(310) 451-3669
June 10, 2022
VIA E-MAIL
Santa Monica City Council
1685 Main Street, Room 102
Santa Monica, CA 90401
Re: Agenda Item 6-B (landmark appeal of brick building) Appellant/Property Owner: 500 Pounds of Dog, Inc. (Michael Bay) Address: 631 Colorado Avenue
Appeal 21ENT-0253/Designation Application 21ENT-0067
Our File No. 22688.001
Dear Councilmembers:
This letter is written on behalf of Michael Bay, the owner of the property at 631 Colorado Avenue. For the past 20 years, he has operated his feature film business (Bay Films) at this location. He has recently relocated out of State and wishes to sell this property. In connection with listing the property for sale, Mr. Bay filed a demolition permit application, which triggered its 75-day review because the building is more than 40 years old. At that time, the property was under contract for sale to a mixed-use residential developer. (The property has been listed in the last two Housing Elements as a site suitable for residential development.)
Upon learning of the demolition permit application, the Santa Monica Conservancy filed an application to nominate the property as a City Landmark (which they have a right to do and which is the only process for initiating review of demolition permits). Planning Commissioner (and former Landmarks Commissioner) Nina Fresco filed her own research in support of the nomination.
The Landmarks Commission, in a divided 4-2 decision, voted to designate the Main Building as a City Landmark and the property as a Landmark Parcel. Following that vote, the property fell out of contract for sale to the residential developer.
The Landmarks Commission’s Architectural Historian (Dr. Ken Breisch) voted against the designation and was an outspoken critic of the designation, as was the Art Conservator on the Commission (Amy Green). The Commission’s licensed architect (Richard Brand) was unable to participate in the vote due to the proximity of his residence to the site. Mr. Bay appealed the 4-2 decision to the City Council. [email protected]
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We are writing in support of: the Staff Recommendation, the City’s independent expert (GPA Consulting), Landmarks Commissioner Dr. Breisch, another historic preservation consultant whom the City often hires (ESA/Dr. Jerabek-Bray), and a historic preservation consultant I hired to peer review the reports and perform her own supplemental research (Jenna Snow).
All of the experts conclude that the property does not merit designation.
Consistent with the expert reports, the City Council should grant the appeal, and overturn the designation. This is a de novo hearing and a quasi-judicial proceeding, and there is abundant evidence in the record in support of the appeal.
Please keep in mind that the designation of City Landmarks should be reserved for special buildings. This building (constructed in 1937) is not a special building.
Declaring marginal buildings to be City Landmarks waters down the importance of the City’s truly historic properties. The third party independent experts all agree that this building is not any more notable than many industrial brick buildings found in Santa Monica and throughout Southern California.
Moreover, this building has been substantially altered (and degraded by sandblasting at least twice and the grout has been poorly repointed) over the years.
For the reasons stated in the Staff Report, the property owner (or a future purchaser) should be allowed to demolish the building.
Finally, it is important to keep in mind that none of the buildings currently found at 631 Colorado existed when prominent African American Etta Moxley owned and lived on the property. There is no disputing that the Landmarks Ordinance simply does not allow for designation of a property based on a past house that no longer exists. As the Staff Report thoughtfully explains, there are many other civic ways that Ms. Moxley’s notable accomplishments and leadership can be commemorated:
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. (Staff Report, p. 8.)
I will conclude by quoting extensively from Professor Breisch, who summed things up quite powerfully at the Landmarks Commission hearing:
Yes, I would say I’m not very happy with this, the way it’s moving forward, for a number of reasons. I think there is a Item 6.B
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major question on integrity that’s lacking here. And that I don’t think the building really reflects--I don’t know what it reflects . . .
I’m a little confused by the statement of significance in terms of the reinforced masonry construction, which I don’t think has been proven one way or another. And I went and looked very closely at it, and I couldn’t figure out exactly what was going on, I have to say. And that was in no small part
because the building’s been sandblasted twice. And in terms of the significance of materials and workmanship, for
example, it’s not there.
So, if we’re looking at this building as an example of a particular type of masonry construction, it doesn’t exist anymore. Sandblasting is really a major problem in terms of not just designation, but of course, the way you treat
buildings after they’ve been designated. And this thing has just been decimated. And it’s been repointed to the point where it’s just pretty disgusting workmanship.
So, if we’re sort of mixing these things together, there are new windows, the entry’s been moved and really there’s no integrity whatsoever to this structure in terms of the
masonry, and whether it’s groutlock or not, which I really am doubtful about. So, the thing we’re designating should really reflect something of the history of the place. And if it’s been so altered with sandblasting in the ‘50s and changing
windows and moving entryways, then I just don’t see that working for me.
I am absolutely sympathetic to recognizing the earlier
African-American neighborhood and community that was
there, but I don’t think this is really the place to do it . . .
There’s a wonderful memorial to Biddy Mason in Downtown LA, but that’s not a historic landmark. It commemorates what was there and is no longer there, that’s been erased, and that’s what we’ve got here. So, that bothers me too, I think, to be recognizing that.
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With all due respect Commissioner Sloan, I think that there were previous occupants before the African-Americans were there. And I think we have a park just down the street [i.e., Tongva Park] that recognizes that as well.
It’s just bothersome to me that we keep layering on these things that don’t really reflect the nature of the Landmark Ordinance and what it’s intended to do. So, that’s my
problem.
To use a real important architectural technical term, it’s cute.
But I don’t think it rises to the level of being a landmark.
I don’t think it rises to that level.
Conclusion
We urge the City Council to agree with the Staff Recommendation and grant the appeal and overturn the designation of this property.
Very truly yours,
Kenneth L. Kutcher
KLK:sna
cc: Stephanie Reich
David Martin
David White
Heidi von Tongeln
Douglas Sloan
Michael Bay
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1 Vernice Hankins
From: Ruthann Lehrer <[email protected]>
Sent: Monday, June 13, 2022 11:45 AM
To: councilmtgitems; Sue Himmelrich; Gleam Davis; Lana Negrete; Kristin McCowan; Phil Brock; Oscar de la Torre; Christine Parra
Subject: Item 6B: Landmark designation appeal on 631Colorado
EXTERNAL
June 13, 2022
Item 6B: Appeal of Landmark Designation for 631 Colorado Avenue
Honorable Councilmembers,
This letter supports the Landmark designation of the Main Building at 631 Colorado Avenue, and requests that you deny the appeal.
The property owner who has requested demolition has commissioned additional reports from historic preservation consultants to undermine the findings of the STOA that was approved by the Landmarks Commission. The findings of those reports are designed to satisfy the client and can be understood in that light. The GPA report, which the City commissioned, was refuted during the public hearing on the landmark application, and the STOA convincingly explains the reasons why this building is significant under the Santa Monica criteria for designation. I note that we use the local Santa Monica criteria for assessing significance, and not the National Register criteria.
Our landmarks are selected because they tell the stories that are important to understand Santa Monica’s history and our development. We don’t require such buildings to be the first, the only or the most important conveyance of such history, but – as Criteria 1 states:
It exemplifies, symbolized or manifests elements of the cultural, social, economic, political or architectural history of the City.
The stories that 631 Colorado manifests are:
The expansion of commercial uses southward in our downtown, replacing former residential buildings, exemplifying the growth of our business economy in Depression‐era economic recovery; A new beer distribution business locating downtown that symbolized the end of prohibition; A succession of uses that exemplifies our economic development, from beer distribution to aviation to automotive to films. The sequence itself tells a story.
Criteria 4 can be confusing as it combines a cluster of different concepts for assessing architectural and material characteristics. This building is significant under the first phrase:
It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction…
The masonry construction is valuable to a study of post‐Long Beach Earthquake response to vernacular building construction addressing seismic stabilization. That 1933 earthquake was a major regional geological event which had enormous consequences to urban development. Groutlock bricks were an innovative Item 6.B
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2 technology which exemplify one response, even if that innovation did not become popular or enduring. The concrete bond beams are another visible response to seismic issues.
The fact that the bricks have been sandblasted is unfortunate but is never considered sufficient to disqualify a property from meeting criteria for designation. Such afflictions are found on many landmarked buildings (i.e.
Palisades Building at the Miramar; the Keller Block downtown). This argument to disqualify landmark status is way overblown.
Additionally, the Streamline Moderne façade is a classic embodiment of that style, with the grooved pilasters, the repeat of three horizontal lines (known as “speed lines” in architectural terminology), and the three‐ stepped pilaster caps. Its use on the façade of this vernacular building is valuable to a study of the architecture of this period. While the façade windows are not original, they are entirely consistent and compatible with the character of the building.
Finally, I would like to remind you of other developments in Santa Monica that have combined preservation of a small landmarked building into a larger project:
Rapp Saloon with Hostelling International
Pono Burgers in a housing development
Nikkei Hall in a housing development
Palisades Building and Moreton Bay Ficus in the Miramar development Two small landmarked structures on Ocean Avenue into the Frank Gehry project.
The corner location of the landmarked building facilitates its incorporation into a new project, and there are incentives for doing so (i.e. Mills Act Historic Property Contract).
Finally, a word about professional qualifications. I am certified as a historic preservation professional, validated by the State Office of Historic Preservation during my tenure as historic preservation planner with the City of Long Beach. While Nina Fresco lacks an advanced degree in this field, she utilizes professional methodology of historical research, using a wide number of primary sources and investigating historical context as reflected in newspaper articles, journals and diaries, and deriving a narrative from these materials.
She has been researching a book on Santa Monica history for a number of years and can draw upon a vast trove of information.
Please deny the appeal, support the Landmark Commission findings, and preserve an important piece of the Santa Monica story.
Thank you for your consideration.
Sincerely,
Ruthann Lehrer
Former Landmarks Commissioner, architectural historian
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1 Vernice Hankins
From: Karen Wise <[email protected]>
Sent: Tuesday, June 14, 2022 11:06 AM
To: councilmtgitems
Subject: City Council Agenda Items 6A. and 6B
EXTERNAL
Dear Members of the City Council:
I write regarding Agenda Items 6A. and 6B, I urge you to please follow staff recommendations to repealing two recent landmark designations. Specifically
Agenda Item 6A. Follow staff recommendations to:
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.
Agenda Item 6B. Follow staff recommendations to:
1. Approve Appeal 22ENT‐0015, appeal of the Landmarks Commission’s decision to designate the property located at 631 Colorado Avenue as a City Landmark; and
2. Deny Designation Application 21ENT‐0125 to designate the property located at 631 Colorado Avenue as a Landmark or Structure of Merit.
It is not clear that either of these buildings fits national standard criteria for landmark status.
As we work towards the Santa Monica of the future, I believe that we should build wider and more inclusive conversations about the criteria for what gets preserved and why, as well as how limiting that should be for what can be done. Preservation of some buildings is critical, and it is not the only way to commemorate or to learn from history.
Documentation, mitigation and interpretation are more effective and appropriate in some cases, and we need to build a more coherent and transparent set of criteria and process for decision making.
Thank you very much. Sincerely
Karen Wise, Ph.D.
Santa Monica
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P.O. BOX 653
SANTA MONICA, CA 90406
310-496-3146
www.smconservancy.org
631 Colorado Avenue
Appeal of Rebuttal from Applicant for Designation
631 Colorado Avenue clearly qualifies as a Santa Monica Landmark based on the findings adopted by the Landmarks Commission at the January 10, 2022 designation hearing. The appeal should be denied.
631 Colorado Was the First Commercial Structure in a Historic Residential Neighborhood 631 Colorado Avenue is significant to Santa Monica history under two Landmarks Designation criteria, 1 & 4. It is significant to Santa Monica history as the first, and also the last example of a single-story industrial-style commercial building that began the transformation of one of the earliest residential sections of the city, home to working class whites, and people of color since the first lots were sold here. The significance of this resource is enhanced by the range of uses it saw, which were emblematic of trends in the city during their periods of occupancy. The structure’s construction was influenced by major historic events of its time reflected in its style and method of construction, and reflects city planning and zoning history.1 This is clearly laid out and explained in the findings for designation adopted by the Landmarks Commission in the January 10, 2022 STOA (Attachment K). It provides a snapshot of Santa Monica in 1937. To see this, we have to consider the historical context of the immediate vicinity.
Our Local Ordinance is not the Same Thing as the National Register The appellant’s analysis of the subject property promises to streamline details in the original application, which it considers “irrelevant” allowing the appellant to find significance only in the biggest and brightest flashes of success, wealth, innovation, and progress. The appellant’s analysis repeatedly falls back on National Register bulletins to justify a glossing over and distancing from local narratives. If we were proposing a parcel in Santa Monica for National Register listing, we would follow the direction in the bulletins to the letter. We aren’t.
As our city attorneys will remind you, Santa Monica’s historic preservation program is ruled by our local Landmarks Ordinance that includes codified criteria and employs a locally tailored application form. We do not use the National Register criteria or application. Our Santa Monica criteria are in some ways similar to national criteria, but purposefully modified in language and interpretation to capture the kinds of resources that are important for narration of Santa Monica history. In fact, that is how the National Register guidance instructs us to proceed on 1 Note: the subject structure is a commercial building where liquor sales took place, and also included a warehouse, which gives it an industrial aspect. Since industrial uses have never been permitted on this site, it would be incorrect to call it an industrial building, and since it includes a warehouse space, it is clearly also not strictly commercial.
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the local level. The National Register reminds us that all places are part of their local community, which best understands the importance of those places, and how to protect them from change or loss likely to impact them. For example, a National Parks Service website encouraging the establishment local historic districts includes the following to introduce the topic (emphasis added):
Local legislation is one of the best ways to protect the historic character of buildings, streetscapes, neighborhoods, and special landmarks ….
2 In Santa Monica, Landmarks and Historic Districts include places that represent the range of lifestyles, property types, and cultural influences that make up the city’s history. They convey a spectrum of local narratives, not only the stories of rich white men who attract our attention with dazzling accomplishments and glamourous architecture. Nonetheless, literature guiding interpretation of national criteria for designation is often, as in this case, weaponized against our local preservation program by property owners and their attorneys seeking to avoid designation.
Accuracy Counts: It was a Residential Neighborhood of Color The subject property was not ever located in an industrial zone of the city. That is a factually incorrect assumption made by the appellant in the following claim on page 4 of the Snow report (Attachment J):
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).
Images used by the appellant in figures 1, 2, 3, and 4 of the report submitted by Ms. Snow to support this completely conjectural claim are all from the 1960s, which was after the entire area had been transformed with redevelopment that followed the pioneering construction of the subject property by almost 3 decades. A complete set of maps and images in the original application (Attachment D) ranging from 1895 – 1960 shows the actual historic character of the subject district as residential until sometime after 1950. Furthermore, though there was not a zoning ordinance as we think of it today in Santa Monica until 1922, the city did have laws on the books directing where certain uses could or could not be, beginning in the 1890s. In June 1912, Ordinance No. 159 defined limited locations where industrial manufacturing uses would be allowed. The industrial zone was generally between the centerlines of Olympic and Colorado Boulevards with some variation on the east and west ends. West of Lincoln Boulevard adjacent to downtown, the boundaries jogged around two lumberyards that predated the ordinance (and were developed with wooden sheds very different from the subject property type). The rest of the 1912 boundary west of Lincoln Boulevard was set back away from the residential district that would someday host the present structure by a full block. The industrial area did 2 https://www.nps.gov/tps/education/workingonthepast/index.htm Item 6.B
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not begin in the area of the subject property and “come to include Colorado Avenue,” as the appellant falsely claims, again referring to the four irrelevant 1960s images as evidence. Next, the applicant blithely lists sites in other parts of the city that developed under completely different contexts as alleged comparables. Buildings are not isolated events. Context is everything. Beginning in the 1940s, the part of the actual industrial zone that is west of Lincoln did not come to accommodate more industry as the appellants report assumes, but in fact was overtaken by a large residential trailer park that accommodated a huge influx of wartime aircraft workers (see images in Attachment D for evidence).
The residentially zoned neighborhood of which the subject property was a part was home to working class whites, African Americans, Mexicans and other people of color since the first lots were sold in the city. In 1922, new zoning classified the area a commercial or “C” Zone. “C” Zones allowed residential uses but prohibited industrial manufacturing. With “C” zoning in place, the residential areas on 5th, 6th, and 7th Streets, including the subject property, were poised for commercial redevelopment, but change did come not right away. 631 Colorado’s Style and Method of Construction Tell Us About its Era In the late 1930s, recovery from the Great Depression began to impact the already established commercial district of downtown on 2nd, 3rd, and 4th Streets. There was plenty to do on those blocks, so growth didn’t extend east of there for the first time until 1937 when the subject property was constructed by the ABC Distributing Company. The ABC Distributing Company adorned its new warehouse and sales office structure with art deco/streamline modern characteristics. The look was consistent with the architectural moves in the rest of downtown, and provided a respectable street presence for the liquor business. It was not the only liquor outlet in the city for long, and obviously a business big enough to occupy a property this size would sell its wares beyond the borders of Santa Monica, but it was the first of note in Santa Monica, and the only liquor business to invest in a new brick building using the latest trends in brick technology along with some popular architectural detailing, however slight. Because of the use of period-specific materials and an uncommon application of detailing for its building type in Santa Monica, the property also qualifies under Santa Monica Landmark Designation Criterion 4 as a rare example of a historic method of construction and use of detail valuable for study.
As for the bricks, neither Groutlock nor Porta Costa bricks changed the world in the long term and were not described in that way in the findings. The bricks convey a historical narrative that took place when the Great Depression collided with 1933 Long Beach Earthquake, two disasters of epic proportions. Once again, the appellant loses track of the fact that we are preserving buildings that are records of particular moments in time that show how we lived, worked, and in the case of these bricks, solved problems. The appeal statement dismisses Groutlock and Porta Costa bricks because “they have come to be regarded as gimmicky.” Historians are supposed to record history, not judge it. Regardless of how they “have come to be regarded,” the bricks represent a specialized construction solution particular to their time and are worthy of study. Note that the Smithsonian Museum has an 8-track tape player in its collection. Also Item 6.B
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considered gimmicky, 8-track players nonetheless represent a moment in history worth knowing about.
631 Colorado is the Last of its Kind in Downtown
In the 1950s, just as with the well-documented story of the Belmar area, this section of downtown was marked as blighted and slum clearance activities took place. It was not taken over by eminent domain, but the city ordered a number of the old homes, still occupied by people of color, to be demolished. Because segregation made it more difficult for people of color to find places to live in the city, they typically helped their fellows by passing homes they occupied to other people of color by sale or rental, a fact documented on the real estate pages of the Santa Monica Outlook, and also apparent through detailed study of Santa Monica census records. So, it took the aggressive, national slum clearance movement of the 1950s to open up the commercially zoned lots immediately adjacent to the center of downtown for redevelopment. By the 1960s, when the aerials in Figures 1, 2, 3, & 4 of the appellant’s report were taken, the residential neighborhood visible in more germane earlier aerials provided by the applicant (see original application, Attachment D) was gone without a trace. It had been replaced with one- and two-story commercial buildings, and a handful of apartments. In recent decades, all of the second phase structures except for the subject property, have been redeveloped, or have already approved plans. The subject property is not only the first of its kind, it is also the last of its kind in the downtown.
Erased Stories of People of Color are Critical to the Context of Santa Monica History The improvements on this parcel meet two of Santa Monica’s Criteria for Landmark Designation, and a narrative related to the city’s community of color is part of its predevelopment context. A racial justice framework, an analytical tool we hope to develop to take advantage of our historic preservation program’s potential to further racial justice education in the city, comes into play. Etta Vena Moxley, a historic figure even the appellant acknowledges is highly significant, spent her entire adult life living and working in Santa Monica. Her home of 30 years has been redeveloped, but her story still has a place in the context of the qualified landmark that replaced it at 631 Colorado Avenue. Staff determined the negative race story at Appian Way, not in their view associated with extant improvements on the site, should not be considered in making a landmark designation determination. Likewise, recognition of this inspiring and uplifting narrative was also dismissed for a lack of association with extant improvements. This approach may seem even-handed or fair, but from a racial justice perspective, we may not wish to treat both those stories the same way. By not referring to Etta Moxley in the contextual background of the site, which Criteria 1 allows us to do when describing the cultural significance of this landmark, we are re-burying an inspiring narrative as quickly as we uncovered it. In Santa Monica, most physical evidence of the lives of people of color from the early days of the city has been erased. Entire neighborhoods were razed, disrupted, and redeveloped. We have an opportunity to leverage the natural nexus between racial justice education and historic preservation goals to make Santa Monica better. Not all stories that lurk in the shadows of our history should have a place in our narratives. Analytical Item 6.B
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discussion that seeks a balance of key factors would ensure our findings include the right contextual stories for the right reasons. But this one is pretty easy to decide, it’s all upside. We should not rely only on rare philanthropically funded interpretive displays to tell this part of our history and allow our city’s historic preservation program to remain silent. Since 631 Colorado Avenue meets certain landmark designation criteria in its own right, it is appropriate and fair to include as part of the context for the site, the story of Etta Moxley, an inspiring and important African American woman who lived here in Santa Monica for her entire productive life, though not a single physical artifact associated with her remains extant.
Integrity is to Ensure it Can Tell its Story
The condition of a building proposed for designation, called its integrity, is defined by the National Park Service as a building’s ability to convey its significance. Integrity is evaluated by examining seven characteristics of a property that may have changed over time. Standards for integrity for listing on the National Register are very high because that honorary designation makes properties eligible for significant federal grants and tax breaks. In Santa Monica where we allow a wide range of rehabilitation, remodeling, and additions to our historic resources, the key approach for evaluating integrity is on the view from the public right of way because we preserve buildings to benefit the public and allow historic landmarks to adapt and change to meet the evolving needs even after designation. In the case of the subject property, the most significant alteration is to the window systems, which have been replaced with compatible windows in the original openings. This is a typical change made to commercial buildings. While not ideal, it does not constitute a substantial change to the overall appearance of the landmarked structure from the street. Of the seven aspects of integrity, four of them are apply to the overall resource: location, feeling, association, and setting. These are all intact because the building has not moved from its corner location, still appears as an industrial-style commercial building, and retains its relationship to its surroundings. The other three aspects of integrity are specific to features of the resource: design, workmanship, and materials. These are affected by the changes to the window systems and less so by a rear addition. Defining characteristics of 631 Colorado are still highly apparent and remain valuable for conveying the aspects of Santa Monica history the building represents as described in the Landmarks Commission’s excellent findings for designation.
Landmarks are Frequently Part of New Development in Santa Monica In an “Appeal Supplement” included in your packet as (Attachment I), the appellant brings up a non-sequitur issue relative to a Landmark Designation application regarding the future disposition of the site for development. Through my 20 years of involvement in the city’s historic preservation program, one city attorney after another has consistently urged the Commission to remember that an evaluation for Landmark Designation should avoid any consideration of future change to a resource. It is beside the point. The appellant, though fully aware of this, notes that this parcel has been listed on the Suitable Sites Inventory that supports our yet-to-be-certified 6th Cycle Housing Element. The appellant takes advantage of common misconceptions that historic preservation and landmarks designation stop all future Item 6.B
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change to imply that this parcel would not be able to achieve its development potential for housing were its designation as a landmark upheld. As the appellant points out, abandonment of existing uses on SSI sites is indeed critical to their redevelopment, but the leap the appellant makes that redevelopment depends upon the demolition of all existing improvements is incorrect and misleading.
Historic Resources have been successfully incorporated into new development many times in Santa Monica, and our LUCE speaks at great length about the importance of considering adaptive reuse in new development. When the nomination was filed, a representative of the property owner was contacted to provide information on historic preservation and adaptive reuse. We had a lengthy discussion of how this historic resource, were it to be designated could indeed still fulfill its housing potential, how the new development could even be enhanced by the incorporation of the landmark, and how significant property tax incentives help pay for the addition costs associated with historic preservation. This has been demonstrated in the city many times over, beginning decades ago with the incorporation of the 1875 Rapp Saloon on Second Street (the city’s first-ever landmark) into the American Youth Hostel, and more recently with the WWII Quonset Hut that serves as a restaurant that is part of a substantial housing development at the corner of Lincoln and Broadway. Our landmark City Hall has been incorporated into a brand-new city services building, and the Santa Monica Professional Building has become part of the Proper Hotel. Additionally, there are a number of landmark cottages in multi-unit residential zones of the city that have been able to accommodate several additional units on site.
This landmark would be particularly accommodating to new development because of its siting along property lines at a visible corner, and because the Landmarks Commission did not include any of the altered accessory buildings on the site in the designation. As the appellant’s attorney well knows, FARs permitted in our downtown are designed to ensure sufficient building articulation, setbacks, open space, and fresh air circulation in new construction. To meet city code, most new residential developments include lower level open spaces open to the sky, and are not solid masses. A simple willingness could easily design housing on this site that incorporates this landmark structure without giving up any by right development potential.
Furthermore, the appellant’s attorney worked closely with the Santa Monica Conservancy to propose a host of special code provisions that city council included in the 2015 Zoning Ordinance Update to further accommodate preservation needs in the course of new construction. Landmarking would not be a constraint on housing capacity.
The Landmarks Commission accurately determined that 631 Colorado meets Santa Monica Landmarks Designation Criteria 1 & 4 based on the findings in the January 2022 STOA, which should be upheld.
Nina Fresco
Santa Monica Conservancy
June 14, 2022
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