Jenna Snow ● Historic Preservation Consulting ● 323/317-3297 ● [email protected] Memorandum
DATE: May 16, 2022
TO: Kenneth L. Kutcher
Harding Larmore Kutcher & Kozel, LLP
41250 Sixth Street, Suite 200
Santa Monica, CA 90401
FROM: Jenna Snow
RE: 631 Colorado Avenue, Santa Monica, CA
Introduction
The Santa Monica Conservancy filed a City Landmark Designation application for the property located at 631 Colorado Avenue (Assessor Parcel Number 4291-023-009) in Santa Monica, California (“subject property” or “property”) in May 2021. That nomination was heard by the Landmarks Commission on January 10, 2022, who voted 4-2 to designate the property, following a recusal by one of the Commissioners. Despite that the property was designated, arguments offered in support of the Landmark nomination are incomplete and misleading and do not adequately support findings of significance.
The hearing record includes detailed reports from two different independent historic preservation consulting firms that professionally evaluated the nomination and both of those reports concluded that the subject property does not satisfy any of the criteria for designation as a City Landmark.
Furthermore, the City staff report prepared for the January 2022 Landmarks Commission hearing recommended that the application for designation should be denied.
I have been asked to render an opinion as well. To that end, I have conducted two site visits, carefully reviewed the nomination and two independent evaluations and the findings of the Landmarks Commission. In addition, I have also consulted various brick experts, examined additional historic photographs and the 2001 architectural plans that guided the extensive remodeling that occurred in 2002. It is my professional opinion that the subject property does not meet any of the City Landmark criteria set forth in the Santa Monica Landmarks and Historic District Ordinance. My resume is attached.
The following memorandum summarizes my research and analysis on which my opinion is based.
City of Santa Monica Landmarks and Historic District Ordinance The City of Santa Monica Landmarks and Historic District Ordinance was adopted by City Council in 1974 and allows the Landmarks Commission to designate City Landmarks that meet one or more of the following criteria:1
1. It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City.
1 City of Santa Monica Municipal Code, Section 9.56.100(A). 631 Colorado Avenue, Santa Monica, CA 2
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.
The Santa Monica Landmarks Commission does not have jurisdiction over the interior spaces of designated Landmarks, with the exception of interior spaces regularly open to the public.2 Previous Evaluations
Historic resource surveys of the City in 1983 and 20113 did not identify the subject property, which indicates the property did not appear eligible as a historic resource at the time of those surveys. It was not until the 2018 Historic Resources Survey update (2018 HRI survey) that the subject property was eventually identified as a potential Santa Monica Landmark. In doing so, the 2018 HRI survey identified the architectural style of the subject property as “industrial vernacular” and described its potential significance as follows:
631 Colorado appears eligible for listing as a Santa Monica Landmark. The property is significant for conveying patterns of industrial development in the Downtown neighborhood of Santa Monica. Constructed in 1937, it is one of relatively few extant industrial buildings in the area from the pre-World War II period.4 Subsequently, the subject property has been more thoroughly assessed in the landmark designation application and the two assessment reports prepared by the two qualified preservation experts. In January 2022, GPA Consulting prepared a “Landmark Assessment Report” for the City of Santa Monica to render a professional opinion about whether the property appeared eligible for designation. Based on research and analysis, the GPA report concluded that the subject property “does not appear eligible under any of the Santa Monica Landmark Criteria.”5 Preservation experts at ESA also prepared a “City Landmark Assessment and Evaluation Report” for the owner of the subject property, dated December 2021, and came to the same conclusion that the property does not meet any of the six criteria for designation.
It is important to distinguish between, on the one hand, the HRI Update survey that considered several thousand properties and on the other hand, a site-specific assessment report focused on a single property, such as those prepared by GPA and ESA. As explained in National Register Bulletin #24, “Guidelines for Local Surveys: a basis for preservation planning,” a reconnaissance-level survey is defined as “a ‘once over lightly’ inspection of an area, most useful for characterizing its resources 2 City of Santa Monica Municipal Code, Section 9.56.110. 3 Additional historic resource survey efforts took place in 1986, 1993, 1994, 1997, 2002, 2004, and 2006. 4 Architectural Resources Group and Historic Resources Group, “Appendix B: 2018 Historic Resources Inventory Update – Individual Resources,” prepared for the City of Santa Monica, January 2017, 46. 5 GPA Consulting, “Landmark Assessment Report: 631 Colorado Avenue,” prepared for the City of Santa Monica, January 3, 2021, 21.
631 Colorado Avenue, Santa Monica, CA 3
in general and for developing a basis for deciding how to organize and orient more detailed survey efforts.” In contrast, an assessment report is a “close and careful look” at one particular property.6 Landmarks Commission Findings
The Findings and Determination of the Landmarks Commission (or “STOA”) regarding the January 2022 Landmark nomination correctly describes that the subject property consists of two buildings: a Main Building, constructed in 1937, and an Auxiliary Building, constructed in 1941. The STOA identify only the Main Building as significant, finding eligibility under two of the six criteria (i.e., Criteria 1 and 4).
7 Under criterion 1, three factors of significance are relied upon for designation of the Main Building:
1. “the first light industrial commercial building in the south-east portion of downtown”
2. “representative of the City’s [economic development] evolution from the 1930s to the present day”
3. “association with Etta Vena Moxley (1870-1950), a dedicated life-long leader in the African American Women’s Club movement”
Under criterion 4, the Main Building at the subject property was found significant for its use of groutlock brick and as “the only known example of post-Long Beach Earthquake transitional engineering techniques for ensuring that brick and mortar structures had seismic integrity.” Analysis
As previously noted, although lengthy, the Landmark nomination relies upon a flawed analysis, and got bogged down with many irrelevant details that distract from a true assessment of significance.
The following provides a more direct and clear analysis for each of the above listed areas of potential significance.
6 Anne Derry, H. Ward Jandl, Carol D. Shull, and Jan Thorman, National Register Bulletin #24, Guidelines for Local Surveys: a basis for preservation planning, (National Park Service, 1977), revised by Patricia L. Parker in 1985. 7 The STOA are muddled, given their unsupported reference to “two contributing structures (page 1),” while at the same time clearly stating that “The Designation includes the structure at the corner of 7th Street and Colorado Avenue, excluding all other stricture[s] on the parcel” (page 4).
631 Colorado Avenue, Santa Monica, CA 4
The subject property was not the first light industrial commercial building in the south-east portion of downtown
The terminology “light industrial commercial building” is unclear and vague. It is more accurate to describe the Main Building typology as a pre-World War II industrial development and eliminate use of the word “commercial.” While there may have been some commercial function through direct beer sales at the property, the primary function was as a warehouse, which is generally considered to constitute an industrial use. A visit to the site clearly shows that this warehouse building was constructed fur use as an industrial building with a simple façade, nearly devoid of decoration, unarticulated side elevations, and a large open floor interior space. The architecture is unremarkable and relatively nondescript, best described as “industrial vernacular” as it was in the 2018 HRI.
Contrary to the Landmark nomination, the Main Building was not the first industrial property of its kind in the industrial area of Santa Monica. While the Landmark nomination ascribes the property’s location as the south-east portion of Downtown, it is more accurate to describe this portion of Colorado Avenue as part of an industrial zone adjacent to the former railroad, and now the Santa Monica Freeway (I-10).
Figure 1 Historic aerial photograph, view east, subject property outlined red, note industrial buildings along Colorado Ave. and south (UCLA Air Photo Archives, 1965)
Figure 2: Detail of historic aerial photograph at left, west elevation of subject property, note two large openings (UCLA Air Photo Archives, 1965)
631 Colorado Avenue, Santa Monica, CA 5
As seen in Sanborn maps, Lincoln Boulevard, contained a mix of commercial and industrial buildings.8 Also seen in historic aerial photographs, this industrial zone, which came to include Colorado Avenue, contained many low-scale industrial buildings (see above Figure 3, for example).
These primary sources documenting this industrial zone are further supported by the 2018 HRI survey, which describes industrial development primarily adjacent to the railroad right-of-way. At the time, this area provided means of easy transport of raw materials and finished goods in and out of the city. As described in the historic context of the 2018 HRI survey, “the effects of the early rail line routing can still be seen on the landscape today through zoning and the continued concentration of light industry uses in the same locations as they were historically.”9 The Main Building at the subject property was not the earliest example of an industrial development around Colorado Avenue, nor is it the last remaining example. Developed well before the subject property, the 1918 Sanborn map shows the Bassett & Nebeker Lumber Yard directly across the street at the southwest corner of Colorado Avenue and 7th Street. Among other examples identified in the 2018 HRI survey are Arden Farms Co / Santa Monica Ice Cream Co. at 1545 12th Street (1928), Alpha Engineering at 2902 Colorado Avenue (1938), and Crescent Cleaners at 1415 Colorado Avenue (1955).
Both primary and secondary sources place the subject property at the northern edge of industrial development in Santa Monica. The subject property was not unique but simply one of many such buildings contributing to the larger trend of industrial development. The subject property has not been shown to be the first or only industrial building in this area of the city and therefore is not eligible under criterion 1.
8 Attachment C of the ESA Report includes pertinent Sanborn Fire Insurance maps. 9 Architectural Resources Group and Historic Resources Group, “Historic Resources Inventory Update – Historic Context Statement,” prepared for the City of Santa Monica, January 2017, 236.
Figure 3: Historic aerial photograph, view northwest, subject property outlined red, note industrial buildings along Colorado Ave. and south (UCLA Air Photo Archives, 1966)
Figure 4: Detail of historic aerial photograph at left, south and east elevations of subject property, note original configuration of south elevation (UCLA Air Photo Archives, 1965)
631 Colorado Avenue, Santa Monica, CA 6
The subject property is not representative of the City’s economic development from the 1930s to the present day
As detailed in the Landmark nomination, as well as the two consultant reports, the following outlines the history of occupants of the subject property:
1937-1953: A.B.C. Distribution Company
1955-1956: Aerophysics Development Corporation
1967-1994: Keystone Autobody Shop
1994-present: various film production offices
None of these occupants appears to have made any significant contributions to their specific industries while occupying the subject property. As described more fully below, the subject property was constructed as a beer distribution warehouse for A.B.C. Distribution Company, a function it retained from 1937 until approximately 1953. Subsequently, the property was occupied by the Aerophysics Development Corporation for a little less than two years. It was one of three buildings the company used simultaneously in this period, and it is not known how the subject property was used by the company. In 1956, Aerophysics Development Corporation became a subsidiary of Studebaker-Packard and moved its headquarters to Santa Barbara. While the company appears to have made advances in the aerospace industry, the subject property does not appear to have been the location of any significant innovation. Between 1967 and 1994, the subject property was occupied by Keystone Autobody Shop, a full-service automobile repair facility. The Landmark nomination provides minimal additional information on Keystone Autobody Shop, and it can be inferred that the company did not innovate anything new in the areas of car repair or service. None of these businesses is noteworthy. (A.B.C. Distribution Company is discussed in greater detail below.) A building’s occupancy by various diverse businesses that may be representative of the types of industries prevalent in Santa Monica over time does not constitute historic significance. Because there is no written guidance on Santa Monica Landmark eligibility, extensive written guidance provided by the National Park Service for the National Register of Historic Places is typically relied upon. National Register guidance states,
“Mere association with historic events…is not enough, in and of itself, to qualify…The property’s specific association must be considered important as well.
For example, a building historically in commercial use must be shown to have been significant in commercial history.”10
While the subject property was used by a variety of owners, there is no evidence that any of the businesses made significant contributions to their specific fields while occupying the subject property. Therefore, the subject property is not eligible under criterion 1 for its contribution to the economic development of Santa Monica.
• A.B.C. Brewing Company is not a rare or significant example of industrial development in Santa Monica
As described in the landmark designation application, 631 Colorado Avenue was constructed as a distribution warehouse for Aztec Brewing Company in 1937, four years after Prohibition was lifted.
Aztec Brewing Company was established in Mexicali, Mexico in 1921, catering to Americans 10 National Register Bulletin #15, How to Apply the National Register Criteria for Evaluation (National Park Service, 1990, revised 2002), 12.
631 Colorado Avenue, Santa Monica, CA 7
traveling to Baja. After prohibition, the company moved its brewing operations to San Diego11 and opened a beer hall in the Logan Heights neighborhood. Murals from the beer hall, painted by Spanish artist, Jose Moya del Pino, depicted traditional Aztec and Mayan imagery.12 By late summer of 1933, there were six distributors of Aztec Brewing Company beer throughout the greater Los Angeles area, each of which had their own franchise.13
While Aztec Brewing Company may convey a significant pattern of economic development in San Diego immediately after prohibition, contrary to the landmark designation application, there is no clear connection between the subject property and Santa Monica’s economy in the 1930s and 1940s.
Unlike the San Diego brewery, the subject property does not “exemplif[y] economic development following the end of prohibition.”14 631 Colorado Avenue was a distribution warehouse for a San Diego-based company; there was never any beer brewed on the premise. There is no information on who received the beer that was distributed, but it is highly likely it did not stay exclusively in Santa Monica. An advertisement from August 1933 notes that the Venice location of the A.B.C.
Distribution Co. distributed beer throughout “Santa Monica, Venice, Ocean Park and Beach Section.”15 It can be assumed that the distribution area remained similar when A.B.C. Distribution Co. moved to the subject property after it was constructed in 1937.
A.B.C. beer was not the only beer option open to thirsty denizens of Santa Monica. The 1934 Los Angeles City Directory lists 10 breweries making beer in Los Angeles.16 While Santa Monica may have taken a “more conservative stance on alcohol consumption at the end of prohibition,”17 there is no evidence to suggest that beer brewed outside the City, such as in Los Angeles, was not distributed in Santa Monica.
Finally, the 1936 Santa Monica City Directory lists two other “Brewers’ Agents” and one “LiquorsDistributors.”18 Of those, Bohemian Distributing Co, located at 2439 Main Street, and Ocean Park Beverage Co, located at 2719 Main Street, are both extant.19 The same year, the 1936 Los Angeles City Directory lists 20 “Brewers’ Agents.”20 While A.B.C. Distributing Co. may have been one of the early beer distributors in Santa Monica, it was by no means the only one, nor is it the last one remaining.
Furthermore, warehousing and distribution was such a common use, it is typically not considered significant at all. There was no actual product made at the subject property and A.B.C. Distribution Company does not appear to have innovated any new techniques of distribution. Therefore, there is no evidence to suggest that the subject property “reflect[s] the elevated stature of the liquor business in that [post prohibition] era.”21 The subject property is not significant under criterion 1 for its association with the A.B.C Distribution Co.
11 Nina Fresco, “City of Santa Monica – City Planning Division: Designation Application,” submitted May 20, 2021. 12 Ian Anderson, “Celebrating 100 years of Aztec Brewing,” San Diego Reader, January 22, 2021, https://www.sandiegoreader.com/news/2021/jan/22/beer-celebrating-100-years-aztec-brewing/.
Many of the murals from the beer hall, also called the Rathskeller, were removed from the brewery before it was demolished in 1990 and reinstalled in the Logan Heights library. (“Aztec Brewing Company,” Chicano Park Museum, https://chicanoparkmuseum.org/logan-heights-archival-project/aztec-brewery/.) 13 “Display Ad,” Los Angeles Times, August 30, 1933, 5; Nina Fresco, “City of Santa Monica – City Planning Division:
Designation Application,” submitted May 20, 2021. 14 Nina Fresco, “City of Santa Monica – City Planning Division: Designation Application,” submitted May 20, 2021. 15 “Display Ad,” Los Angeles Times, August 30, 1933, 5. 16 “Brewers,” Los Angeles City Directory, (Los Angeles: Los Angeles Directory Co., 1934). 17 Nina Fresco, “City of Santa Monica – City Planning Division: Designation Application,” submitted May 20, 2021. 18 Santa Monica and Venice City Directory, (Los Angeles: Los Angeles Directory Co., 1936). 19 Neither 2439 Main Street nor 2719 Main Street were identified in the 2018 Historic Resources Inventory Update. 20 Los Angeles City Directory, (Los Angeles: Los Angeles Directory Co., 1936). 21 City of Santa Monica, “Findings and Determination of the Landmarks Commission of the City of Santa Monica in the Matter of the Designation of a Landmark.”
631 Colorado Avenue, Santa Monica, CA 8
The subject property is not significant for association with Etta Vena Moxley (1870-1950), a leader in the African American Women’s Club movement, as there are no extant buildings associated with Moxley
As explained in great length in the landmark designation application, Etta Moxley, a leader in the African American Women’s Club movement, lived in a house at the subject property from around the turn of the twentieth century through circa 1928, although she owned the property until 1937.
During this period, there were four residential cottages on the subject property and a small commercial building. All but one of these five buildings were demolished in 1937 to allow for construction of the existing building at 631 Colorado Avenue. The last building was demolished by 1965. There are no buildings left from the period when Etta Moxley lived at the property. The two buildings at the property date from 1937 and 1941, after Etta Moxley had moved to another location and sold the property.
As described in the landmark designation application, Etta Moxley was one of the founding members of the Monday Women’s Club, located at 1209 East 6th Street in the Oakwood neighborhood of Venice, which was designated a City of Los Angeles Historic Cultural Monument #1203 in 2020. The clubhouse is significant as an important reminder of black women in Venice who banded together for social interaction and were actively engaged with improving their community. In addition to her involvement in the Monday Women’s Club, Etta Moxley was also very active in the state-wide California Association of Colored Women’s Clubs, serving as its fourth president between 1912 and 1914.22 During her tenure, she supported the establishment of the Sojourner Truth Home in 1913, located at 1119 East Adams Boulevard (extant), the first collective effort undertaken by black women’s clubs throughout Southern California that initially provided living quarters and job training for unmarried women and single mothers.23 Etta Moxley is indeed an important individual whose accomplishments should be brought to wide public attention. However, the property at 631 Colorado Avenue is not the correct location to commemorate her life and work as there is nothing tangible left from the period of her residency.
According to Santa Monica Municipal Code, Section 9.56.030, an improvement appropriate for designation includes “Any building, structure, place, site, work of art, landscape feature, plantlife, life-form, scenic condition or other object constituting a physical betterment of real property, or any part of such betterment.” As there is no improvement at the subject property associated with Etta Moxley, this location is not eligible for designation for this association. Furthermore, there is no basis in the Santa Monica Landmarks Ordinance to designate this property for its past association with the resident of a home that itself no longer exists.
The National Register provides additional guidance on eligibility. National Register Bulletin 32:
Guidelines for Evaluating and Documenting Properties Associated with Significant Persons requires that, “a property must retain integrity from the period of its significant associations.” As described more fully below, integrity refers to the ability of a property to convey its significance. In other words, a property must generally appear as it did when it gained significance. One test is “whether the significant person(s) associated with the resource would recognize it as it exists today.”24 The subject property would most certainly not pass this test. Etta Moxley would not recognize the buildings at the subject property as her former home.
22 California State Association of Colored Women's Clubs, Inc., “California State Association of Colored Women's Clubs, Inc. booklet,” (African American Museum & Library at Oakland: 1953). 23 Douglas Flamming, Bound for Freedom: Black Los Angeles in Jim Crow America (University of California Press, 2005), 139. 24 Beth Grosvenor Boland, National Register Bulletin 32: Guidelines for Evaluating and Documenting Properties Associated with Significant Persons (U.S. Department of the Interior, National Park Service), 23. 631 Colorado Avenue, Santa Monica, CA 9
As aptly and succinctly noted in the GPA report:
Because the built environment only reflects certain aspects of the importance a community, space, or neighborhood may have, place-based historic designation programs do not fully or accurately capture history that may be intangible or lost.
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.25
The City of Santa Monica should strive to communicate the significance of Etta Moxley in a wide variety of meaningful ways. Identifying a site with no physical evidence of Moxley’s life and work does not convey her important role in local history, while some of the above-listed strategies for historical interpretation could better represent her accomplishments.
The subject property is not significant for its use of groutlock brick, which was never an important building material
Groutlock brick was a brand of reinforced brick masonry produced by the Simons Brick Company for a relatively short period of time between 1932 until approximately 1942. Reinforced brick masonry is a type of building material that incorporates steel reinforcement embedded in mortar or grout that increases “resistance to forces that produce tensile and shear stresses.”26 Reinforced brick masonry was first used in the beginning of the nineteenth century in England. One of the earliest uses of reinforced brick masonry was at the Palace Hotel in San Francisco in 1887 that, due to the steel reinforcing, survived the 1906 San Francisco Earthquake. An article published in 1933 estimated about 40 “individual jobs” utilized reinforced brick masonry and “approximately 50 additional jobs are either under construction or under consideration in various parts of the country.”27 The 1933 Long Beach Earthquake initiated substantial changes in the building code, requiring additional reinforcement. These changes to the building code took nearly a decade to put into practice.28 After World War II, use of reinforced brick masonry became common, typically utilizing a hollow within the brick to vertically install reinforcing steel.29 Simons Brick Company heavily advertised their product in local newspapers, highlighting a variety of buildings that used groutlock brick, including residential, industrial, and commercial properties.
Simons groutlock brick retains typical dimensions along the visible elevations with a void at the rear that allows for a horizontal reinforcing rebar. Although Simons produced 150,000 bricks a day in 1933,
30 groutlock bricks were only a small fraction of their total product line. Ultimately, groutlock brick did not take hold and they have come to be regarded as “gimmicky.”31 25 GPA Consulting, 5-6. 26 The Brick Industry Association, “Technical Notes on Brick Construction: Technical Notes 17 – Reinforced Brick Masonry – Introduction,” Reissued October 1996, https://www.gobrick.com/read-research/technical-notes. 27 The Brick Industry Association, “Technical Notes on Brick Construction: Technical Notes 17 – Reinforced Brick Masonry – Introduction,” Reissued October 1996, https://www.gobrick.com/read-research/technical-notes. 28 Richard Rydel, Executive Director, Masonry Institute of America, phone conversation with Jenna Snow, March 23, 2022. 29 Michael Schuler, P.E., President Atkinson-Noland & Associates, phone conversation with Jenna Snow, March 23, 2022. 30 “Factories Throughout City Increasing Production,” Los Angeles Times, May 21, 1933, 16. 31 Josh Higgins, phone conversation with Jenna Snow, March 30, 2022. Josh Higgins is a seventh-generation brick manufacturer. His grandfather, Robert Higgins, founded Higgins Brick & Tile Co. in 1927, which later bought out Simons Brick Co. in Santa Monica.
631 Colorado Avenue, Santa Monica, CA 10
With regards to evaluating the significance of a property for its method of construction, National Register guidance states:
A structure is eligible as a specimen of its type of period of construction if it is an important example (within its context) of building practices of a particular time in history. For properties that represent the variation, evolution, or transition of construction types, it must be demonstrated that the variation, etc., was an important phase of the architectural development of the area of community in that it had an impact as evidenced by later buildings. A property is not eligible, however, simply because it has been identified as the only such property ever fabricated; it must be demonstrated to be significant as well.32
Although the Main Building at the subject property may have used a reinforced groutlock brick, this method of construction does not appear to be historically significant. Like many brick buildings in the 1930s, the method of construction appears to be somewhat experimental, before the new building code was established. Its use at the subject property does not appear to have influenced any other nearby building, nor did it change the code. Finally, groutlock brick had a relatively short life and did not become the dominant type of reinforced brick masonry in the post-World War II era.
Given all these considerations, it cannot be said that the building material or method of construction is significant.
The Main Building does not retain integrity from its date of construction, 1937, as the appearance of 631 Colorado Blvd has changed considerably over time. 631 Colorado Boulevard has undergone substantial changes since it was constructed in 1937 and does not retain integrity. Typically, for a property to be eligible for designation, it must meet at least one eligibility criterion listed above and retain sufficient integrity to convey that historic significance.
Integrity is defined as physical and visual characteristics necessary to convey significance. Evaluation of integrity is founded on “an understanding of a property’s physical features and how they relate to 32 National Register Bulletin #15, How to Apply the National Register Criteria for Evaluation (National Park Service, 1990, revised 2002), 18.
Figure 3: South elevation, view northwest (Santa Monica History Museum, 1945)
Figure 4: South elevation, view northwest, red highlights show areas of alteration (Snow, 2022)
631 Colorado Avenue, Santa Monica, CA 11
its significance.”33 The seven aspects of integrity are Location, Design, Setting, Materials, Workmanship, Feeling, and Association. To satisfy the integrity requirement, a property must retain at least a majority of seven aspects.
While the Main Building at the subject property retains integrity of location (as it has not been moved), it lacks integrity of design, materials, and workmanship. Primary alterations include:
replacement of all window and door openings, including replacement of window sash and relocating the primary entrance from the south elevation to the west elevation; an addition to the north elevation; and sandblasting of all visible elevations at least twice, changing the appearance of the brick.34 Because of these alterations diminishing integrity, the Main Building cannot convey its feeling and association as an industrial building. The subject property does not resemble its historic appearance, neither from 1937 nor from the 1960s. Even if the property were to be found to have significance, it does not retain sufficient integrity to convey that significance.
Conclusion
This memorandum confirms the findings in two prior assessment reports prepared by GPA Consulting and ESA, respectively, as well as the City staff report prepared in preparation of the Landmarks Commission hearing in January 2022. As demonstrated in the earlier reports, as well as this memorandum, the Main Building at the subject property is not significant under criterion 1. As an industrial building, it contributed to the evolution of industrial development in Santa Monica along the early rail line, a zone which included Colorado Boulevard by the 1910s. It was not the earliest industrial building in the area, nor is it the last. None of the business that occupied the building were shown to have made significant contributions to their specific fields while occupying the subject property. Finally, there are no extant buildings at the subject property associated with Etta Moxley. Under criterion 4, while the building may have used groutlock brick construction, this is not a historically significant method of construction. Further, there is no evidence that its use in the Main Building influenced its use in any other building activities in the area. The Main Building at 631 Colorado Boulevard does not rise to the level of significance to warrant designation as a City of Santa Monica Landmark.
33 Rebecca H. Shrimpton, editor, How to Apply the National Register Criteria for Evaluation (Washington, DC: National Park Service, Department of the Interior, 1998) 44, <http://www.nps.gov/history/nr/publications/bulletins/nrb15/>. 34 The north elevation is not accessible due to the closeness of the adjacent building to the north.
Figure 6: Historic aerial photograph, west elevation, note two large openings (UCLA Air Photo Archives, 1965)
Figure 7: West elevation, view east, red highlights show areas of alteration (Snow, 2022)
QUALIFICATIONS
JENNA SNOW
In January 2015, Jenna Snow launched an independent historic preservation consulting practice with offices in Los Angeles. With twenty years of professional experience, Ms. Snow has a strong and broad understanding of best historic preservation practice, including federal, state, and local regulations.
Throughout her career, Ms. Snow has authored, co-authored, and/or served as project manager for over 100 historic preservation projects, including a wide variety of historic resource assessments, National Register, California Register, and local nominations, as well as historic resources surveys. She regularly contributes to environmental impact reports, historic preservation certification applications, Section 106 reviews and other work associated with historic building rehabilitation and preservation planning. For five years, she served on the board of the South Carthay Historic Preservation Overlay Zone in mid-city Los Angeles.
PROFESSIONAL EXPERIENCE
Jenna Snow, Historic Preservation Consulting, January 2015-present Chattel, Inc., Los Angeles, CA, July 2002 – December 2014 International Council on Monuments and Sites, Transylvania Trust Foundation, Cluj-Napoca, Romania, Fall 2004
Neighborhood Preservation Center, New York, NY, Spring 2002 New York City Department of Design and Construction, Historic Preservation Office, New York, NY, Summer 2001
The Freedom Trail Foundation, Boston, MA, January 1999 - October 1999
SELECTED PROJECTS
Temple Ohave Israel (Brownsville, PA) – Prepared a National Register nomination for a 1919 synagogue located in a small, economically depressed town of western Pennsylvania. The synagogue, significant as an anchor for the small, but influential Jewish community of Brownsville, PA, was listed in the National Register in February 2016. Listing in the National Register makes the property eligible for state grants to maintain the building, including replacement of a much needed roof.
Hawk House (Los Angeles, CA) – Prepared a successful Historic Cultural Monument nomination for a 1939 single family residential house designed by renown Los Angeles architect Harwell Hamilton Harris for Stan and Ethyl Hawk.
The house severed as the headquarters for the furnishing company “Hawk House.” Chuey House (Los Angeles, CA) - Prepared a Historic-Cultural Monument nomination for a single family residence designed by one of the most influential Los Angeles architects, Richard Neutra, in 1956. As the property was for sale, the house was threatened with demolition. While the nomination was ultimately withdrawn, it served as a negotiation tool for the Los Angeles Conservancy.
Frank’s Camera (Los Angeles, CA) – Completed a Historic Structures Report in support of a Mills Act Contract for a former S.H. Kress & Co., a five-and-dimestore. A contributor to the Highland Park-Garvanza Historic Preservation Overlay Zone, the building was constructed in 1928 and is undergoing a rehabilitation to convert the building to smaller retail spaces. The building serves as a visual and economic anchor to the revitalizing commercial strip along North Figueroa.
Monday Women’s Club (Los Angeles, CA) - Prepared a historic resource assessment for a black women’s club in the Venice neighborhood. Moved to the site in 1926, the building on the property was proposed for demolition. Worked with the project team on a focused EIR that studied alternatives.
EDUCATION
Columbia University in the City of
New York, Master of Science in
Historic Preservation, 2002
Brandeis University, Bachelor of
Arts in Fine Arts, 1998
QUALIFICATIONS
Secretary of the Interior’s
Professional Qualifications
Standards in Architectural History
LEED GA
AWARDS
Rosalind W. Levine Prize for
excellence in Fine Arts, June 1998
COMMUNITY
INVOLVEMENT
Secretary, South Carthay Historic
Preservation Overlay Zone Board,
2011-2016
Pick Leader, Food Forward, 2011-
present
Los Angeles Conservancy
ModCom Working Group, 2013-
2014
Guest Editor, The Next American
City, Fall 2006, Issue 12
New Orleans recovery team from
Western Regional Office of the
National Trust for Historic
Preservation, February 2006
Jenna Snow ● Historic Preservation Consulting ● 323/317-3297 ● [email protected] Additional Projects:
Commodore Apartments (Los Angeles, CA) - Process Investment Tax Credit application for a 1926 Hollywood apartment building that completed a major rehabilitation project. The rehabilitation carefully restored the primary façade, which had experienced multiple alterations over the years.
West Los Angeles Veteran’s Affairs (Los Angeles, CA) – Between 2010 and 2014, prepared Section 106 review and consultation for the first of 11 buildings that are undergoing seismic retrofit and limited rehabilitation. The buildings will be reused to house veterans who are homeless. The rehabilitation won a Los Angeles Conservancy award. Also prepared a successful National Register nomination for the whole campus, which was listed in November 2014. Work was done at Chattel, Inc. as a subconsultant to Leo A. Daly.
West Los Angeles Veteran’s Affairs Building 205 and Building 208 (Los Angeles, CA) - Process Investment Tax Credit application and Section 106 review for two buildings out-leased to a nonprofit developer. The two buildings will be rehabilitated to house homeless veterans. Work is estimated to be complete in 2021.
Boyle Hotel/Cummings Block (Los Angeles, CA) – Completed Investment Tax Credit Application and National Register nomination for 1898 hotel in Boyle Heights neighborhood of Los Angeles. The building has been reused to house low-income residents of Boyle Heights and has been a catalyst for economic rehabilitation in the neighborhood. The rehabilitation won a Los Angeles Conservancy award, as well as a National Preservation Honor Award. Work was done at Chattel, Inc. for the East Los Angeles Community Corporation.
Breed Street Shul Project, Inc. – Project Manager for Phase 1 seismic stabilization and stained glass window restoration. Provided design review and construction monitoring and prepared historic review documentation for local environmental review. Consulted with federal agencies on Section 106 compliance for a FEMA grant and a federal appropriation. Work was done at Chattel, Inc.
Historic Resources Survey Update (Los Angeles, CA) - Served as the project manager for preparation of historic context statements and intensive-level historic resource survey. The survey were prepared in close coordination with the Los Angeles Office of Historic Resources to dovetail into SurveyLA. Surveyed approximately 3,000 properties, including property-specific research on approximately 400 of these properties. Attended several public hearings at both the beginning and end of the process, as well as presented at nearly a dozen neighborhood council meetings. Work was done with Chattel, Inc.
Judson Rives Building (Los Angeles, CA)– Completed Investment Tax Credit Application for a 1908 office building in downtown Los Angeles, a contributing resource to the Broadway Historic District that was converted to residential use. Work was done at Chattel, Inc.
Hollywood Profession Building (Los Angeles, CA) - Completed Investment Tax Credit Application for a 1926 office building on Hollywood Boulevard. The building is significant not only for its distinctive Neo-Gothic style, but also with for its association with former United States President Ronald Reagan. The office building was converted to residential use. Work was done for Chattel, Inc. for CIM Group.
Residential Survey (Whittier, CA) - Prepared a historic context statement focusing on architectural contexts and themes connected with residential development in Whittier. Feld surveyed approximately 1,540 properties generally constructed prior to 1941 using an Access database incorporating GIS mapping to collect survey data in the field. The survey was prepared in close coordination with the City of Whittier staff and Historic Resources Commission and was adopted by the City of Whitter in 2015. Work was done with Chattel, Inc.
SurveyLA City of Los Angeles (Office of Historic Resources) – Participated in completing a historic resource survey of over 97,000 properties in South and Southeast Los Angeles. Co-authored historic context statement of Los Angeles’ industrial history. Work was done at Chattel, Inc.