show that a majority of lots within the tract remained undeveloped at that time.
Both the designation application and ARG historic assessment contain numerous historic photos of the neighborhood over time. The photos demonstrate the variety of building typologies in this area and suggest that no one building typology was prevalent.
Multi-Family Housing
The City of Santa Monica Historic Context Statement emphasizes that multi-family development within the city was rare in the late nineteenth century. At this time, large hotels like the aforementioned Arcadia often rented rooms to travelers and other itinerant types during the summer months, but these properties were principally commercial - not residential - in function. As noted in the City of Santa Monica Historic Context Statement adopted by the Landmarks Commission as part of the 2018 HRI update, “no apartment buildings are listed in the 1899 directory and only one, the Kensington Apartments on S. Ocean Avenue, is listed in the 1907 directory.” In the 1910s there was construction of more purpose-built, multi-family dwellings as Southern California witnessed an influx of new residents in addition to seasonal tourists in search of longer-term accommodations. This need was especially pronounced in Santa Monica, given its identity as a bastion of tourism and recreation. As noted in the 8 of 27
Historic Context Statement, “six official apartment buildings are listed in Santa Monica [in 1909] and the number increased significantly during the teens.” 114 apartment buildings are identified in city directories from 1912.
A wide variety of multi-family building typologies were built beginning in the early 1910s.
Examples of multi-family housing in Santa Monica during this period tended to consist of small-scale duplexes, triplexes, and flats (also commonly referred to as fourplexes) that could easily pass as single-family residences and were favored because of their ability to seamlessly blend into the fabric of existing neighborhoods. Bungalow courts began appearing circa 1908, and thereafter evolved into other iterations of courtyard housing that became popular in subsequent decades. Large apartment houses and other, more quintessentially urban types of multi-family housing also became increasingly common. 1665-1671 Appian Way fits neatly into this context. Constructed in 1914, during the period that multi-family housing was starting to come of age, the property is reflective of the location, type, scale, and general configuration of the city’s multi-family housing stock.
The application also states that “the multi-family residence 1665-1671 Appian Way is eligible for designation as a Santa Monica Landmark under SMMC Section
9.56.100(A)(4) as a rare example of an architectural historical type) valuable for study:
the double bungalow, a type that was previously common in Santa Monica but has largely disappeared.” However, photos from that period demonstrate this building type was not prevalent in the beachfront area during the period of significance. The “doublebungalow” is not a recognized multi-family typology and did not have influence in Santa Monica or throughout the region.
Historic Resource Designation Application
The applicant for the designation application submitted information to support designating the property located at 1665 Appian Way as a City Landmark. The application asserts that the property meets SMMC Section 9.56.100(A)(1) as it exemplifies elements of the social and urban design/architectural history of the City. 9 of 27
The application also states that as a result of development and redevelopment in this beachfront area over time, no other extant examples from this period of similar smallscale duplex housing at Santa Monica’s oceanfront near the pier have been identified.
The application also states that the multi-family residence 1665-1671 Appian Way is eligible for designation as a Santa Monica Landmark under SMMC Section
9.56.100(A)(4) as a rare example of an architectural historical type) valuable for study:
the double bungalow, a type that was previously common in Santa Monica but has largely disappeared.
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 10 of 27
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 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 11 of 27
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.
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 kick starts 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.
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Analysis
Staff has analyzed the application materials, the ARG consultant assessment commissioned by the City, the GPA consultant assessment commissioned by the property owner, the information provided at the Landmarks Commission meeting hearings conducted on September 13 and November 08, 2021, including input written and oral from the public and the Commission discussion. Staff respectfully disagrees with the conclusions of the Commission and ARG that the property is eligible for designation. There does not appear to be anything particularly rare or influential about this “double bungalow” or duplex in the development of the typology or architecture in the city. Further, the beachfront area developed with a variety of uses and building typologies and as such the vernacular duplex that this property represents was never prevalent in this specific location. However, there remain numerous vernacular multifamily properties in the surrounding neighborhoods and throughout the city, and as such the subject property is not a rare or representative example.
At the September 13, 2021 Landmarks Commission meeting, a member of the public provided information regarding the documented racist actions of the property owner.
The item was continued and this was a topic of discussion at the November 08, 2021 Landmarks Commission meeting. While the Statement of Official Action (STOA) does not include a mention of this, the discussion includes some information on this matter to ensure a full, yet concise, analysis of all the issues raised by the applicant, appellant, Commission and members of the public.
Racism of the Property Owner
At the September 13, 2021 Landmarks Commission meeting, a member of the public included information in written correspondence and oral testimony regarding the racist practices of John Stotler, the property owner who had the building constructed, requesting the Commission consider this information as part of their discussion. The hearing on the item was continued to November 08, 2021 and the Commission directed staff to provide additional information regarding this matter. 13 of 27
The consultant found, and staff agrees, that the property was not associated with the racist activities of John Stotler for purposes of designation under the Landmarks Ordinance. Mr. Stotler was a founding member of the Santa Monica Bay Protective League, which appears to have been founded upon a focused mission to deny property to African Americans in Santa Monica and actively advocated against access to Santa Monica Bay by black people. Mr. Stotler’s racist position and actions as a white property owner do not make him noteworthy or unique.
While the City of Santa Monica must recognize and find a way to come to terms with the racist practices that were prevalent, this particular building is not specifically or directly associated with the racist activities of John Stotler. Although Stotler constructed and resided in the subject building, the property itself does not appear to have played a significant role in this facet of local history other than the location of Stotler’s residence, and therefore there is insufficient evidence linking this history to the property. As such, it does not meet the criteria for association as it is not clearly nor directly associated with that shameful history. Additionally, had evidence suggested Mr. Stotler’s racist practices were specifically connected to this property, staff would recommend that any designation specifically not recognize Mr. Stotler, so as not to honor the City’s history or racist practices or Mr. Stotler’s place within that history.
Figure 4 Views of Subject Property from Appian Way
“Double Bungalow” Property Type
ARG researched this property type to see if it is, in fact, a recognized property type that has been influential or been prevalent in the city. ARG found that the “doublebungalow” is not a recognized property type and the property is similar to other multi- 14 of 27
family housing types. The property does not appear to have a special or unique configuration that would warrant special consideration under Landmark Criterion 4.
Staff agrees with this analysis.
Rarity of Subject Property
ARG performed additional research regarding rarity of the property type. The additional research confirmed ARG’s conclusion that the property appears to be an early, rare example of purpose-built multi-family housing of the era, and as such finds that the property appears eligible for designation under criterion SMMC 9.56.100(a)(1) as a Santa Monica Landmark as an example of Santa Monica’s economic history as associated with multi-family development and its relative rarity. ARG also found that the building may appear eligible for listing as a City of Santa Monica Structure of Merit under 9.56.080(B)(1) as a rare intact example of a purpose-built multi-family housing.
Staff respectfully disagrees with this conclusion. As there continue to be several extant multi-family properties of this era remaining on the HRI, staff believes that the area studied for its rarity may be too narrowly focused within the vicinity of the subject property and may therefore establish a false sense of rarity. Other properties in nearby neighborhoods appear to be more exemplary of multi-family development in this era. In particular, the properties in the Fourth Street Corner District and the Bay Street Cluster contain multi-family properties built within a similar time frame. As noted in the consultant’s report, the property is not the best example of the property type and staff believes there are other properties and property types that better exemplify the early economic and development history of this area. Additionally, historic photos demonstrate that this property type was not particularly prevalent in the immediate vicinity during the early period of the 20th century.
In the early years of development of the City, there was great flexibility of use, particularly in residential structures. In particular, there were many properties in close proximity to the beach that may have originally been built as single-family structures and were quickly remodeled for use as multi-family. Some of these structures remain as multi-family structures and others have been remodeled again to single-family or other 15 of 27
use. As such, staff is unsure whether identifying this property as “purpose-built” multifamily housing is a distinction that may unnecessarily reduce the pool of comparable properties. It doesn’t appear that this building typology was prevalent at any time in the immediate area of the subject property. Staff believes the property is neither a good example or a rare example of its type, and therefore does not warrant designation as a City Landmark or Structure of merit.
Landmarks Commission Action
On November 08, 2021, the Landmarks Commission held a public hearing, continued from September 13, 2021, on the property’s potential eligibility as a Landmark or Structure of Merit. The Commission was provided with the designation application materials, the ARG landmark assessment report commissioned by the City, including the supplemental report provided in response to their direct request related to John Stotler, staff’s analysis in the staff report, and the historic assessment property by, GPA on behalf of the property owner, to prepare an independent historic assessment and submitted that assessment as a part of the record for consideration by the Landmarks Commission. The GPA assessment concluded that the property does not satisfy the criterion findings as a City Landmark, or Structure of Merit. The GPA report and the appellant’s demolition permit application and appeal application materials are 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 4-3 to designate building at 1665 Appian Way as a City Landmark and the property parcel on which the building is located as an associated Landmark Parcel. The Commission designated the Landmark and Landmark Parcel based on criterion #1 pursuant to SMMC Section 9.56.100(A).
The Commission’s findings included:
• Criterion #1: The subject property exemplifies elements of Santa Monica’s economic history, specifically those associated with patterns of early residential development. It was among the smattering of early multi-family dwellings that were built in newly-subdivided tracts adjacent to the Municipal Pier (which 16 of 27
opened in 1909) and other recreation and leisure oriented amenities that were located adjacent to the shore. Modest, purpose-built multifamily housing options like the subject property were introduced to Santa Monica in the very early twentieth century, loosely defined as the period prior to 1920. These early examples of purpose-built multi-family housing were a testament to the profound influence that leisure, recreation, and tourism had on Santa Monica’s built environment at this time. Their relatively compact footprints and efficient use of space reflect the ways in which developers adapted and responded to a demand for shorter-term, affordable alternatives to the single-family house in order to better accommodate the itinerant lifestyles of tourists and others drawn to Santa Monica’s culture and climate. The subject property - and particularly its oceanfront setting and efficient use of space - is illustrative of how Santa Monica’s housing stock evolved in response to broad economic trends of the period. Built in 1914, the subject property has a relatively early construction date when compared against Santa Monica’s pool of extant multi-family residential buildings. It thus stands out as an early example of purpose-built multi-family residential development, which began to come of age in the 1910s but did not proliferate until the 1920s. Examples of multifamily development from the 1920s onward are manifold in Santa Monica; examples of multi-family housing predating 1920, by contrast, are far fewer. In addition, the subject property is notable on account of its rarity: specifically, it is one of but only a few examples of early (pre-1920) purpose-built multi-family residential development in Santa Monica that remains extant and retains sufficient integrity to convey its association with key patterns of residential development and economic history. It is certainly not the only remaining example of a pre-1920 multi-family dwelling - the locally designated Purser Apartments (1659 Ocean Front Walk, 1913) sits across the street and conveys many of the same characteristics - but the subject property is among an already meager population of pre-1920, purpose-built multi-family resources that has diminished even more over time, as similar properties have either been demolished to make way for new development or have been altered to the extent to which they no longer retain sufficient integrity for listing. Though it has experienced some alterations, the subject property retains integrity from its 17 of 27
original construction date. Rarity is corroborated by data culled from the 2018 HRI. Including the subject property, only eleven examples of pre-1920 multifamily properties were identified in the HRI as eligible for listing. This figure is very meager when compared against the total number of eligible resources identified in the HRI (875) and the total number of parcels within the City of Santa Monica (approximately 23,000). Moreover, Sanborn maps from 1918 indicate that at that time, there were a sizable number of modest, purpose-built multifamily dwellings in the Seaside Terrace and Vicente Terrace tracts, particularly on the inland blocks east of Appian Way. Almost all of these early, purpose-built multi-family dwellings from the 1910s have since been extensively altered or demolished. Many succumbed to redevelopment that took place in these neighborhoods in the 1990s, which resulted in the demolition of many existing properties and the construction of expansive, multi-lot developments in their place.
Because the Landmarks Commission designated the structure as a City Landmark, in accordance with Interim Zoning Ordinance 2643, it was automatically determined that the property did not merit designation as a Structure of Merit. 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, resulting in a 4 to 3 vote in favor of designation. The Commission focused their discussion on the particular qualities and craftsmanship of the structure, its rarity, and the racism of the original property owner.
Although no formal vote was taken because none was necessary under IZO 2643, the Commission discussed and generally agreed that it did not appear that the property satisfied any of the criteria for a Structure of Merit.
The November 08, 2021 Landmarks Commission staff report, approved meeting minutes, and the approved Statement of Official Action are attached. The audio recording of the September 13, 2021 and November 08, 2021 meetings are posted on 18 of 27
the City’s webpage: <https://www.smgov.net/Departments/PCD/BoardsCommissions/Landmarks-Commission/>.
Appeal
On November 16, 2021, the appellant/property owner filed a timely appeal of the Landmarks Commission’s decision. The appellant primarily amplifies the staff report, the pertinent information was previously discussed in this report.
Appeal Analysis
1. Appellant states that the staff report and the property owner’s historic preservation consultant report (GPA Consulting) finds that the property does not meet the City’s criteria for designation as a City Landmark or Structure of Merit.
The Appellant also cited that GPA also found that the recommendations do not follow the guidance published by the National Park Service.
City Staff and GPA consulting agreed that neither the findings for Landmark nor Structure of Merit designations could not be met. The staff report and GPA’s report noted that the building is an unremarkable vernacular structure, many of which are still extant in the city, and that the property type did not influence development patterns or represent a notable building type. As there are other similar buildings in the city and throughout the region and that there is nothing that distinguishes this property to be historic but rather it is simply old.
The GPA report also identifies the importance of attention to the National Register guidance. Historic preservation professionals and Commissions alike refer to National Register guidance to assist in analysis of significance pertaining to designation.
Regarding Santa Monica Criterion 1, “It exemplifies, symbolizes or manifests elements of the cultural, social economic and political or architectural history of the City”. The National Register guidance has a similar criterion, and states that the property must be not only associated with a historic trend, but that the property must have an important association with that trend. The property may have been built as part of the building of multi-family housing to serve full-time residents and visitors alike. However, it does not 19 of 27
appear to be an important property type or of significant influence within that trend.
Other property types such as the courtyard property type was in fact very influential in the city during the 1920’s and 1930’s and thereafter. The “double-bungalow” is not a recognized type and the building is vernacular and commonplace in a way that does not appear to be significant within that trend. Staff is in agreement with the appellant that the property does not meet Santa Monica Criterion 1.
2. The appeal states that while the City’s consultant (ARG) found the property to be worthy of designation as an example of “purpose-built multi-family housing, but that the analysis does not support that conclusion. The appeal re-iterates the staff report which states that the geographic area and typology was significantly narrowed to create the appearance of rarity.
As the staff report to the Landmarks Commission states, there were about 112 multifamily residential properties built in the era from 1910 to 1920 and more than 10 percent of those properties remain extant. Therefore, the property is not a rare example of its type. There are a number of other vernacular multi-unit residential properties remaining, several recognized such as in the 4th Street Corner Historic District, Bay Street Cluster, and 11th Street Historic District.
Additionally, photos included in the ARG and GPA consultant reports reveal that there were not a substantial number of similar properties originally built within this neighborhood or tract. The property was always a simple, unremarkable, vernacular structure in an eclectic neighborhood filled with various types, sizes and styles of structures. Staff respectfully disagrees with the ARG report which suggests the property is a rare example of a diminishing type. However, this particular property was not one of similar properties built in this small area of the city that no longer exist, but one of an eclectic mix of property types. And so identifying it as a rare property type appears to be a mischaracterization.
Recommendation
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Eligibility as Landmark or Structure of Merit Designation and Proposed Findings The Interim Zoning Ordinance 2643, which governed the demolition permit review process for this property, 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.
Staff has analyzed the application materials, the ARG historic resource assessment procured by the City, and the GPA historic resource assessment commissioned by the property owner and has considered all the testimony and Landmarks Commission discussion and designation. Based on a thorough analysis of all this information, the City’s past practice, National Register Guidance and the Secretary of Interior’s Standards, staff respectfully disagrees with the Landmarks Commission conclusion and recommends the City Council approve the appeal and deny the designation. The property, while one of the only extant beachfront bungalow the so-called “doublebungalow” does not appear to be a significant aspect on the larger trend of residential development near the beach or in Santa Monica as a whole. Additionally, based on analysis of the history of the building fabric in the neighborhood over time, and the prevalence of multi-family vernacular architecture of this period remaining throughout the city, staff does not find the subject property to be a rare example of its type.
The following draft findings are provided to support this conclusion:
Evaluation for Landmark Designation
The Landmarks Ordinance requires the Commission, and the City Council on appeal, to review the building’s eligibility as a Landmark based on the six criteria discussed below. As this is an appeal, in order to be designated as a Landmark, the Council is required to find that the property meets one or more of the criteria:
SMMC 9.56.100(a)(1). It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. 21 of 27
The subject property is a simple, unremarkable example of a duplex typology, built in a period where a variety of multi-family building typologies were being built in the area closest to the beach as well as the adjacent Ocean Park neighborhood. As there were about 112 multi-family residential properties built in this era and more than 10 percent of those properties remain extant, the property does not warrant recognition. Additionally, other multi-family properties from this era in the immediate and surrounding neighborhoods (Bay Street Cluster, 4th Street Historic Corner District) have been recognized as exemplary of this typology. Therefore, the subject property does not appear to be eligible for listing as a Landmark under Criterion 1.
SMMC 9.56.100(a)(2). It has aesthetic or artistic interest or value, or other noteworthy interest or value.
The subject property is a vernacular building that lacks the distinctive characteristics of a particular architectural style. Its features are more a testament to function than they are to aesthetics. Because of its vernacular appearance, the building reads as a simple structure that was erected to provide affordable, functional housing options to Santa Monica’s working and middle-class residents - and was not intended to be a building of particular architectural or aesthetic merit in the spirit of this criterion.
For these reasons, 1665-1671 Appian Way does not appear to be eligible for listing as a Landmark under Criterion 2.
SMMC 9.56.100(a)(3). It is identified with historic personages or with important events in local, state or national history.
There is insufficient evidence indicating that any of the people associated with the subject property made significant contributions to history. Original owner John S.
Stotler - who also lived in one of the building’s dwelling units between 1914 and 1931 - appears to have had a successful career, first in the mining industry and later as a local real estate developer, but does not appear to have made any significant inroads to history that would render him a historically significant individual in the spirit of this criterion. None of the subsequent owners or tenants associated with the building appear to be of historical significance. The scant information that is available 22 of 27
about these individuals indicates that they lived typical lives and were employed in typical vocations.
There is also insufficient evidence to indicate that the property is associated with a significant event in local, state, or national history. It appears to have functioned as nothing more than a typical multi-family dwelling between its original (1914) construction and the present day. For these reasons, 1665-1671 Appian Way does not appear to be eligible for listing as a Landmark under Criterion 3.
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.
As discussed in the evaluation against Landmark Criterion 2, the subject property is a vernacular structure that lacks distinctive characteristics of an architectural style.
There is also nothing particularly noteworthy about its method of construction or craftsmanship, as it is a conventional wood frame building utilizing methods and materials typical of the era in which it was constructed. The subject property does not read as a particularly strong example of any particular multi-family property type identified in the City of Santa Monica Historic Context Statement. It has four units, but does not present as a fourplex; it also contains a pedestrian passage between its volumes, but lacks the shared open space that is characteristic of bungalow courts and courtyard housing. It lacks the height and the density characteristic of apartment houses. For these reasons, there is insufficient evidence showing that it is a unique or rare example of an architectural or historical type valuable to a study, per this criterion.
The building does not appear to be significant on the merits of its architecture. Its significance is derived from its use and associative qualities, not for reasons relating to its physical design. Therefore, 1665-1671 Appian Way does not appear to be eligible for listing as a Landmark under Criterion 4.
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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.
Original building permits for the subject property are not available; supplemental research about the property indicates that it was not designed by an architect, and was built by building contractor F.N. Jones. No pertinent information could be found about the life, career, or contributions of Jones; available documentation indicates that he was a locally-based building contractor who erected the occasional building but was not especially prolific in their craft. Given the lack of information about F.N.
Jones - and the lack of an architect of record - there is insufficient evidence demonstrating that the building is a representative example of the wok or product of a notable builder, designer, or architect. For these reasons, 1665-1671 Appian Way does not appear to be eligible for listing as a Landmark under Criterion 5.
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 property does not possess any singular feature or physical characteristic that stands out as memorable or noteworthy. While it reads as considerably older that most other buildings in the immediate vicinity, there is nothing particularly notable about its design or appearance apart from its relative age. It is located on a typical residential lot on a lesser-traveled street, and does not occupy a particularly prominent location. It may be familiar to those who reside in the neighborhood and pass by on a regular basis, but to the casual passer-by the building does not stand out as an aesthetically distinctive resource in the spirit of this criterion. It is compatible with, and blends into its surroundings. For these reasons, ARG concludes that 1665-1671 Appian Way does not appear to be eligible for listing as a Landmark under Criterion 6. 24 of 27
Evaluation for Structure of Merit Designation
While the consultant, ARG, has found that the subject property meets one or more of the Structure of Merit Criteria, staff respectfully disagrees with that assessment and recommends 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 subject property has been identified in the City’s Historic Resource Inventory (HRI).
As noted, in the most recent (2018) iteration of the HRI, it was flagged as potentially eligible for individual listing and was assigned the California Historical Resources Status Code of 5S3: “appears to be individually eligible for local listing or designation through survey evaluation.” However, based on further evaluation as noted above, the property does not appear eligible for listing under any Structure of Merit criteria.
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 subject property is a simple design of a property type for which more than 10% of similar property types built in the 1910s are extant. The subject property does not stand out as an architectural design, detail or historic type and is not rare, and therefore does not appear to be eligible for designation under this criterion. (B)(2). The structure is representative of a style in the City that is no longer prevalent.
The building is more than 50 years of age. However, as noted in the evaluation against Landmark Criteria 2 and 4, it is a vernacular building that lacks distinctive characteristics of an architectural style. Additionally, while the property was not influential on other properties, vernacular buildings are ubiquitous throughout Santa Monica and remains 25 of 27
prevalent. For these reasons, Appian Way does not appear to satisfy Structure of Merit Criterion B.2.
(B)(3). The structure contributes to a potential Historic District.
The subject property has not been identified as a contributor to a historic district.
Therefore, it does not appear to be eligible for listing as a Structure of Merit under 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).
At its November 08, 2021 meeting, the Landmarks Commission designated the property commonly known as 1665 Appian Way 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-0065 and designate the property as a City Landmark and the property commonly known as 1665 Appian Way as an associated Landmark Parcel.
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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.
Financial Impacts and Budget Actions
Prepared By: Stephanie Reich, Design and Historic Preservation Planner Approved Forwarded to Council
Attachments:
A. 1665 Appian Way Appeal City Council In Person Meetings B. 21ENT-0067 (1665 Appian Way) LM Application and Historic Report (1) C. 21ENT-0253 (1665 Appian Way) APP Application (1)
D. ARG_1665 Appian Way Assessment_090221
E. ARG_1665 Appian Way Supplemental Memo 110221
F. 21ENT-0067 (1665 Appian Way) STOA LM Designation (1) G. LC minutes 11-08-2021
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H. STOA 21ENT-0253 1665 Appian Way Council Appeal STOA
I. Written Comments