Cities Index.
Agenda packet, first session

Santa Monica City Council
November 18, 2025

Document
Agenda packet, first session
Meeting
November 18, 2025
Body
Santa Monica City Council
Pages
3
Original file
219.9 MB
Text extracted from the city's file for reading and search. Open the original on santamonicacityca.iqm2.com. That file is the official record.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thank you your attention to this important matter.

David Yuguchi
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1640 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 1 David Yakobson
From: carrie davies <[email protected]>
Sent: Tuesday, November 18, 2025 11:25 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
Please note that the body of this email was copied in the interest of time, but we fully support its content. We are especially concerned about the traffic impacts of this development on our neighborhood.

The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thanks,
Carrie & Chris Davies
2507 Pearl ST.

Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1641 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 2 David Yakobson
From: Marc Verville <[email protected]>
Sent: Tuesday, November 18, 2025 11:26 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis
Cc: councilmtgitems; Oliver Chi; Heidi von Tongeln
Subject: Subject: SMCC 2025-11-18 Meeting Item 5.D. Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood). This change is also being done in the complete absence of an Emergency Evacuation Capacity Plan (Agenda Item 4.S. - Local Hazard Mitigation Plan – please see my separate comment on that issue), which borders on the negligent.

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thanks,
Marc L. Verville
Sunset Park
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1642 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 3 David Yakobson
From: Mindi Shank <[email protected]>
Sent: Tuesday, November 18, 2025 11:29 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street back to its proper and intentional R1 zoning. Protect our neighborhoods! Thanks,
Mindi Shank
29th Street Resident
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1643 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 4 David Yakobson
From: Tracey Hom <[email protected]>
Sent: Tuesday, November 18, 2025 11:45 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems; Heidi von Tongeln; Oliver Chi Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

This upzoning is illegal and will be fought on several fronts Tracey Hom and Lenny Hom
2638 29th st.

Santa Monica, CA 90405
310 749 5343
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1644 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 5 David Yakobson
From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, November 18, 2025 11:45 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "it can be seen with certainty there is no possibility that the amendments may have a significant effect on the environment." This is clearly false and the City failed to comply with the law. Furthermore, there is a disturbing trend of staff using the "Common Sense Exemption" when it does not apply in order to avoid the environmental review required by law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood. The 10- year reprieve from certain development in the Covenant is proof there are impacts and evidence that the land use and zoning change is not eligible for the Common Sense Exemption.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

Here is a list of uses that are now permitted, which staff failed to provide to council, despite multiple requests by the community. There is no way any of you can say with a straight face that these have "no possibility of a significant effect on the environment.  Grooming and Pet Stores
 Pet Day Care Services
 Veterinary Services
 Alternative Fuels and Recharging Facilities
 Banks and Credit Unions
 Business Services
 Theater
 Small-Scale Gaming Arcade
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1645 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 6  Restaurants, Full-Service, Limited Service & Take-Out (2,500 square feet and smaller, including Outdoor Dining and Seating)
 Restaurants, Full-Service, Limited Service & Take-Out (2,501 — 5,000 square feet, including Outdoor Dining and Seating)
 Restaurants, Full-Service, Limited Service & Take-Out (greater than 5,000square feet, including Outdoor Dining and Seating)
 Food Hall (up to 175 seats)
 Convenience Market
 Farmers Markets
 General Market
 Liquor Stores
 Instructional Services
 Live-Work
 Bed and Breakfast
 Maintenance and Repair Services
 Nurseries and Garden Centers
 Outdoor Newsstands
 General Personal Services
 Personal Services, Physical Training
 Tattoo or Body Modification Parlor
 General Retail Sales, Small-Scale
 Bus/Rail Passenger Stations
 City Bikeshare Facility
 Utilities, Minor
It is simply not possible for the City to show that the rezoning of this property "can be seen with certainty to have no possible significant effects on the environment," which means the CEQA process must be followed. It's also unacceptable that staff continues to provide false information in staff reports and verbally at meetings to City Council. How can the community be served by you if you are getting false information from staff? Please do not condone this unethical behavior from staff.

We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial and restore the Residential/R1 designations.

Regards,
Nikki Kolhoff
Santa Monica Resident
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1646 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 7 David Yakobson
From: Heather Thomason <[email protected]>
Sent: Tuesday, November 18, 2025 11:50 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
I am concerned that the city is far too regularly making exceptions under CEQA and declarations that projects/ordinances/laws could have no possibility that they may have a significant effect on the environment. This sort of declaration seems false, and leaves the city very vulnerable to litigation. I strongly urge this Council, and City staff to take a step back and consider a new approach to these sorts of declarations.

Of particular concern at this very moment is that the City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." In determining this, it seems to me that the City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thank you very much for your consideration,
Heather Thomason
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1647 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 8 David Yakobson
From: Lauren Behrendt <[email protected]>
Sent: Tuesday, November 18, 2025 11:53 AM
To: [email protected]; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thanks,
Lauren Behrendt
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1648 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 9 David Yakobson
From: Leanna Einbinder <[email protected]>
Sent: Tuesday, November 18, 2025 11:58 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems; Oliver Chi; Heidi von Tongeln Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "it can be seen with certainty there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood after 10 years (with the proposed covenant).

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property "can be seen with certainty to have no possible significant effects on the environment," which means the CEQA process must be followed. It's also unacceptable that staff continues to provide false information in staff reports and verbally at meetings to City Council. How can the community be served by you if you are getting false information from staff? Please do not condone this unethical behavior from staff.

We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial and restore the Residential/R1 designations.

Regards,
Leanna Einbinder
Santa Monica Resident
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1649 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 10 David Yakobson
From: Eve Lopez <[email protected]>
Sent: Tuesday, November 18, 2025 12:00 PM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems; Heidi von Tongeln; Oliver Chi Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thank you.

Eve Lopez
Santa Monica resident
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1650 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 1 David Yakobson
From: rob arocd.com <[email protected]>
Sent: Tuesday, November 18, 2025 11:16 AM
To: Lana Negrete; Ellis Raskin; Dan Hall; Jesse Zwick; Natalya Zernitskaya; Barry Snell; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thanks,
Rob Levin
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1651 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 1 David Yakobson
From: Teri D Bernstein <[email protected]>
Sent: Tuesday, November 18, 2025 11:08 AM
To: councilmtgitems; Lana Negrete; Caroline Torosis; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Oliver Chi; Heidi von Tongeln; Jesse Zwick Cc: Nikki Kolhoff; Tracey Hom; Mindi Shank; Leanna Einbinder; Dick Bernstein Subject: 11-18-2015 Closed Session Item 5.D. (Teri Davis Bernstein v. City, et al)

EXTERNAL
Greetings Councilmembers and other City leaders:

Due to timing considerations, I filed, under my name, the lawsuit on your Closed session agenda...with the help of a group of concerned neighbors--now operating under the acronym SPEAR. We will be amending and following up with legal representation.

The lawsuit was filed not only because the Rezoning of 2644 30th needs to be reversed, but also because there needs to be a Public Record of the opposition to this action, as the Minutes to your Council Meetings do NOT accurately reflect the level of voter opposition. About a hundred people wrote or spoke against this action. City staff made serious misrepresentations that were not acknowledged in the minutes. The Public Record needs to expose the egregiousness of these actions.

I remain baffled about one crucial part of this transaction. If a property owner wants a "favor" from the City to make it easier to re-lease units in their building, why wouldn't the City counter his request with a request for a concession that would also improve the situation for the surrounding residents in return? Why wouldn't they provide the simplest remedy that would cause the least harm? I think that is what the Council initially promised when the item was tabled. But Rezoning to Neighborhood Commercial? This is a HUGE overreaction--it is a big "GET" for the owner.

AND...In any business transaction (debits=credits), if one person gets something, the other party gets something, too. Who is the other party here? It's not the residents. (The covenant is a temporary band aid mitigating the harm of the Rezoning, not a net positive.) My guess is SOMEBODY got SOMETHING.

Who was the beneficiary of the consideration accorded by the valuable asset of Rezoning the City granted to 2644 SM Partners and Scott Sternberg? Please let us in on what seems like the "Project 2025" of Santa Monica. I wonder where the money is coming from and really worry about that...

I'm afraid that developers and other interests are shouting into the ears of City Council members so loudly that you have forgotten the reasons of service that we hope led you all to seek public office in the first place.

The elephant in the room is that you on the Council have a VERY difficult job. And you are not being paid enough for the work you have to do. THAT IS A RECIPE FOR DISASTER. People try to "equalize" things, and Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1652 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 2 I'm afraid that you might rationalize doing the bidding of others in exchange for a new job, or donations to your favorite charity, or the promise of support when you seek your next political office.

You might have been told that this is "the way things are done" but AOC talks about being mentored in the "way things are done on Capitol Hill" as climbing onto the laps of lobbyists...and she has resisted that. You can, too.

I urge you to turn away from rationalization and the slippery slope of supporting monied interests over principled interests.

You can back away from this rezoning, knowing that because of your enormous workload AND your reliance on the misrepresentations of City Staff, you:
 accepted their misrepresentations of this being an error in LUCE (how can LUCE be an error? It is a huge city process with all parties involved. It is the law.)  unknowingly let a property owner make a rezoning request without paying the proper fees and filing the proper forms
 gave in to pressure to go along with some bigger plan of people with money and a long agenda, rather than following your conscience, which was evident when you initially tabled this item.

It is NOT YOUR FAULT that you were led down this path to rezoning a section of a 2 block long R1 street into Neighborhood Commercial. How does that make sense? YOU DO HAVE THE POWER TO STEP BACK FROM THIS REZONING POSITION.

Please reverse your action.

Thank you. What follows my signature is a succinct description of the rezoning parameters, prepared by a member of our neighborhood group.

Teri Davis Bernstein, MBA, CPA (inactive), member of SPEAR 2528 29th St
Santa Monica, CA 90405
Description of problem:

The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law. The City's rezoning may have significant environmental impacts on this residential neighborhood.

The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood, and after 10 years, the building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood. Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday) to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood). It is simply not possible for the City to show that the rezoning of this property has no Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1653 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 3 possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1654 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 4 David Yakobson
From: Wendy Dembo <[email protected]>
Sent: Tuesday, November 18, 2025 11:06 AM
To: Lana Negrete; Ellis Raskin; Natalya Zernitskaya; Barry Snell; Jesse Zwick; Dan Hall; Caroline Torosis; councilmtgitems
Cc: Oliver Chi; Heidi von Tongeln
Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

EXTERNAL
Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management, The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and decided that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law!
The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped into an 85-foot-tall housing structure across from one and twostory homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment.

We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

With great concern,
Wendy Dembo
Santa Monica Resident
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1655 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 1 David Yakobson
From: John Reynolds <[email protected]>
Sent: Tuesday, November 18, 2025 11:13 AM
To: councilmtgitems
Subject: Oppose up-zoning 30th street 11/18/25 by 5-D

EXTERNAL
Honorable mayor, city manager and council members,
[email protected], [email protected], [email protected], [email protected], [email protected], [email protected],
[email protected], [email protected] Cc: [email protected], [email protected] Subject: 11/18/25 agenda item 5-D – Litigation re "Common Sense" CEQA Exemption at 2644 30th St.

Dear Mayor Negrete, City Councilmembers, City Manager Chi, and Office of Emergency Management,
The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA under the “Common Sense Exemption” because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law.

The City's proposed rezoning may have significant environmental impacts on this residential neighborhood. The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood. The building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood, with only a 10-year reprieve.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday), to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Thanks,
John Reynolds
3217 17th street
213-598-2120
from Yahoo Mail for iPhone
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1656 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) 1 David Yakobson
From: Karen Pickard-four <[email protected]>
Sent: Tuesday, November 18, 2025 10:43 AM
To: Council Mailbox; councilmtgitems
Cc: Jesse Zwick; Lana Negrete; Caroline Torosis; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Oliver Chi
Subject: Consent Calendar Item

EXTERNAL
Dear Councilpersons and Mayor:

As a Sunset Park Resident, I support the Writ below and will be following the progress of this lawsuit closely. Please consider the voting residents of the community you represent as you discuss this tonight.

The rezoning of the property at 2644 30th needs to be REVERSED.

Closed Session Item 5.D. (Teri Davis Bernstein v. City, et al):

The City changed the zoning of a portion of 2644 30th Street from R1 to Neighborhood Commercial and determined that this zoning change was exempt from CEQA because "there is no possibility that the amendments may have a significant effect on the environment." The City failed to comply with the law. The City's rezoning may have significant environmental impacts on this residential neighborhood.

The existing office building at 2644 30th Street may be redeveloped immediately for uses that are substantially different from what exists today (including materially different commercial activity) that would encroach upon the neighborhood, and after 10 years, the building can be redeveloped to an 85 feet tall housing structure across from one and two-story homes in a residential neighborhood.

Even without any redevelopment at all, the rezoning permits the building, which has consisted of office space for decades (i.e., people working from 9am-5pm, Monday through Friday) to now immediately be converted to use as a restaurant or another commercial establishment, which would have significant environmental impacts (e.g., constant in-and-out traffic, double parking food delivery vehicles, noise, air quality and other environmental factors that do not currently exist in this neighborhood).

It is simply not possible for the City to show that the rezoning of this property has no possible significant effects on the environment. We ask that the City follow the law and conduct the proper environmental review process required of it, and consequently reverse the rezoning of 2644 30th Street to Neighborhood Commercial.

Karen Pickard Four (resident since 94)
Sent from my iPhone
Item 5-D
November 18, 2025
Item 5-D
November 18, 2025

5.D.a
Packet Pg. 1657 Attachment: Written Comments [Revision 2] (7418 : 5.D. Closed Session: Terri Davis) City Council
Report
City Council Meeting: November 18, 2025
Agenda Item: 12.A
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To: Mayor and City Council
From: Jing Yeo, Director, Administration
Subject: Appeal of Decision by Landmarks Commission to Designate the Front Residence on the Property Located at 1125 18th Street as Structure of Merit Recommended Action
Staff recommends that the City Council:

1. Adopt a finding of no possibility of significant effect pursuant to Section 15061(b)(3) (Common Sense Exemption) of the California Environmental Quality Act (CEQA) Guidelines;

2. Approve 25ENT-0135, appeal of the Landmarks Commission’s decision to designate the front building, a 952 square foot rectangular one-story, single-unit wood-frame residence, on the property located at 1125 18th Street as a Structure of Merit; and

3. Deny Designation Application 25ENT-0069 to designate the front building, a 952 square foot rectangular one-story, single-unit wood-frame residence, on the property located at 1125 18th Street as a Structure of Merit.

Summary
On February 20, 2025, Shahab Ghods of Plus Architecture Inc. submitted a demolition permit application for the property at 1125 18th Street. On April 30, 2025, the Santa Monica Conservancy submitted historic resource designation application 25ENT-0069 to nominate the front building, a 952 square foot rectangular one-story, single-unit wood-frame Craftsman bungalow residence, on the property located at 1125 18th Street as a Structure of Merit. The designation application included information to support designating the residence as a Structure of Merit based on the criteria set forth in Santa Monica Municipal Code (SMMC) Section 9.56.080(A) and (B)(1-2) stating that “the structure has been identified on the City’s Historic Resources Inventory,” (Criterion A), “the structure is a unique or rare example of an architectural design, detail, or historical

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type,” (Criterion B1), and that “the structure is representative of a style in the City that is no longer prevalent” (Criterion B2).

The City retained Page and Turnbull (P&T) to prepare a Historic Resource Assessment (HRA) to determine if the front residence is eligible for designation as a Structure of Merit, and as a result of their research and analysis, P&T concluded that the building does not meet any of the Structure of Merit Criteria. Preservation staff visited the property, analyzed the report, and reviewed other similar properties and agreed that the building does not appear to meet any of the Structure of Merit criteria.

The Landmarks Commission held a public hearing on July 14, 2025 to consider the front residence’s eligibility as a Structure of Merit. After considering all written and oral evidence presented at the hearing, at the conclusion of their discussion, the Commission designated the front residence as a Structure of Merit in a 4-2 vote with one absence under Criteria A, B1 and B2. The evidence considered, which included the Santa Monica Conservancy application, public presentations, and other materials are attached and provided here: July 14 2025 Landmarks Commission Agenda.

On July 24, 2025, Landmarks Commissioner Pam O’Connor filed a timely appeal (Appeal 25ENT-0135) of the Landmarks Commission’s decision to designate the building as a Structure of Merit. Based on the evidence outlined in the P&T assessment, evidence received prior to and during the Commission’s public hearings on July 14, 2025, and review of the appeal statement, staff does not believe this information materially changes the original findings presented to the Landmarks Commission and continues to recommend denial of the designation. The Landmarks Commission findings included in the Statement of Official Action (STOA) and the appeal statement are presented for the Council’s consideration as part of this de novo hearing. Staff recommends the Council uphold the appeal and determine the front residence ineligible as a Structure of Merit.

Discussion
City of Santa Monica Landmark and Historic District Ordinance SMMC Chapter 9.56

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Adopted in 1976, the stated purpose of the City’s Landmark and Historic District Ordinance is:

A. To promote the public health, safety and general welfare by establishing such procedures and providing such regulations as are deemed necessary to: 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 may designate an improvement as a Landmark or Structure of Merit to protect and enhance improvements that are found to meet certain criteria supporting either designation.

Currently, there are 143 designated City Landmarks, 16 designated Structures of Merit, and 5 Historic Districts within the City.

A Structure of Merit is an “improvement that has been designated as and determined to be appropriate for official recognition by the Landmarks Commission.” A Structure of Merit contributes to Santa Monica’s cultural identity but is not sufficiently distinguished to merit designation as a City Landmark. A key difference between Landmark and Structure of Merit designations is the level of historic significance based on their respective designation criterion. A Landmark criterion is 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

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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. In contrast, a designated Landmark may not be demolished without approval of a Certificate of Appropriateness by the Landmarks Commission, or the City Council on appeal, under very limited circumstances. Further, a Structure of Merit designation can also be used to initiate a potential Historic District application. However, the intent of using a potential district as the basis of a Structure of Merit designation 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 the protections a Landmark property designation provides.

SMMC Section 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, if appealed, the City Council reviews the Commission’s designation of a Landmark or Structure of Merit, as well as any related decisions de novo, as a new hearing separate from the deliberations of the Commission. 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.

Historic Resources Inventory Status
1125 18th Street was evaluated as part of the 2018 Historic Resources Inventory (HRI) survey and found to be potentially eligible for listing as a Santa Monica Structure of

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Merit. The property was not included in a previous HRI. The reasoning for this determination provided in the 2018 HRI is as follows:
1125 18th Street appears eligible for local listing as a Santa Monica Structure of Merit. The property conveys patterns of residential development that shaped the Wilshire Montana/Mid City neighborhoods of Santa Monica in the early decades of the twentieth century. Constructed in 1923, it is an example of a residential building from this formative period of neighborhood growth. The building does not rise to the level of significance needed to be eligible as a Landmark, but it appears eligible as a Structure of Merit.
‘
Parcel map showing the subject property, shaded in red aerial view.

Surrounding Neighborhood
The subject property is located in a residential neighborhood one block from Wilshire Boulevard, a major east-west commercial thoroughfare that runs the length of the city.

The parcels surrounding the subject property are characterized by a mix of multi-unit properties and single-unit residences ranging from the early 20th century to the present.

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Property Information and Architectural Description
The subject property is located on a 160-by-50-foot rectangular lot on the east side of 18th Street. The front building that is subject to this appeal is a 952 square foot rectangular one-story, single-unit wood-frame residence with a low-pitched front gable roof with an intersecting side gable projection. The roof is clad with asphalt shingles and features wide overhanging eaves with exposed rafter tails and triangular cross-hatched wood vents at the gable ends. The front building is clad in painted narrow wood clapboard. Typical windows are wood double-hung windows with flat wood surrounds located on all façades. The upper sash of the windows on the primary (west) façade features simplified prairie-style muntins.

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The front residence is considerably set back from the street behind a front yard with a lawn, a mature tree, and landscape plantings along the primary street façade. A concrete paved ribbon driveway with grass down the center runs along the south side of the parcel and terminates at the rear wood fence. There is another residence at the rear of the property adjacent to the alley, separated from the front building and yard by a wood fence. This building is not included in the designation application, and, as the underlying parcel is not eligible for designation as part of the Structure of Merit designation, neither the rear building nor any of the other improvements on the property, including hardscape and landscape, is included as part of this appeal. 1125 18th Street, Street View
Architectural Style: Craftsman Bungalow
Craftsman bungalows are typically characterized by low-pitched gabled roofs with wide, unenclosed eave overhangs; decorative beams or braces; exposed rafter tails; tapered square columns or pedestals; and extending porch elements. Small-scale, wood-framed Craftsman bungalows could be constructed easily and affordably and were often available as kit houses, or built from plans in pattern books, through the 1910s.

Neighborhoods of Craftsman houses developed into the 1920s as streetcar suburbs.

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Elaborate and unique homes of the wealthy, such as the Gamble House in Pasadena, represent high style examples while rows of more modest bungalows are found throughout California.

Based on a review of the 2018 Historic Context Statement survey results, 178 properties in Santa Monica were identified by the survey as “Craftsman” style. Of these, 30 individually significant properties were identified in the Wilshire Montana neighborhood, 18 as potential Landmarks and 12 as potential Structures of Merit. Like 1125 18th Street, all 30 properties were identified as being significant, at least in part, for conveying the “patterns of residential development” in the Wilshire Montana area in the “early decades of the twentieth century”. Twenty of the Craftsman style properties identified as significant in the Wilshire Montana neighborhood represent relatively modest bungalow-style homes, which display a variety of different Craftsman design elements and types, as well as levels of integrity. Below are few examples:

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Historic Integrity
To qualify for listing in any local, state, or national historic register, a property or landscape must possess significance under at least one evaluative criterion and retain integrity. Integrity is defined by the California Office of Historic Preservation as “the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance,” or more simply defined by the National Park Service as “the ability of a property to convey its significance”.

With the exception of an ADA ramp on the south side, the subject property appears to have had very few exterior modifications since it was originally constructed.

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Location
The 1125 18th Street primary (front) residence retains integrity of location. The subject building has remained situated at its location of original construction since 1923. Since the construction of the main residence, a secondary structure and fence have been installed at the rear of the property. This does not appear to impact the integrity of location.

Setting
The front residence at 1125 18th Street retains integrity of setting. The residence continues to be located where it was originally instructed. The parcel on which the house is located has changed with the addition of a secondary residence at the rear of the property. However, it retains its general landscape setting, driveway, and view from the street.

If eligible, the appropriate period of significance for the building would be 1923, the year of its construction. It is in reference to the design and appearance of the building and its setting in this year that the integrity discussion is based.

Design, Materials, Workmanship, Feeling, and Association As the front residence at 1125 18th Street has not been significantly altered and remains in its original location since its construction in 1923, it maintains integrity of Design, Materials, Workmanship, Feeling, and Association.

Historic Resource Designation Application
The Santa Monica Conservancy submitted information to support designation of the property at 1125 18th Street and offered the following findings:

A. The structure has been identified in the City’s Historic Resources Inventory.

B. The structure is a minimum of 50 years of age and meets one of the following criteria:

1. The structure is a unique or rare example of an architectural design, detail or historical type. The subject property is a Craftsman bungalow that was constructed late in the time period for that style’s prevalence – 1923 – and

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has design features that are unique within the typical framework of that style:
the offset entryway placed at a side elevation rather than at the front; the small entry porch reduced to frame the front door; the intersecting cross roof gables; the bank of windows on the front façade with crossed muntins which are asymmetrical, lacking the lower muntin.

2. The structure is representative of a style in the City that is no longer prevalent. Single-family one-story Craftsman homes represent a style that is no longer prevalent.

Analysis
Staff has analyzed the application materials submitted by the Santa Monica Conservancy, the P&T consultant assessment commissioned by the City, and the information provided at the Landmarks Commission meeting including input from the public and the Commission’s discussion. As per the City’s regular practice, P&T was hired to do a historic resource assessment, and produces research, analysis and an independent professional assessment of the nominated building. Staff reviews that information and provides additional analysis that also includes the City’s consistent practice. P&T evaluated the property under the Structure of Merit Criteria in SMMC

9.56.080 and in addition assessed the building’s physical integrity. As a result of this analysis, P&T concluded that the property does not meet any of Criteria, as it is a modest example of a Craftsman bungalow, a type that is relatively common in the Wilshire Montana neighborhood and Santa Monica.

While the subject property has been identified in the most recent iteration of the HRI, the front residence appears ineligible under the Criterion A “the structure has been identified on the City’s Historic Resources Inventory.” The HRI is a “windshield survey” with determinations being made on limited information. Upon further research and evaluation, the subject residence is a modest Craftsman bungalow that represents a restrained interpretation or partial application of the Craftsman style rather than a particularly distinguished or unique example. Furthermore, the modest Craftsman bungalow remains a relatively common building type that remains prevalent within the neighborhood. As such, the subject residence does not appear to warrant its current

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listing on the HRI and appears ineligible under Structure of Merit Criterion A, “The structure has been identified on the City’s Historic Resources Inventory.” Further, given its relatively simple design and the continued presence of similar properties in the area, P&T found that 1125 18th Street does not represent a rare or unique example of its type and the structure does not appear to meet any of the criteria for designation as a City of Santa Monica Structure of Merit. The structure is not representative of a style in the City that is no longer prevalent. Rather there are many similar vernacular or modest Craftsman bungalow buildings in the neighborhood and throughout the city, and the building type and style remains quite prevalent. The structure does not contribute to a potential historic district. Therefore, the 1125 18th St does not appear to be eligible for this level of designation under any of the Criteria set forth in 9.56.080(B). Upon analysis of all the material, staff agrees with the P&T analysis and respectfully disagrees with the conclusions of the Commission that the front residence is eligible for designation as a Structure of Merit.

Landmarks Commission Action
On July 14, 2025, the Landmarks Commission held a public hearing on the front residence’s potential eligibility as a Structure of Merit. The Commission was provided with the designation application materials, the P&T assessment report commissioned by the City, staff’s analysis in the staff report, and public comment. The P&T assessment concluded that the property does not satisfy the criterion findings as a Structure of Merit.

The P&T report and the owner’s demolition permit application and appeal application materials are attached.

In consideration of all written and oral testimony, staff’s analysis, P&T’s historic preservation consultant report, and materials introduced into the public record, the Commission voted 4-2 (one commission was absent) to designate the front residence at 1125 18th Street as a Structure of Merit. The Commission made the designation primarily based on the application materials and applicant testimony. The Commission’s findings included:

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Criterion A. The structure has been identified in the City’s Historic Resources Inventory as eligible for Structure of Merit designation.

Criterion (B)(1). The structure is a minimum of 50 years of age and the structure is a unique or rare example of an architectural design, detail or historical type.

The subject building was constructed in 1923 and therefore is more than 50 years of age. 1125 18th Street is a relatively intact example of a modest Craftsman bungalow built during Santa Monica’s real estate boom of the 1920s.

The Craftsman bungalow was a common single-family residential style in the Wilshire Montana neighborhood at the time the neighborhood was being developed in response to improved transit access. These small-scale, woodframed homes were popular due to their ease and affordability of construction.

The building possesses some key characteristics of this housing type, including its one-story height, low-pitched gable roof with overhanging eaves, visible rafter tails, angular brackets supporting the entry door gable, wood siding, and multi-lite wood frame windows.

The extant Craftsman bungalows and other single-family residences built in the first three decades of the 20th century in the Wilshire Montana neighborhood are no longer prevalent thus represent a picture into the past of a homogenous single-family neighborhood located within the Wilshire Montana area, and the Green Acres Tract specifically. During and after Santa Monica’s period of growth in the 1920’s, low-scale apartment complexes and bungalow courts in various Revival styles were constructed alongside single family homes. This pattern created the neighborhood’s varied residential character, an architectural mix which reflects decades-long development patterns in the Green Acres Tract and Wilshire Montana neighborhood.

The Craftsman bungalow remains a relatively uncommon building type within the neighborhood, specifically the Green Acres Tract of the Wilshire Montana neighborhood. 1125 18th Street, a small modest, vernacular Craftsman style

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bungalow appears to represent a rare or unique example of its type within this area of Santa Monica.

This vernacular Craftsman bungalow represents a unique and rare variation of the typical Craftsman bungalow architecture. As a late variant constructed in 1923, features such as a bank of windows on the façade, a reduced porch and entry door on a side elevation and asymmetrical window muntins break away from the classic design of Craftsman bungalows.

Criterion (B)(2). The structure is representative of a style in the City that is no longer prevalent. 1125 18th Street is an example of a modest vernacular Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first two decades of the 20th century. 1125 18th Street is single-family one-story Craftsman home representing a style that is no longer prevalent in the Wilshire Montana neighborhood, specifically the Green Acres Tract.

The Landmarks Commission designated the structure as a Structure of Merit after receiving an application that was filed in response to the property owner filing a demolition permit application. During its deliberations, the Commissioners had substantial disagreement on whether or not the property met the Structure of Merit designation criteria, resulting in a 4 to 2 vote in favor of designation. The Commission focused their discussion on the particular qualities and craftsmanship of the structure, and its rarity.

The July 14, 2025 Landmarks Commission staff report, approved meeting minutes, and the approved STOA are attached. The audio recording of the July 14, 2025 meeting is posted on the Landmarks Commission webpage.

Appeal
The appellant filed a timely appeal on July 24, 2025. The appeal amplifies the staff report and the pertinent information was previously discussed in this report. The appeal

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also refutes the Landmarks Commission findings. Additionally, the appeal statement argues more broadly that the Structure of Merit designation is flawed and should be removed from the Landmarks Ordinance. As noted below, whether the Structure of Merit designation should be removed from the Landmarks Ordinance is a policy question for the City Council that is outside the scope of this appeal and not before the City Council as part of this public hearing.

Appeal Analysis

1. Appellant states that the staff report and the City’s historic preservation consultant finds that the property does not meet the City’s criteria for designation as a Structure of Merit. The Appellant also cited that statements made in the designation application are not supported by any evidence and that Commission’s findings focused on its uniqueness within the Green Acres Tract, a small tract within the Wilshire Montana neighborhood and that there was no evidence provided to demonstrate why this small tract was significant.

The appeal statement is correct that City Staff and the City’s consultant agreed that the findings for designation as a Structure of Merit could not be met. The staff report and P&T’s report noted that the building is an unremarkable vernacular/modest bungalow structure, many of which are still extant in the city, and is not a rare example of its type in Santa Monica. As there are other similar buildings in the city and throughout the region, the property type or style is not particularly rare but rather commonplace.

Further, there is nothing that distinguishes this property as historic, but rather it is simply old.

Further, the findings made by the Commission are based on the rarity of the building in the Green Acres Tract, a very small area within the Wilshire Montana neighborhood. It is not consistent with professional practice or the City’s past practice to identify the rarity of a property based on the small area of a single development tract.

Staff is in agreement with the appellant that the front residence does not meet Santa Monica Structure of Merit criteria.

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2. The Structure of Merit Designation is flawed.

The appeal statement goes on to argue that the Structure of Merit designation is unique to Santa Monica and is not aligned with State of California preservation programs and might be found by the State to be hindering housing development. These arguments in the appeal are outside the scope of the question presented to the Council, i.e., whether the structure meets the criteria for Structure of Merit. Thus, staff recommends that the City Council not discuss or base its decision on these arguments. However, Council could consider, from a policy perspective, at a later Council meeting, whether it would like to reform the Structure of Merit designation.

By way of providing additional background on the Structure of Merit as it may relate to analysis of the appeal, staff provides the following information: the appeal statement is correct that the Structure of Merit designation is relatively unique to Santa Monica.

There are a few other cities in California with tiered designation systems. The criteria and requirements for Structure of Merit in Santa Monica are specific and differ from those of other cities. Structure of Merit Criteria allows for a different and lower threshold than the Landmarks Designation Criteria. The Code defines a Structure of Merit criteria and therefore the Landmarks Commission may designate a property as a Structure of Merit if it meets required findings under those criteria.

A designated Structure of Merit is eligible for demolition after a certain waiting period.

This is different than demolition of a designated Landmark, which requires approval of the Landmarks Commission, or the City Council on appeal under very limited circumstances. Any modifications to a Structure of Merit do not require a Certificate of Appropriateness but its status as a Structure of Merit is considered by the Architectural Review Board or staff who review the proposed modifications for compliance with the Secretary of Interior’s Standards. Modifications to a City Landmark require a Certificate of Appropriateness and must be reviewed by staff or the Landmarks Commission.

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Recommendation
Eligibility as a Structure of Merit Designation and Proposed Findings The Zoning Ordinance that governs the demolition permit review process requires the City Council, on appeal, to review the building’s eligibility as a Landmark or Structure of Merit. In order to be designated as a Structure of Merit, the Council is required to find that the front residence meets one or more of the Structure of Merit Criteria.

Staff has analyzed the application materials, the P&T consultant assessment commissioned by the City and has considered all the testimony and Landmarks Commission discussion and designation findings. Based on a thorough analysis of all this information, the City’s past practice, and the Secretary of Interior’s Standards, staff respectfully disagrees with the Landmarks Commission conclusion and recommends the City Council approve the appeal and deny the Structure of Merit designation. The front residence does not appear to be a particularly unique or rare example of the vernacular bungalow property type or style and many modest and vernacular Craftsman bungalows remain within the neighborhood, the City of Santa Monica, and the region.

Evaluation for Designation as a Structure of Merit
Pursuant to SMMC Section 9.56.080, a property merits consideration as a Structure of Merit if it satisfies one or more of the following criteria. The front residence located at 1125 18th Street does not appear eligible under any of the following criteria. Below each criterion is discussed in detail:

SMMC Section 9.56.080(A). The structure has been identified in the City’s Historic Resources Inventory.

As the subject residence is identified in the City of Santa Monica’s 2018 HRI update as a potentially eligible resource for local listing, it technically meets the wording of this criterion. However, P&T and City Preservation staff’s opinion is that identification as a potential resource in Santa Monica’s HRI does not alone provide sufficient basis for the

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individual designation of a property as a Structure of Merit. This criterion recognizes the findings of previous evaluations conducted in support of the inventory and update. It appears to presume that if a property is “identified” in the inventory, it has already been evaluated according to and found significant under at least one of the categories of SMMC Section 9.56.080(b) (see below). While the subject property has been identified in the most recent iteration of the HRI, the residence appears ineligible under this criterion. The HRI is a “windshield survey” with determinations being made on limited information. Upon further research and evaluation, the subject residence is a modest Craftsman bungalow that represents a restrained interpretation or partial application of the Craftsman style rather than a particularly distinguished or unique example.

Furthermore, the modest Craftsman bungalow remains a relatively common building type that remains prevalent within the neighborhood. As such, the subject residence does not appear to warrant its current listing on the City’s HRI and appears ineligible under this criterion.

SMMC Section 9.56.080(B). The structure is a minimum of 50 years of age and meets one of the following criteria:

The subject residence was built in 1923 and, therefore, satisfies the 50-year threshold.

SMMC Section 9.56.080(B)(1). The structure is a unique or rare example of an architectural design, detail or historical type.

The front residence located at 1125 18th Street is a relatively intact example of a modest Craftsman bungalow built during Santa Monica’s real estate boom of the 1920s.

The Craftsman bungalow was a common single-unit residential style in the Wilshire Montana neighborhood at the time, as the neighborhood was being developed in response to improved transit access. These small-scale, wood-framed homes were popular due to their ease and affordability of construction. The building possesses some key characteristics of this housing type, including its one-story height, low-pitched gable roof with overhanging eaves, wood siding, and multi-lite wood frame windows. However, it lacks more distinctive architectural elements typical of Craftsman homes, such as

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prominent front porches with tapered stone, brick, or stucco columns or decorative beams. Rather than being a unique interpretation of Craftsman style, the idiosyncratic entrance at 1125 18th Street, which consists of a relatively small front porch facing the driveway rather than the public right-of-way, is a departure from the wide front entry porches which define the character of Craftsman bungalows. As such, the front residence at 1125 18th Street represents a restrained interpretation, or partial application of the Craftsman style rather than a particularly distinguished or unique example.

The extant Craftsman bungalows and other single-unit residences built in the first three decades of the 20th century in the Wilshire Montana neighborhood are not remnants of originally homogenous single-unit neighborhoods. Rather, residences like 1125 18th Street represent a middle stage of neighborhood development. Though established in the late 19th and early 20th century, development in these areas progressed slowly and in a patchy fashion until construction of single-unit residences accelerated during the 1920s. During and after this period of growth, low-scale apartment complexes and bungalow courts in various Revival styles were constructed alongside single unit dwellings. This pattern created the neighborhood’s varied residential character, an architectural mix which reflects decades-long development patterns in the Green Acres Tract and Wilshire Montana neighborhood.

According to the 2018 HRI update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to the front residence at 1125 18th Street. Although some have been removed for site redevelopment and others altered to the degree that they have lost integrity, the modest Craftsman bungalow remains a relatively common building type within the neighborhood. Given its modest design and the continued presence of similar properties in the area, the front residence at 1125 18th Street does not appear to represent a rare or unique example of its type. Therefore, the subject residence does not appear to be eligible for listing as a Structure of Merit under this criterion.

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SMMC Section 9.56.080(B)(2). The structure is representative of a style in the City that is no longer prevalent.

The front residence at 1125 18th Street is an example of a modest Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first three decades of the 20th century. The front residence at 1125 18th Street is one of many remaining Craftsman residences in the Wilshire Montana neighborhood and the City of Santa Monica as a whole. According to the 2018 HRI update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to 1125 18th Street. Although some have been removed for site redevelopment and others altered to the degree that they have lost integrity, the modest Craftsman bungalow remains a relatively common building type that remains prevalent within the neighborhood.

Therefore, the subject residence does not appear to be eligible for listing as a Structure of Merit under this criterion.

SMMC 9.56.080(B)(3). The structure contributes to a potential Historic District.

The subject residence has not been identified as a contributor to a potential Historic District. Therefore, it does not appear to be eligible for listing as a Structure of Merit under this criterion.

Conclusion & Statement Of Significance
The front residence at 1125 18th Street is a modest example of a Craftsman bungalow, a type which remains relatively common within the neighborhood and throughout the city and the region. The front residence at 1125 18th Street does not represent a rare or unique example of its type and is not an example of a no-longer prevalent style. Based on research and analysis, P&T has found, and staff agrees, that the front residence at 1125 18th Street does not meet any of the criteria for designation as a City of Santa Monica Structure of Merit.

Alternatives

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As an alternative to the recommended action, the City Council may consider the following if supported by the full evidentiary record:

1. Deny the appeal and uphold the Landmarks Commission’s decision by adopting the Landmarks Commission’s findings pursuant to Statement of Official Action 25ENT-0069 and designate the front residence as Structure of Merit.

2. Articulate revised findings resulting in the denial of the subject appeal, approving the subject property as a Structure of Merit.

Environmental Analysis
The denial of the appeal and denying designation of the property as a Structure of Merit is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) (Common Sense Exemption) of the CEQA Guidelines, which states that CEQA does not apply, “where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment”. Based on the evidence provided in the record, the property does not meet the criteria for designation and is not a historic resource for the purposes of CEQA. Therefore, it can be seen with certainty that the denial is exempt from CEQA.

Financial Impacts and Budget Actions
There is no immediate financial impact or budget action as a result of the recommended action.

Prepared By: Stephanie Reich, Design and Historic Preservation Planner Approved Forwarded to Council
Attachments:

A. Demo Permit Application 1125 18th Street

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B. 25ENT-0069 (1125 18th St) SM Application (2)
C. 25ENT-0135 (1125 18th St) APP Application
D. 25ENT-0135 (1125 18th Street) appeal narrative
E. 1125 18th Street (25ENT-0069) Staff Report
F. HRA 2025-07-08_1125 18th Street1
G. Signed STOA_25ENT-0069_(1125_18th
H. City Council Public Notice 1125 18th Street Appeal 25ENT-0135 I. LC Minutes 20250714 Approved
J. LC Public Correspondence 20250714 Item 6A
K. 05 Levine Act P&T - signed 3-27-25
L. Written Comments
M. PowerPoint Presentation

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Packet Pg. 1680 Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1681 Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1682 Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1683 Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1684 Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 34'
10'-1"
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13'-11"
43'
16'
5'

97.0321 8'-1"
28'-6"
24'-6"
6'
14'-1"
11'-7"
14'-1"
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24'-6"
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18TH STREET

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C-37594

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DEMOLITION OF EXISTING

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DEMOLITION PLAN
REF. NORTH
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TRUE NORTH
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MAINTENANCE PLAN NOTES:

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Packet Pg. 1685 Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 







  



 


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12.A.a
Packet Pg. 1686
Attachment: Demo Permit Application 1125 18th Street (7242 : Appeal of 1125 18th Street Structure of CITY OF SANTA MONICA – CITY PLANNING DIVISION

LANDMARKS COMMISSION
DESIGNATION and STRUCTURE OF MERIT

APPLICATION
Landmark Designation Application Page 1
November 2024
Applications are submitted online through a virtual appointment system.

If you have questions about completing this application, please email City Planning at [email protected].

GENERAL INFORMATION
PROJECT ADDRESS: 1125 18 th Street
PROJECT DESCRIPTION: Nomination for Structure of Merit for front house constructed 1923 with some distinctive architectural features. Behind it, a secondary structure was built in 1950. By applying for a permit, I understand and agree that contact information, including but not limited to, email addresses and telephone numbers, will become part of a disclosable public record pursuant to the California Public Records Act and that the City may elect not to redact contact information contained in this application prior to disclosing a copy of this application to the public. I further agree that I do not object to the City’s disclosure of contact information contained in this application in response to public records requests.

APPLICANT (Note: All correspondences will be sent to the contact person) Name: Organization Name:

Address: City/State: Zip:

Phone: Email:

CONTACT PERSON (If different from applicant)
Organization Name:

City/State: Zip:

Name:

Address: QG6WUHHW
Phone: Email:

Relation to Applicant:

PROPERTY OWNER
Name:

Address: City/State: Zip:

Phone: Email:

How is the ownership structured?
Person(s) Trust LLC Other______________________________________ Designation Requested Choose One, or Both:

Landmark Structure of Merit
I hereby certify that I have reviewed the subject application and declare, under penalty of making a false declaration, that to the best of my knowledge and belief, the information provided within this application is true, correct, complete, and made in good faith. I authorize the applicant or contact person to make decisions that may affect my property as it pertains to this application.

Applicant’s Name (PRINT) Applicant’s Signature / Date
Mario Fonda-Bonardi, President
Kaitlin Drisko, Executive Director
Santa Monica Conservancy
2520 2nd Street 6DQWD0RQLFD 90405
(310) 496-3146 [email protected]
Santa Monica Conservancy
Santa Monica, CA 90405
[email protected]
Executive Director
Houshmand Joseph Naim
301 N. Avalon Blvd Wilmington, CA 90744
(310) 270-5695 [email protected]
Unknown.

Santa Monica Conservancy
(310) 948-5311
4/30/2025

12.A.b
Packet Pg. 1687 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 2
November 2024 PROPERTY INFORMATION/ SUBMITTAL REQUIREMENTS

SUBMITTAL REQUIREMENTS
Completed Application
All materials must be submitted digitally. Prepare one PDF file with the SIGNED application and all supplemental materials and a second PDF file of the Project Plans. Resolution should allow legible printing at 11" x 17".

Copy of ANY Relevant Permits
Digital Color Photographs:

Photographs of elevations or improvement organized to represent the current and past condition of the property.

Brief description of site or structure
Additional Information
Any information you feel would be of assistance in reviewing the application, such as original plans, old photos, or other historical information.

Description of site or structure (Optional).

PROPERTY INFORMATION
FOR STRUCTURES ONLY:
x Date of Construction: ______________ Factual Estimated x Historic Use of Structure(s): ___________Present Use of Structure(s): _________________ x Occupancy Status: Occupied Unoccupied
Statement of historic importance (Optional):
1923
Dwelling Dwelling

UNKNOWN
See Attached

12.A.b
Packet Pg. 1688 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 3
November 2024 SUBMITTAL REQUIREMENTS

OAKS INITIATIVE DISCLOSURE FORM
** Required for all Applications **
Pursuant to City Charter Article XXII, The Taxpayer Protection Amendment of 2000, the applicant is required to disclose all of its trustees, directors, partners, officers, and those with more than a ten percent (10%) equity, participation or revenue interest in Applicant / Contractor.

Identify the names of the following individuals
Applicant / Contractor: __________________________________________________________ Trustees, directors, partners, officers of the Applicant / Contractor (attach additional sheets if necessary):

Those with more than a 10% equity, participation or revenue interest in Applicant / Contractor (attach additional sheets if necessary):

Santa Monica Conservancy
Mario Fonda-Bonardi, President
Carol Lemlein, Vice President
Alec Nedelman, Secretary
Judith Meister, Treasurer
Catherine Conkle, Board Member
Carolyne Edwards
Nina Fresco
Karen Ginsberg
Albin Gielicz
David Kaplan
Ruthann Lehrer
Sharon Reyes
Amanda Seward
Morgan Sykes Jaybush
Laurel Schmidt
None. The Conservancy is a 501(c)3 non-profit corporation. , Board Member
, Board Member
, Board Member
, Board Member
, Board Member
, Board Member
, Board Member
, Board Member
, Board Member
, Board Member

12.A.b
Packet Pg. 1689 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 4
November 2024
SANTA MONICA CITY ATTORNEY’S OFFICE

TO: Public
FROM: City Attorney’s Office
RE: Levine Act Disclosure Form
DATE: January 25, 2024

The Levine Act (Government Code 84308) is a California law aimed at preventing “pay to play” practices by prohibiting parties, participants, and their agents in a proceeding involving a license, permit, or other entitlement from contributing more than $250 to an officer of the City during a 12-month period. The prohibition applies to any 12-month period while the proceeding is pending and for 12 months following the date a final decision is rendered in the proceeding.

State law requires a party to a proceeding to disclose any contributions exceeding an aggregate $250 that the party and their agents have made to an officer of the City within the preceding 12 months. The Disclosure Form is intended to assist City officials with recognizing when they have an obligation to disclose and recuse themselves, and to aid parties with their disclosure obligations.

1. To what sort of proceedings is the disclosure form applicable?

The Levine Act applies to all discretionary entitlements and contracts, with the exception of labor contracts, personal employment contracts, and contracts that must be awarded to the lowest responsive/responsible bidder. It does not apply to ministerial approvals. For instance, the Levine Act applies to the following:
• Building and development permits
• Conditional use permits
• Contracts generally (unless an exception applies):
o Contracts for goods, services, professional services
o Real property contracts for purchase, sale, lease
o Contract amendments o Settlement agreements
o Small contracts, including purchase orders, and zero dollar contracts (no de minimis exception)
• Public street abandonments
• Private development plans
• Professional license revocations
• Rezoning of specific real estate parcels
• Event permits
• Rulemaking procedures affecting a particular industry where only a small number of businesses are affected

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Packet Pg. 1690 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 5
November 2024
• Special district formation proceedings involving the creation of a special use or benefit to the person in the district
• Tentative subdivision and parcel maps
• Zoning variances
• Vacation of a public easement across private property • Pre-applications, such as for General Plan Amendment, considered by the legislative body prior to filing of formal application
• Contracts entered under the City Manager’s Authority
• Closed session items that may result in a contract/settlement agreement approved by Council (real estate or litigation)
It does not apply to:
• Purely ministerial decisions
• General policy decisions or rules where the interests affected are many and diverse • Ordinances and resolutions (except items like development agreements adopted by ordinance)
• Ballot measures
• Departmental policies
• Council rules
• Contracts awarded to the lowest responsive/responsible bidder (not applicable in Santa Monica)
• Labor contracts and project labor agreements
• Personal employment contracts
• Allocation of resources in the City budget

2. Who is required to disclose?

A “party” to a proceeding is any person who files an application for, or is the subject of, a proceeding. In general, a person or company who applies for a permit, license, or right to use property in a particular way, which requires the City’s discretionary approval, will qualify as a party.

Parties are also required to disclose contributions by their agents. An “agent” is someone who (1) represents a party to a proceeding for compensation; and (2) appears before or otherwise communicates with the City for the purpose of influencing the pending proceeding.

This can include law firms, architects, engineers, consultants, and similar entities. Both the individual and their employer or firm are considered “agents.”

A party should also disclose contributions of other entities majority owned by the party, as well as contributions of any other entity whose contributions it directs or controls.

3. What must be disclosed?

A party must disclose campaign contributions over $250 made in the prior twelve months. A “contribution” is anything of value for which the party has not received full consideration, including money, nonmonetary items, payments made for advertising or

12.A.b
Packet Pg. 1691 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 6
November 2024
other expenses coordinated with a candidate or committee, loans, tickets to political fundraisers, etc.

4. Who is considered an officer of the City?

An “officer” is anyone who may make, participate in making, or attempt to influence a decision in the proceeding or who exercises authority over officers who may do so. This includes elected officials, members of appointed boards and commissions, the City Manager, and any individual who is a candidate for elected office or who has been a candidate in the twelve months prior to the decision. This definition is included on the Disclosure Form.

5. When should the disclosure occur?

The Disclosure Form must be completed (1) by a party to a contract with the City (or that party’s agent) at the time the party submits a response to a Request for Proposal or other competitive solicitation, enters into contract negotiations with the City, or executes a contract with the City, whichever is earliest; or (2) by a party to a license, permit, or other entitlement proceeding before the City at the time the party (or their agent) submits the license, permit, or entitlement application to the City. The party (or their agent) must submit a supplemental form if they make any new reportable contributions while the same contract, license, permit, or other entitlement is being considered. The party (or their agent) must also use the form if they need to correct any previously submitted form.

Parties are solely responsible for completing the form accurately, and could face penalties for failure to do so. The California Fair Political Practices Commission (FPPC) is the body who enforces violations of the Levine Act. If a party is uncertain about whether they are required to report or combine a contribution, they should consult with their attorney.

Nothing herein constitutes legal advice and individuals are urged to consult with their own attorney regarding the requirements of the law. To the extent there is any inconsistency, the language of the Levine Act and FPPC Regulations govern over this notice. Resources for officers, parties, participants, and agents, are available on the FPPC’s website at https://www.fppc.ca.gov/learn/pay-to-play-limits-and-prohibitions.html

12.A.b
Packet Pg. 1692 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 7
November 2024

CITY OF SANTA MONICA

CALIFORNIA LEVINE ACT DISCLOSURE
In 2022, California’s SB1439 extended requirements under Government Code Section 84308, also known as the "Levine Act", to prohibit City “Officers” from participating in any action related to a contract, license, permit, or entitlement if such Officer received campaign contributions totaling more than $250 within the previous twelve months, and for twelve months following the date of a final decision, from a party or participant to the proceeding, or their agent.

Section 84308(a)(4) of the Levine Act defines an "Officer" as follows: “Officer” means any elected or appointed officer of an agency, any alternate to an elected or appointed officer of an agency, and any candidate for elective office in an agency. The term “Officer” is further defined 2 Cal. Code Regs. Section 18438.1, which states:

An officer of an agency includes only those persons who make, participate in making, or in any way attempt to use their official position to influence a decision in the license, permit, or entitlement for use proceeding, or who exercise authority or budgetary control over the agency or officers who may do so, and:
(1) Serve in an elected position, including an official appointed to an elected position due to an interim vacancy or an election otherwise canceled because the official was the sole candidate for the position;
(2) Serve as a member of a board or commission;
(3) Serve as the chief executive of a state agency, or county, city or district of any kind; or
(4) Have decision making authority with respect to the proceeding involving a license, permit, or other entitlement for use and is also a candidate for elected office or has been a candidate for elective office in the 12 months prior to the proceeding.

A list of Santa Monica Elected Officials and members of boards and commissions can be found at the following links. The party making this certification is responsible for determining whether a recipient of a political contribution is a City Officer prior to completing this form.
https://www.smgov.net/departments/council/
https://www.santamonica.gov/departments/rent-control https://www.smgov.net/ /boards/.

Have you, your company, or any agent on behalf of you or your company, made any political contributions of more than $250 to any City Officer in the twelve months preceding the date of the submission of your application or proposal?
____YES ____ NO
Name of Councilmember or City Officer: _________________________________ X

12.A.b
Packet Pg. 1693 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Landmark Designation Application Page 8
November 2024
City of Santa Monica Levine Act Disclosure Form
Name of Contributor: _________________________________________________ Date(s) of Contribution(s): ____________________________________________ Amount(s) ________________________________________________________ Please specify below and/or add additional sheet(s) to identify additional Councilmembers or City Officers to whom you and/or your agents made campaign contributions.

Answering YES does not preclude the City of Santa Monica from awarding a contract, license, permit, or entitlement or taking any subsequent action related to the item. It does, however, preclude the identified City Officer from participating in any actions related to such item.

By signing below, you certify you also agree to disclose to the City any future contributions made to Councilmembers or other City Officers by you or your agent(s) after the date of signing this disclosure form, and within 12 months following the approval, renewal, or extension of the requested contract, license, permit, or entitlement.

I HEREBY CERTIFY UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF CALIFORNIA THAT THE FOREGOING IS TRUE AND CORRECT.

Signed: ____________________________ Date: ____________________ Print Name: _________________________ Title: _____________________ Company: ___________________________
Additional Disclosures:

Please note this form is a public record and subject to a California Public Records Act request.

City of Santa Monica Levine Act Disclosure Form
4/30/2025
Mario Fonda-Bonardi President
Santa Monica Conservancy

12.A.b
Packet Pg. 1694 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) P.O. BOX 653
SANTA MONICA, CA 90406
310-496-3146
www.smconservancy.org
DATE: April 30, 2025
RE: Structure of Merit Nomination – 1125 18th Street, Santa Monica, CA 90405

Dear Ms. Reich,
The Santa Monica Conservancy is submitting a nomination for Structure of Merit designation for the property at 1125 18th Street in response to the property owner’s demolition permit application.

The subject property is listed on the HRI as a potential Structure of Merit, and the Conservancy concurs that a full historic assessment should be conducted to confer status and apply resulting privileges, entitlements, and standards. We find that the structure is a rare example representing the first phase of residential development in an area that today consists primarily of multi-unit housing, and that it is an unusual and late representative of Craftsman design. Its setting with a deep frontyard setback, green lawn and mature landscape conveys the name of the subdivision as the Green Acres tract.

Our application states that the property meets Structure of Merit criteria A, B1 and B2.

We understand that the owner’s intention is to develop the site for six units of new housing.

Because this is a large lot, and the existing structure at the front of 1125 built in 1923 occupies a small part of the parcel, there remains substantial space to construct new housing inclusive of preservation of the existing front house. There are many successful examples of this type of development in Santa Monica.

The Conservancy intends to reach out to the owner as part of the process for consideration of a Structure of Merit designation, to present the benefits of designation as well as to discuss future development scenarios that include preserving the historic resource.

Thank you for your assistance.

Sincerely,
Mario Fonda-Bonardi
President, Santa Monica Conservancy

12.A.b
Packet Pg. 1695 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1125 18th Street, Santa Monica, CA 90405
Nomination for Structure of Merit
4/30/2025

Page 1 ends

DESCRIPTION OF SITE AND STRUCTURE
The parcel at 1125 18th Street is 160 X 50 ft. in size and is located between Wilshire Boulevard and California Avenue in the Green Acres tract. The primary structure on 18th Street is a late Craftsman bungalow constructed in 1923 with some distinctive architectural features. Behind it, a secondary structure was built in 1950. A large mature tree with a spacious canopy is situated in the front yard. A garage on the south side of the parcel, built at the same time as the house, was demolished recently, but the ribbon driveway remains.

The HRI lists this property as eligible for Structure of Merit designation:
“1125 18th Street appears eligible for local listing as a Santa Monica Structure of Merit. The property conveys patterns of residential development that shaped the Wilshire Montana/MidCity neighborhoods of Santa Monica in the early decades of the twentieth century. Constructed in 1923, it is an example of a residential building from this formative period of neighborhood growth. The building does not rise to the level of significance needed to be eligible as a Landmark, but it appears eligible as a Structure of Merit.” The Craftsman bungalow displays characteristic features of that style, with one notable variation: the front entry, rather than frontally facing the street, is placed on a side elevation, offset from the street. The low-pitched front gable roof intersects with a sidefacing gable that projects over the entry door. This roof form caps a mass that projects slightly forward from the mass under the main roof gable, creating a stepped façade profile.

The cladding is narrow wood clapboard and the roof is composition shingles. The main façade feature is a continuous series of rectangular windows with wide board surrounds, wood sash double-hung with Craftsman-style crossed muntins; they are original. Exposed prominent rafter tails and angular wood braces over the entry door are typical Craftsman features. A slanted wheelchair ramp accesses the front door, altering the original front steps.

The green front lawn and mature tree with an expansive green canopy are integral to the significance of the site, alluding to the name of the original subdivision: Green Acres. The neighborhood today consists primarily of multi-family properties, making this Craftsman bungalow and its landscaped setting a “window into the past.”

STATEMENT OF ARCHITECTURAL SIGNIFICANCE

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Packet Pg. 1696 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1125 18th Street, Santa Monica, CA 90405
Nomination for Structure of Merit
4/30/2025

Page 2 ends

The Craftsman bungalow at 1125 18th Street was built in 1923, a late example of an architectural style that was prevalent from c. 1905-1920, with a peak of popularity from 1910-1915. By the early 1920s, Spanish Colonial Revival had become predominant in residential design along with other historical revival styles. Chronologically, this example is an outlier, but it indicates that the appeal of Craftsman architecture lingered into the 1920s.

This house is a pristine and intact example of Craftsman bungalow design, unaltered except for the handicapped ramp. The wood cladding consists of narrow clapboards, and the roof forms are low-pitched gables. The windows are double-hung wood sash, with crossed muntin detailing, framed with wide board surrounds. Structural members are prominent design features: exposed rafter tails, roof gable ends, angular brackets supporting the entry door gable. It has a high level of architectural integrity.

As an example of Craftsman design, the house displays variations on the traditional template for Craftsman homes. Typically, the entrance faced the street in a frontal position.

Here, the entry door is offset at a side elevation. Rather than an expansive front porch, the entry porch is smaller, compressed to fit the size of the front door. The elevation that faces the street consists of two groups of windows in rows, crowned with intersecting roof gables. The window detailing with the crossed muntins is a feature with aesthetic interest, with the novelty of asymmetry – the lower muntin is omitted.

STATEMENT OF HISTORIC IMPORTANCE
The house at 1125 18th Street represents the original housing development of the midWilshire area when it first became a residential neighborhood in the 1920s. Today, this house is relatively unique in its neighborhood, which consists primarily of multi-unit buildings. Its survival provides a glimpse back in time to understand the Green Acres tract as it was first developed in the 1920s, part of the boom in Santa Monica neighborhood development beginning in the 1920s. In later decades, multi-family construction replaced the original first-generation homes, so that this property today is a virtual “window into the past.” The attached Sanborn maps show the evolution of this mid-Wilshire area, and the gradual replacement of the original housing stock. The original tract name, Green Acres, is evoked by the landscaped setting of a grass lawn and sturdy tree with an expansive canopy in front of the house.

12.A.b
Packet Pg. 1697 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1125 18th Street, Santa Monica, CA 90405
Nomination for Structure of Merit
4/30/2025

Page 3 ends

APPLICABLE CRITERIA FOR DESIGNATION AS A STRUCTURE OF MERIT Section 9.56.080
Criteria A, B1 and B2.

A. The structure has been identified in the City’s Historic Resources Inventory.

B. The structure is a minimum of 50 years of age and meets one of the following criteria:

1. The structure is a unique or rare example of an architectural design, detail or historical type.

The subject property is a Craftsman bungalow that was constructed late in the time period for that style’s prevalence – 1923 – and has design features that are unique within the typical framework of that style: the offset entryway placed at a side elevation rather than at the front; the small entry porch reduced to frame the front door; the intersecting cross roof gables; the bank of windows on the front façade with crossed muntins which are asymmetrical, lacking the lower muntin.

2. The structure is representative of a style in the City that is no longer prevalent.

Single-family one-story Craftsman homes represent a style that is no longer prevalent.

12.A.b
Packet Pg. 1698 Attachment: 25ENT-0069 (1125 18th St) SM Application (2) (7242 : Appeal of 1125 18th Street Structure of Merit Designation) CITY OF SANTA MONICA – CITY PLANNING DIVISION

APPEAL FORM
ENT No.:

Appointments to submit an Appeal Form can be scheduled at the following links for ONLINE or IN-PERSON submittal.

Appointments are encouraged, however, Appeal Forms are also accepted during REGULAR COUNTER HOURS. if you have questions about completing this application, please email City Planning at [email protected].

GENERAL INFORMATION
PROJECT ADDRESS:

PROJECT CASE NUMBER: ________________ ORIGINAL HEARING DATE:

ACTION BEING APPEALED:

By applying for an appeal, I understand and agree that contact information, including but not limited to, email addresses and telephone numbers, will become part of a disclosable public record pursuant to the California Public Records Act and that the City may elect not to redact contact information contained in this application prior to disclosing a copy of this application to the public. I further agree that I do not object to the City’s disclosure of contact information contained in this application in response to public records requests.

APPELLANT (Note: All correspondences will be sent to the contact person) Name: Organization Name:

Address: City/State: Zip:

Phone: Email:

CONTACT PERSON (If different from appellant)
Name: Organization Name:

Address: City/State: Zip:

Phone: Email:

Relation to Applicant:

A hearing date on the appeal will not be scheduled until sufficient information regarding the basis for the appeal has been received to enable City Planning Division staff to prepare the required analysis for the staff report.

Appellant’s Name (PRINT) Appellant’s Signature / Date
1125 18th Street 25ENT0069 7/14/25 Pam O'Connor Self 906 9th Street #2 Santa Monica, CA 90403 310-905-7582 [email protected] Pam O'Connor Designation of 1125 18th Street as a Structure of Merit 25ENT-0135

12.A.c
Packet Pg. 1699 Attachment: 25ENT-0135 (1125 18th St) APP Application (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Appeal Form
October 5, 2023 Page 2 APPEAL FORM QUESTIONNAIRE

APPEAL INFORMATION
Please state the specific reason(s) for the appeal (use additional sheets if necessary) Is the appeal related to the discretionary action and findings issued for the proposed project? If yes, please explain.

Yes No
Is the appeal related to the conditions of approval? If yes, which conditions and why:

Yes No
Is the appeal related to design issues? If yes, please explain.

Yes No
Is the appeal related to compatibility issues such as building height, massing, pedestrian orientation, etc.? If yes, please explain.

Yes No
Is the appeal related to non-compliance with the Santa Monica Municipal Code? If yes, which Code section(s) does the project not comply with and why:

Yes No
Is the appeal related to environmental impacts associated with the project If yes, please explain:

Yes No
Is the appeal related to other issues? If yes, please explain:

Yes No
See Attachment

12.A.c
Packet Pg. 1700 Attachment: 25ENT-0135 (1125 18th St) APP Application (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Basis for Appeal of 1125 18th Street Structure of Merit designation 1) Insufficient findings.

The Structure of Merit category has been used to designate and put restrictions on properties that DO NOT meet the criteria to be designated as a Landmark.

To qualify for designation as a Structure of Merit a property must be identified in the Historic Resource Inventory (HRI, a windshield survey of the City conducted in 2018) as appearing to be eligible as a Structure of Merit and be at least 50 years old. Then the property must meet one of two criteria:

B1. The structure is a unique or rare example of an architectural design, detail or historical type.
or
B2. The structure is representative of a style in the City that is no longer prevalent.

The property does not meet either B1 or B2. The building is not a rare example of a Craftsman style house in Santa Monica. While it exhibits some influences of the Craftsman style, the building and its materials are not fully authentic to the Craftsman style. The building is not fully representative or true to the style. There are better examples of Craftsman style buildings found throughout the City and in the Wilshire Montana neighborhood.

The independent consultant report commissioned by the City of Santa Monica and the Staff Report for the property both agree that the property is not a good or representative example of the Craftsman architectural style and it does not meet the criteria for designation as a Structure of Merit.

The period of significance for the Craftsman style is 1906 to 1920. The subject building was constructed in 1923, after the period of significance of the architectural style. The independent consultant report states that the building is a “modest example of a Craftsman bungalow, a type that is relatively common in the neighborhood and Santa Monica” and “given its relatively simple design and the continued presence of similar properties in the area, it does not represent a rare or unique example of its type.”
Testimony from the representative of the nomination applicant said that “architectural design” was “primarily” the basis for the nomination, Citing the “unique” features of the building’s design and calling it “innovative”, the representative added that the “quirky asymmetry” and the row of windows along the front (which are NOT representative of the Craftsman style) were “perhaps inspired by a modernist concept of residential design by avant garde modernism in the 1920s.” There is no evidence to support this supposition. The builder was Miner L. Fuller who was listed in the 1925 Santa Monica City Directory as living at 1253 18th Street. No biographical information could be found regarding Fuller, his training or if he had a body of work. It is likely that Fuller was one of many individual builders/contractors who took

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Packet Pg. 1701 Attachment: 25ENT-0135 (1125 18th Street) appeal narrative (7242 : Appeal of 1125 18th Street Structure of Merit Designation) advantage of the building boom of the 1920s and constructed an occupational simple building on speculation. Fuller was not listed as a contractor in City Directories of the period (of which there were four pages listing contractors). There is no evidence that Fuller knew of or was inspired by avant garde 1920s era modernist architects.

According to the 2018 Historic Context Survey Results there are 178 Craftsman style properties in Santa Monica. Within the Wilshire Montana neighborhood, where the subject property is located, there are 30 Craftsman style properties identified, of which 18 were eligible as Landmarks and 12 eligible as Structure of Merit. These buildings “represent modest bungalow style homes, which display a variety of different Craftsman design elements and types.” The Commission’s discussion and the findings made for the designation revolved around the building being in the Green Acres Tract. This is one of many tracts subdivided for residential development in the City in the early 20th Century. The Green Acres Tract is a small area – bounded on the north by Washington Avenue, Wilshire Boulevard on the south, 17th Street on the west and 21st Street on the east -- an area bounded by two long blocks and four short blocks. There was no evidence provided as to why this small tract was significant in the development history of Santa Monica as it was one of many tracts recorded in the early 20th Century as Santa Monica was developing into a residential city.

The Commission’s findings were that the subject property was “unique” within this small area of the City and that the Craftsman bungalow architectural style was no longer prevalent in this very small area of the City and thus was a “rare” example of the Craftsman style.

Those findings are inadequate. The Commission winnowed down to a very small area of the City and then stated that within that small area this Craftsman style building is “unique” and “rare” - -- in spite of the data in the HRI that shows that there are 30 Craftsman style buildings in the Wilshire-Montana neighborhood and 178 Craftsman style buildings in the City of Santa Monica. 2) The Structure of Merit designation is flawed.

The Structure of Merit designation is “unique” to Santa Monica. It is a category established decades ago in an era of “downzoning” of the City. Buildings that do not qualify to be designated as a Landmark can be designated as a Structure of Merit which restricts redevelopment of a property and also allows a property that is not a bona fide Landmark to take advantage of the Mills Act, which provides the owner of a property a reduction in property taxes (note, the amount of the reduction is “paid” by the Assessor withholding the amount which otherwise go to the City as revenue).

The State of California has a list of California Historical Resource Status Codes to be used to identify the status of a historic resource ) https://ohp.parks.ca.gov/pages/1069/files/ResourceStatus-Codes.pdf).

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Packet Pg. 1702 Attachment: 25ENT-0135 (1125 18th Street) appeal narrative (7242 : Appeal of 1125 18th Street Structure of Merit Designation) The status code 5S3 is that a property “appears individually eligible for local listing or designation through survey evaluation.” In the City of Santa Monica’s Historic Resource Inventory, a property that appears to be eligible for the City’s Structure of Merit category is given the status code of 5S3*. The * is added as there is no official status code for a building that is not evaluated as eligible for Landmark designation. The concept of Structure of Merit does not exist within the framework of the State’s historic preservation programs.

In the discussion at the Commission meeting regarding the subject property one Commissioner observed that the Structure of Merit designation was a “quirky” part of the Landmarks Ordinance and that the Commission has “wrestled with it for 20 years trying to change it.” The Commissioner noted that the pandemic and staff reductions stalled any updating of the City’s Landmark Ordinance.

Regarding the criteria for a Landmark, the City’s criteria are a holdover from early historic preservation ordinances. Many cities have updated their landmarks ordinance to comport with the four criteria used by the National Register of Historic Places and the California Register of Historical Resources.

Last year AB 2580 was signed into law. The bill requires an annual report be made to the State Department of Housing and Community Development HCD) as part of the City’s Housing Element Annual Progress Report to include a list of all historic designations listed on the National Register of Historic Places, the California Register of Historical Resources (California Register), or a local register of historic places by the city in the past year, and the status of any housing development projects proposed for the new historic designations.

The purpose of the legislation is to prevent historic preservation ordinances from unduly hindering housing development. The City of Santa Monica’s Structure of Merit, which is not recognized in the California Historical Resource Status Codes, would be found to be hindering housing development in the guise of historic preservation.

The City of Santa Monica’s Landmark Ordinance should be updated to revise the Landmark criteria and delete the Structure of Merit category.

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Packet Pg. 1703 Attachment: 25ENT-0135 (1125 18th Street) appeal narrative (7242 : Appeal of 1125 18th Street Structure of Merit Designation) -1-
Landmark Commission Meeting: July 14, 2025
Agenda Item: 6A
To: Landmark Commission
From: Stephanie Reich, Landmark Commission Secretary
Permit(s): 25ENT-0069
Address(s): 1125 18th Street
Applicant: Santa Monica Conservancy
Subject
Public Hearing to consider the designation application 25ENT-0069 for the property located at 1125 18th Street to determine whether the residential structure in whole or in part, should be designated as a Structure of Merit. The Landmarks Commission will consider the application based on whether the application, research and public testimony demonstrates that the building meets one or more of the required criteria for Structure of Merit designation pursuant to SMMC Section 9.56.080. Consideration of compliance with the California Environmental Quality Act (CEQA), including an exemption under CEQA Guideline 15061(b)(3) (Common Sense Exemption).

Recommended
Action
1) Staff recommends the Commission deny the designation of the residence at 1125 18th Street, as a Santa Monica
Structure of Merit. The staff analysis concludes that the structure does not appear eligible for listing as a Structure of Merit under any of the designation criteria as the property is a typical example of a common property type.
2) 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.

Alternatively, if the project were to be approved, the
Commission would adopt a finding of no possibility of
significant effect pursuant to Section 15061(b)(3) (Common Sense Exemption) of the California Environmental Quality Act (CEQA) Guidelines.

Introduction & Background
The property owner has filed a demolition permit application. The Santa Monica Conservancy filed an application to designate the main structure on the property as a Structure of Merit. The property, a modest example of a Craftsman bungalow, is a single-family residence built in 1923.

The structure was identified in the Santa Monica Historic Resources Inventory (HRI) in 2018 as a potential Structure of Merit. The structure had not previously identified on the City’s HRI.

Page & Turnbull has been retained by the City of Santa Monica (City) to prepare a Historic Resource Assessment (HRA) to determine if the property is eligible for designation, and if so, under which criteria.

Page & Turnbull evaluated the property under the Structure of Merit Criteria in SMMC 9.56.080. and assessed its physical integrity. As a result of this analysis, Page & Turnbull concludes that

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Packet Pg. 1704 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 the property does not meet any of Criterion, as it is a modest example of a Craftsman bungalow, a type that is relatively common in the neighborhood and Santa Monica. Given its relatively simple design and the continued presence of similar properties in the area, 1125 18th Street does not represent a rare or unique example of its type. 1125 18th Street does not appear to meet any of the criteria for designation as a City of Santa Monica Structure of Merit and therefore does not appear to be eligible for this level of designation. Preservation staff has reviewed the report and agrees with the Page & Turnbull recommendation.

This report summarizes the HRA by Page & Turnbull and provides a contrast with the applicant’s historic analysis. For more detailed information, please refer to the Historic Resource Assessment and Applicant’s Materials attached to this report.

Aerial view of 1125 18thStreet (outlined in red). Source: Google Earth, 2023, edited by Page & Turnbull.

West (front) elevation viewed from 18th Street (current)

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Packet Pg. 1705 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 Historic Resources Inventory Status
As noted above, 1125 18th Street was evaluated as part of the Historic Resources Inventory (HRI) survey and found to be potentially eligible for listing as a Santa Monica Structure of Merit.

The findings of the 2018 HRI update are quoted below:
1125 18th Street appears eligible for local listing as a Santa Monica Structure of Merit. The property conveys patterns of residential development that shaped the Wilshire Montana/Mid City neighborhoods of Santa Monica in the early decades of the twentieth century. Constructed in 1923, it is an example of a residential building from this formative period of neighborhood growth. The building does not rise to the level of significance needed to be eligible as a Landmark, but it appears eligible as a Structure of Merit.

The property was not included in a previous HRI.

Parcel map, showing the subject property, shaded in red. Source: Los Angeles County Assessor, edited by Page & Turnbull, 2025 Surrounding Neighborhood
The subject property is located in a residential neighborhood one block from Wilshire Boulevard, a major east-west commercial thoroughfare that runs the length of the city. The parcels surrounding the subject property are characterized by a mix of multi-family properties and single-family residences ranging from the early 20th century to the present.

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Packet Pg. 1706 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 4 Single-family residence at 1133 18th Street,
looking northeast.

Property at 1127 18th Street, looking north.

Multi-family housing on the east side of 18th Street,
looking north.

Apartment complex on the south side of 18th Street,
looking west.

ENVIRONMENTAL ANALYSIS
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.

Alternatively, if the project were to be approved, the Commission would adopt a finding of no possibility of significant effect pursuant to Section 15061(b)(3) (Common Sense Exemption) of the California Environmental Quality Act (CEQA) Guidelines. Pursuant to CEQA Guidelines Section 15061(b)(3) it can be seen with certainty that there is no possibility that approving an application and designating the property as a Landmark 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 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.

PUBLIC NOTIFICATION

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Packet Pg. 1707 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 5 Notice of this hearing was provided as required by Section 9.56.170(c) of the Landmarks Ordinance, with notice sent to all owners and occupants within a 300-foot radius and a newspaper notice published in the Santa Monica Daily Press at least 10 consecutive calendar days prior to the hearing. A copy of the notice is included attached to this report.

ANALYSIS
Property Information and Architectural Description
The subject property is located on a 160-by-50-foot rectangular lot on the east side of 18th Street.

The building on the property is a 952 square foot rectangular one-story, single-family wood-frame residence with a low pitched front gable roof with an intersecting side gable projection. The roof is clad with asphalt shingles and features wide overhanging eaves with exposed rafter tails and triangular cross-hatched wood vents at the gable ends. The building is clad in painted narrow wood clapboard. Typical windows are wood double-hung windows with flat wood surrounds located on all façades. The upper sash of the windows on the primary (west) façade features simplified prairiestyle muntins.

The subject property is considerably set back from the street behind a front yard with a lawn, a mature tree, and landscape plantings along the primary façade. A concrete paved ribbon driveway with grass down the center runs along the south side of the parcel and terminates at the rear wood fence.

Front yard, looking north Image from Google Maps, current There is a detailed description of the existing structure and the site included in the Page & Turnbull HRA (attached) beginning on Page 7.

Architectural Style: Craftsman Bungalow
Craftsman bungalows are typically characterized by low-pitched gabled roofs with wide, unenclosed eave overhangs; decorative beams or braces; exposed rafter tails; tapered square columns or pedestals; and extending porch elements. Small-scale, wood-framed Craftsman bungalows could be constructed easily and affordably and were often available as kit houses, or built from plans in pattern books, through 1910s. Neighborhoods of Craftsman houses developed into the 1920s as streetcar suburbs.

Elaborate and unique homes of the wealthy, such as the Gamble House in Pasadena, represent high style examples while rows of more modest bungalows are found throughout California.

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Packet Pg. 1708 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 6 The Gamble House designed by Greene & Greene
in Pasadena is a high-style example of the
Craftsman style. Source: Page & Turnbull,
2011.

The 1908 “Ye Planry” is an example of a Craftsman
bungalow kit house. Source: First Edition Catalog
of Bungalow Plans, Los Angeles,
1908-1913 via Antiquehome.org.

Based on a review of the 2018 Historic Context Statement survey results, 178 properties in Santa Monica were identified by the survey as “Craftsman” style. Of these, 30 individually significant properties were identified in the Wilshire Montana neighborhood, 18 as potential Landmarks and 12 as potential Structures of Merit. Like 1125 18th Street, all 30 properties were identified as being significant, at least in part, for conveying the “patterns of residential development” in the Wilshire Montana area in the “early decades of the twentieth century”. Twenty of the Craftsman style properties identified as significant in the Wilshire Montana neighborhood represent relatively modest bungalow-style homes, which display a variety of different Craftsman design elements and types, as well as levels of integrity.
847 10th Street. Built 1919, identified by the 2018
survey as eligible for designation as a Landmark.
918 19th Street. Built in 1924, identified by the 2018
survey as eligible for designation as a Structure of
Merit.

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Packet Pg. 1709 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 7 811 5
th Street. Built in 1912, identified by the 2018
survey as eligible for designation as a Structure of
Merit Source: Google Maps.
908 California Avenue. Built in 1922, identified by the 2018 survey as eligible for designation as a Landmark.

Source: Google Maps.

Builder: M. L. Fuller
M. L. Fuller is listed on the original building permit dated March 3, 1923; however, little is known about his life or professional work. City directories from that year list Fuller as residing at 1253 18th Street, just one block south of the subject property. During this period, many Craftsman bungalows in Los Angeles were constructed using pattern books that supplied standardized plans and elevations, and as a result, designs were often attributed to builders rather than formally trained architects. Developers and contractors frequently hired young architects who had not yet established their own practices or relied on builders with no formal architectural education. Such practices likely contributed to the lack of documentation surrounding Fuller’s career.

Integrity Analysis
With the exception of an ADA ramp on the south side, property appears to have had very few exterior modifications since it was originally constructed.

Location
The 1125 18th Street primary residence retains integrity of location. The subject building has remained situated at its location of original construction since 1923. Since the construction of the main residence, a secondary structure and fence have been installed at the rear of the property. This does not appear to impact the integrity of location.

Setting
1125 18th Street retains integrity of setting. The residence continues to be located where it was originally instructed. The parcel on which the house is located has changed with the addition of a secondary residence at the rear of the property. However, it retains its general landscape setting, driveway and view from the street.

If eligible, the appropriate period of significance for the building would be 1923, the year of its construction. It is in reference to the design and appearance of the building and its setting in this year that the integrity discussion is based.

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Packet Pg. 1710 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 8 Design, Materials, Workmanship, Feeling and Association As the property at 1125 18th Street has not been significantly altered and remains in its original location since its construction in 1923, it maintains integrity of Design, Materials, Workmanship, Feeling and Association.

Evaluation for Designation as a Structure of Merit
Per SMMC 9.56.080 of the Santa Monica Landmarks and Historic Districts Section, a property merits consideration as a Structure of Merit if it satisfies one or more of the following criteria. 1125 18th Street does not appear eligible under any of the following criteria. Below each criterion is discussed in detail:

SMMC 9.56.080(a). The structure has been identified in the City’s Historic Resources Inventory.

As the subject property is identified in the City of Santa Monica’s 2018 Historic Resources Inventory (HRI) update as a potentially eligible resource for local listing, it technically meets the wording of this criterion. However, Page & Turnbull and City Preservation staff opinion is that identification as a potential resource in Santa Monica’s Historic Resources Inventory does not alone provide sufficient basis for the individual designation of a property as a Structure of Merit.

This criterion recognizes the findings of previous evaluations conducted in support of the inventory and update. It appears to presume that if a property is “identified” in the inventory, it has already been evaluated according to and found significant under at least one of the categories of SMMC 9.56.1080(b) (see below). While the subject property has been identified in the most recent iteration of the HRI, the residence appears ineligible under this criterion. Upon further research and evaluation, the subject residence is a modest Craftsman bungalow that represents a restrained interpretation or partial application of the Craftsman style rather than a particularly distinguished or unique example. Furthermore, the modest Craftsman bungalow remains a relatively common building type that remains prevalent within the neighborhood. As such, the subject residence does not appear to warrant its current listing on the City’s Historic Resource Inventory and appears ineligible under this criterion.

SMMC 9.56.080(b). The structure is a minimum of 50 years of age and meets one of the following criteria:

The subject property was built in 1923 and, therefore, satisfies the 50-year age criterion.

SMMC 9.56.080(b)(1). The structure is a unique or rare example of an architectural design, detail or historical type.
1125 18th Street is a relatively intact example of a modest Craftsman bungalow built during Santa Monica’s real estate boom of the 1920s. The Craftsman bungalow was a common singlefamily residential style in the Wilshire Montana neighborhood at the time, as the neighborhood was being developed in response to improved transit access. These small- scale, wood-framed homes were popular due to their ease and affordability of construction. The building possesses some key characteristics of this housing type, including its one-story height, low-pitched gable roof with overhanging eaves, wood siding, and multi-lite wood frame windows. However, it lacks more distinctive architectural elements typical of Craftsman homes, such as prominent front porches with tapered stone, brick, or stucco columns or decorative beams. Rather than being a

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Packet Pg. 1711 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 9 unique interpretation of Craftsman style, the idiosyncratic entrance at 1125 18th Street, which consists of a relatively small front porch facing the driveway rather than the public right of way, is a departure from the wide front entry porches which define the character of Craftsman bungalows. As such, 1125 18th Street represents a restrained interpretation, or partial application of the Craftsman style rather than a particularly distinguished or unique example.

The extant Craftsman bungalows and other single-family residences built in the first three decades of the 20th century in the Wilshire Montana neighborhood are not remnants of originally homogenous single-family neighborhoods. Rather, residences like 1125 18th Street represent a middle stage of neighborhood development. Though established in the late 19th and early 20th century, development in these areas progressed slowly and in a patchy fashion until construction of single-family homes accelerated during the 1920s. During and after this period of growth, low-scale apartment complexes and bungalow courts in various Revival styles were constructed alongside single family homes. This pattern created the neighborhood’s varied residential character, an architectural mix which reflects decades-long development patterns in the Green Acres Tract and Wilshire Montana neighborhood.

According to the 2018 Historic Resources Inventory update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to 1125 18th Street. Although some have been removed for site redevelopment and others altered to the degree that they have lost integrity, the modest Craftsman bungalow remains a relatively common building type within the neighborhood. Given its modest design and the continued presence of similar properties in the area, 1125 18th Street does not appear to represent a rare or unique example of its type.

Therefore, the subject property does not appear to be eligible for listing as a Structure of Merit under this criterion.

SMMC 9.56.080(b)(2). The structure is representative of a style in the City that is no longer prevalent.
1125 18th Street is an example of a modest Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first three decades of the 20th century. 1125 18th Street is one of many remaining Craftsman residences in the Wilshire Montana neighborhood and the City of Santa Monica as a whole. According to the 2018 Historic Resources Inventory update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to 1125 18thStreet.

Although some have been removed for site redevelopment and others altered to the degree that they have lost integrity, the modest Craftsman bungalow remains a relatively common building type that remains prevalent within the neighborhood. Therefore, the subject property does not appear to be eligible for listing as a Structure of Merit under this criterion.

SMMC 9.56.080(b)(3). The structure contributes to a potential Historic District.

The subject property has not been identified as a contributor to a potential Historic District.

Therefore, it does appear to be eligible for listing as a Structure of Merit under this criterion.

CONCLUSION & STATEMENT OF SIGNIFICANCE
1125 18th Street is a modest example of a Craftsman bungalow, a type which remains relatively

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Packet Pg. 1712 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 10 common within the neighborhood and across the city as a whole. 1125 18th Street does not represent a rare or unique example of its type, and is not an example of a no-longer prevalent style. Based on research and analysis, Page & Turnbull has found, and staff agrees, that 1125 18th Street does not meet any of the criteria for designation as a City of Santa Monica Structure of Merit.

Attachments
Public Notice
Designation Nomination Application
Historic Resource Assessment (HRA)Report, Page & Turnbull, July 2025

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Packet Pg. 1713 Attachment: 1125 18th Street (25ENT-0069) Staff Report [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1125 18th Street

HISTORIC RESOURCE ASSESSMENT (HRA)
SANTA MONICA, CALIFORNIA [19363O]

PREPARED FOR

SANTA MONICA COMMUNITY DEVELOPMENT DEPARTMENT
July 8, 2025

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Packet Pg. 1714 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL i July 8, 2025

TABLE OF CONTENTS
I. INTRODUCTION .................................................................................................................................1 Methodology ...................................................................................................................................................2 Summary of Findings .....................................................................................................................................3 II. EXISTING HISTORIC STATUS.............................................................................................................4 National Register of Historic Places .............................................................................................................4 California Register of Historical Resources .................................................................................................4 California Historical Resource Status Codes...............................................................................................4 City of Santa Monica Designations & Surveys ............................................................................................5 III. PROPERTY DESCRIPTION ................................................................................................................7 Building Description.......................................................................................................................................7 Site Features..................................................................................................................................................13 Surrounding Neighborhood........................................................................................................................15 IV. HISTORIC CONTEXT .......................................................................................................................16 Wilshire Montana .........................................................................................................................................16 Architectural Style: Craftsman Bungalow..................................................................................................19 Builder: M. L. Fuller.......................................................................................................................................21 V. SITE HISTORY ..................................................................................................................................22 Site Development.........................................................................................................................................22 Ownership and Occupant History..............................................................................................................24 VI. EVALUATION..................................................................................................................................26 Local Regulatory Framework ......................................................................................................................26 Evaluation of Significance............................................................................................................................26 Integrity..........................................................................................................................................................28 VII. CONCLUSION & STATEMENT OF SIGNIFICANCE ........................................................................30 VIII. REFERENCES.................................................................................................................................31 IX. APPENDIX.......................................................................................................................................33 Preparer Qualifications................................................................................................................................33

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Packet Pg. 1715 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 1 July 8, 2025
I. INTRODUCTION
This Historic Resource Assessment (HRA) has been prepared at the request of the City of Santa Monica Planning & Community Development Department to evaluate the historic significance of the residence at 1125 18th Street (APN 4276-009-005) in the Green Acres Tract within the Wilshire Montana neighborhood of Santa Monica, California (Figure 1 and Figure 2). The building has remained in its original use as a single-family residence since its construction in 1923.

In April 2025, Mario Fonda-Bonardi of the Santa Monica Conservancy submitted a Structure of Merit Designation Application for 1125 18th Street. The City of Santa Monica Community Development Department is seeking additional information to determine if the property meets the criteria for listing as a Santa Monica Structure of Merit.

Figure 1. Aerial view of 1125 18th Street (outlined in red).

Source: Google Earth, 2023, edited by Page & Turnbull.

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Packet Pg. 1716 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 2 July 8, 2025
Figure 2. Parcel map, showing the subject property, shaded in red.

Source: Los Angeles County Assessor, edited by Page & Turnbull, 2025.

Methodology
This report provides an examination of the current historic status of 1125 18th Street, as well as a property description, historic context for the Wilshire Montana neighborhood, the Green Acres Tract, and a site history. The report includes an evaluation of the building’s eligibility for individual listing as a Santa Monica Structure of Merit. As the City is only seeking to determine the property’s eligibility for local listing, an evaluation of eligibility for listing in the National Register of Historic Places (National Register) and California Register of Historical Resources (California Register) is not included.

In addition to reviewing the Structure of Merit Designation Application submitted in April 2025 for 1125 18th Street, Page & Turnbull prepared this report using research collected from local repositories, including the Los Angeles County Assessor’s Office website and Los Angeles County

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Packet Pg. 1717 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 3 July 8, 2025
Public Works Land Records, as well as various online sources such as Newspapers.com, the California Digital Newspaper Collection, and Ancestry.com. Page & Turnbull consulted the Santa Monica Municipal Code, and building permit and demolition records provided by the City of Santa Monica’s Department of Planning & Community Development.

To prepare the evaluation section of this report, Page & Turnbull referred to bulletins prepared by the National Park Service, which were written as guidance for evaluation for the National Register, but have served as a foundation for professional best practices also at the local and state levels.

Relevant bulletins include National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Page & Turnbull also consulted the 2018 Santa Monica Historic Resources Inventory Update and Historic Context Statement, which provides evaluation frameworks and eligibility criteria based on contexts and themes covering Santa Monica’s history, and references national, state, and local significance criteria.

Page & Turnbull staff conducted a site visit on June 11, 2025. All photographs in the report were taken by Page & Turnbull during this site visit unless otherwise noted.

Summary of Findings
The one-story single-family residence was constructed in 1923 by local builder M. L. Fuller in the Green Acres Tract in the Wilshire Montana neighborhood. It is a modest example of a Craftsman bungalow, a type that is relatively common in the neighborhood and Santa Monica. Given its relatively simple design and the continued presence of similar properties in the area, 1125 18th Street does not represent a rare or unique example of its type. 1125 18th Street does not appear to meet any of the criteria for designation as a City of Santa Monica Structure of Merit and therefore does not appear to be eligible for this level of designation.

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Packet Pg. 1718 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 4 July 8, 2025
II. EXISTING HISTORIC STATUS
The following section examines the national, state, and local historic status currently assigned to the property at 1125 18th Street.

National Register of Historic Places
The National Register of Historic Places (National Register) is the nation’s most comprehensive inventory of historic resources. The National Register is administered by the National Park Service and includes buildings, structures, sites, objects, and districts that possess historic, architectural, engineering, archaeological, or cultural significance at the national, state, or local level.

The subject property is not listed in the National Register of Historic Places individually, or as part of a registered historic district.

California Register of Historical Resources
The California Register of Historical Resources (California Register) is an inventory of significant architectural, archaeological, and historical resources in the State of California. Resources can be listed in the California Register through a number of methods. State Historical Landmarks and National Register-listed properties are automatically listed in the California Register. Properties can also be nominated to the California Register by local governments, private organizations, or citizens.

The evaluative criteria used by the California Register for determining eligibility are closely based on those developed by the National Park Service for the National Register of Historic Places.

The subject property is not listed in the California Register of Historical Resources individually, or as part of a registered historic district.

California Historical Resource Status Codes
Properties listed or under review by the State of California Office of Historic Preservation are listed within the Built Environment Resource Directory (BERD) and are assigned a California Historical Resource Status Code (Status Code) of “1” to “7” to establish their historical significance in relation to the National Register of Historic Places (National Register) or California Register of Historical Resources (California Register).1 Properties with a Status Code of “1” or “2” are either eligible for listing in the California Register or the National Register, or are already listed in one or both of the registers. Properties assigned Status Codes of “3” or “4” appear to be eligible for listing in either 1 California State Office of Historic Preservation, Built Environment Resource Directory (BERD), Los Angeles County, updated September 2022.

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register but normally require more research to support this rating. Properties assigned a Status Code of “5” have typically been determined to be locally significant or to have contextual importance. Properties with a Status Code of “6” are not eligible for listing in either register. Finally, a Status Code of “7” means that the resource has not been evaluated for the National Register or the California Register, or needs reevaluation.

The subject property is not currently listed in the BERD database for Los Angeles County. The most recent update to the BERD database was in September 2022.

City of Santa Monica Designations & Surveys
The City of Santa Monica’s historic preservation program was established in 1976 with the adoption of the Landmarks and Historic District Ordinance. The Landmarks and Historic Districts Ordinance, Title 9, Chapter 56, (adopted June 23, 2015) of the City of Santa Monica Municipal Code (SMMC) regulates designation criteria for listing as a City-Designated Historic Resource. City-Designated Historic Resources include any existing building or structure that is designated by the City as a Landmark, Structure of Merit, or Contributing Building or Structure to a Designated Historic District.

Any improvement – that is a building, structure, place, site, work of art, landscape feature, plant life, life-form, scenic condition, or other object constituting a physical betterment of real property – may be eligible for designation as a historic resource if an application is submitted and approved by the City’s Landmarks Commission. Historic districts may also be listed if they meet the criteria listed in Chapter 19.56.100.2
1125 18th Street is not currently listed as a Santa Monica Landmark, Structure of Merit, or Contributing Building or Structure to a Historic District. A Santa Monica Structure of Merit nomination was submitted for 1125 18th Street by Mario Fonda-Bonardi of the Santa Monica Conservancy in April 2025 and is currently under staff review. 2018 City of Santa Monica Historic Resources Inventory Update Santa Monica has completed several historic resources surveys for various property types. The first comprehensive historic resources survey took place in 1983 as part of an effort to create the City of Santa Monica’s first preservation element for its General Plan. Phases II and III of the survey were completed in 1986 and 1993. Additional surveys and updates were carried out in 1994, 1997, 2002, 2004, 2006, and 2011. The most recent survey was completed in 2018 in order to update the city’s historic resources inventory and historic context statement. In this year, Architectural Resources Group and Historic Resources Group completed an update to Santa Monica’s historic resources 2 “Ordinance No. 2486CCS §§ 1, 2,” Santa Monica Municipal Code, accessed online June 6, 2025, https://ecode360.com/SA5008.

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inventory and historic context statement. The project covered the existing boundaries of the City of Santa Monica.

As part of the 2018 survey, 1125 18th Street was evaluated and found to be potentially eligible for listing as a Santa Monica Structure of Merit. The findings of the 2018 HRI update are quoted below:
1125 18th Street appears eligible for local listing as a Santa Monica Structure of Merit. The property conveys patterns of residential development that shaped the Wilshire Montana/Mid City neighborhoods of Santa Monica in the early decades of the twentieth century. Constructed in 1923, it is an example of a residential building from this formative period of neighborhood growth. The building does not rise to the level of significance needed to be eligible as a Landmark, but it appears eligible as a Structure of Merit.

Based on this evaluation, a status code of 5S3* was recommended for 1125 18th Street. Within Santa Monica, this code indicates that a property appears to be eligible for designation as a Structure of Merit only, not as a Landmark.3 This is not a formal California Historical Resource Status Code; the status code 5S3 is used statewide without a qualifying asterisk, applied to properties which appear “to be individually eligible for local listing or designation through survey evaluation. 4 3 Architectural Resources Group and Historic Resources Group, “Appendix B: Individual Resources,” City of Santa Monica Citywide Historic Resources Inventory, 2018; “City of Santa Monica Citywide Historic Resources Inventory Update Survey Report” (Los Angeles: Prepared for the City of Santa Monica, August 9, 2019), 33. 4 “California Historical Resource Status Codes,” 2003, accessed June 6, 2025, https://ohp.parks.ca.gov/pages/1069/files/chrstatus%20codes.pdf.

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III. PROPERTY DESCRIPTION
Building Description
The subject property is located on a 160-by-50-foot rectangular lot on the east side of 18th Street. 5 The building on the property is a 952 square foot rectangular one-story, single-family wood-frame residence with a low pitched front gable roof with an intersecting side gable projection (Figure 3).

The roof is clad with asphalt shingles and features wide overhanging eaves with exposed rafter tails and triangular cross-hatched wood vents at the gable ends. The building is clad in painted narrow wood clapboard. Typical windows are wood double-hung windows with flat wood surrounds located on all façades. The upper sash of the windows on the primary (west) façade feature simplified prairie-style muntins.

Figure 3. 1125 18th Street, looking northeast from 18th Street. 5 The building is oriented with the 18th Street façade facing southwest. However, for the purposes of this report, the 18th Street façade will be referred to as the “west façade,” and so on.

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Exterior
Primary (West) Façade
The primary (west) façade is set back from the property line and faces 18th Street (Figure 4). The left (north) portion of the façade contains a pair of typical windows (Figure 5). The right (south) projecting section contains a typical window on the north facing wall and a grouping of four typical windows on the west facing wall (Figure 6). A wood bracket extends from the peak of the front gable to the slope of the projecting side gable roof.

Figure 4. Primary (west) façade of 1125 18th Street, looking east.

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Figure 5. Overview of primary (west) facade, looking
east.

Figure 6. Row of windows, looking northeast.

South Façade
The south façade faces a driveway between the subject property and an adjacent property at 1127 18th Street (Figure 7). The building’s entrance is located at the westernmost edge of the south façade beneath a low-pitched gable overhang with large wood brackets (Figure 8). The door is a fully glazed wood door with simplified prairie-style muntins, accessed by three curved concrete steps leading to a small wood deck and ramp, with the ramp extending parallel to the south façade.

Fenestration consists of, from left (west) to right (east) a typical window, two pairs of smaller typical windows, and two typical windows. (Figure 9).

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Figure 7. South façade, looking north.

Figure 8. Small entry porch, looking northwest. Figure 9. Overview of south façade windows, looking northwest.

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East Façade
The rear (east) façade faces a small backyard and features a projecting section with a low-pitched gable roof (Figure 10). The projecting section features a partially glazed wood rear entry door on the east facing wall and a small typical window on the north facing wall (Figure 11). To the right (north) of the projecting section below the primary gable is a typical window (Figure 12).

Figure 10. Rear (east) façade, looking south.

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Figure 11. Rear entry, looking southwest. Figure 12. Rear façade with projecting section, looking southwest.

North Façade
The west façade faces a narrow walkway between the subject property and an adjacent property at 1117 18th Street. Fenestration consists of, from left (east) to right (west), a typical window, a replacement vinyl slider with an altered wood surround, and a typical window (Figure 13).

Figure 13. Overview of north façade, looking south.

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Site Features
The subject property is set back from the street behind a front yard with a lawn, a mature tree, and landscape plantings along the primary façade (Figure 14). A concrete paved ribbon driveway with grass down the center runs along the south side of the parcel and terminates at the rear wood fence. The small backyard adjacent to the front building includes a small lawn and gravel separated by brick pavers (Figure 15).

Figure 14. Front yard, looking north. Figure 15. Backyard of front building, looking north.

The rear half of the parcel contains a secondary building and is separated from the primary building by a wood fence. The secondary building is a rectangular one-story, single-family wood-frame residence with a moderately-pitched cross-gable roof (Figure 16). The roof is clad with asphalt shingles and features overhanging eaves. The building is clad in painted narrow wood clapboard.

Typical windows are multi-lite vinyl hung windows with wood surrounds and located on all façades.

The primary (west) façade windows are flanked by wood shutters with decorative diamond cutouts.

The front yard of the secondary building includes a lawn and mature landscaping (Figure 17). A concrete path runs along the south façade to a small woodshed and rear alley (Figure 18).

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Figure 16. Secondary rear building, looking northeast.

Figure 17. Front yard of rear building, looking
northwest.

Figure 18. Shed adjacent to rear building, looking
east.

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Surrounding Neighborhood
The subject property is located in a residential neighborhood one block from Wilshire Boulevard, a major east-west commercial thoroughfare that runs the length of the city. The parcels surrounding the subject property are characterized by a mix of multi-family properties and single-family residences ranging from the early 20th century to the present (Figure 19 through Figure 22).

Figure 19. Single-family residence at 1133 18th Street, looking northeast.

Figure 20. Property at 1127 18th Street, looking north.

Figure 21. Multi-family housing on the east side of
18th Street, looking north.

Figure 22. Apartment complex on the south side of
18th Street, looking west.

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IV. HISTORIC CONTEXT
Historic context related to the residential development of Santa Monica can be found in the Santa Monica Historic Resources Inventory Update Survey Report Appendix A. 6 Wilshire Montana
The Wilshire Montana neighborhood spans the northern half of Santa Monica’s original 1875 township. Bounded by Montana Avenue on the north, 22nd Street on the east, Wilshire Boulevard on the south, and Santa Monica State Beach on the west, the area originally contained large parcels that supported some of the city’s earliest prominent residences. However, broader residential development was slow until the expansion of regional transportation networks in the early 20th century.7
The extension of the Pacific Electric Railway to Santa Monica in 1905 marked a period of increased development in the neighborhood. With reliable access to downtown Los Angeles and surrounding areas, Wilshire Montana became increasingly attractive to prospective homeowners and real estate developers. By the 1920s, the area was in the midst of a building boom. Residential construction surged, incorporating popular architectural styles of the time such as Craftsman, Spanish Colonial Revival, and Tudor Revival. These styles were often employed in modest single-family residences and low-density multi-family structures like duplexes and bungalow courts.8 A major shift occurred in the 1930s and continued into the post-World War II era as zoning and economic pressures encouraged denser development. Multi-family housing began to dominate, particularly in the form of courtyard apartments. Ocean Avenue, which forms the western edge of the neighborhood, witnessed the rise of high-rise apartment towers in the mid- to late-20th century, capitalizing on panoramic views of the Pacific Ocean. Commercial activity developed concurrently along the major east-west corridors of Wilshire Boulevard and Montana Avenue. Wilshire became a primary vehicular thoroughfare lined with mixed-use and commercial buildings, while Montana Avenue retained a lower-scale, pedestrian-oriented retail environment that remains a distinctive feature of the neighborhood. Despite its predominantly multi-family character today, portions of Wilshire Montana, particularly near 21st and 22nd Streets, retain concentrations of single-family homes. The neighborhood also includes several familiar institutions, including churches, public 6 Architectural Resources Group and Historic Resources Group, “Appendix A: Historic Context Statement,” City of Santa Monica Citywide Historic Resources Inventory, August 9, 2018, 29-38. 7 Architectural Resources Group and Historic Resources Group, “Appendix A: Historic Context Statement,” City of Santa Monica Citywide Historic Resources Inventory, 2018, 21-22. 8 Architectural Resources Group and Historic Resources Group, “Appendix A: Historic Context Statement,” City of Santa Monica Citywide Historic Resources Inventory, 2018, 21-22.

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schools, and community parks, which reflect the area's long-standing residential use and civic development.9
Green Acres
Situated within the eastern portion of the Wilshire Montana neighborhood, the Green Acres Tract was subdivided in 1906 during an early wave of suburban real estate speculation. Bounded by Wilshire Boulevard to the south, Washington Avenue to the north, 17th Street to the west, and 21st Street to the east, the tract was marketed by developers W.S. Vawter, T.H. Dudley, and J.J. Davis as an enclave for “fine residences.” These individuals were active in shaping early Santa Monica, with Vawter serving as a local realtor and Davis holding political office in the early 20th century.10 Despite this early promotion, development within Green Acres progressed slowly. By 1918, Sanborn fire insurance maps show that most lots remained vacant, with only a handful of dwellings constructed primarily along Wilshire Boulevard. The slow initial growth is attributable to a combination of factors, including the economic fluctuations of the 1910s and the tract’s relative distance from Santa Monica’s commercial core at the time. It was not until the real estate boom of the 1920s that Green Acres began to experience substantial development. Large lots were frequently subdivided to accommodate bungalow courts, small single-family residences, and increasingly, low-rise apartment buildings. These developments echoed broader trends in Santa Monica during the interwar period, when increasing population and changing lifestyle preferences made multi-family housing more desirable (Figure 23 and Figure 24). 11 9 Architectural Resources Group and Historic Resources Group, “Appendix A: Historic Context Statement,” City of Santa Monica Citywide Historic Resources Inventory, 2018, 21-22. 10 Architectural Resources Group and Historic Resources Group, “Appendix A: Historic Context Statement,” City of Santa Monica Citywide Historic Resources Inventory, 2018, 45-46. 11 Architectural Resources Group and Historic Resources Group, “Appendix A: Historic Context Statement,” City of Santa Monica Citywide Historic Resources Inventory, 2018, 45-46.

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Figure 23. 1928 aerial of the Green Acres Tract outlined in red showing the beginning stages of major development. 1125 18th Street indicated by yellow arrow. Source: UCSB Library, Flight C_300, Frame J-257.

Edited by Page & Turnbull.

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Figure 24. 1938 aerial of the Green Acres Tract outlined in red showing increased development. 1125 18th Street indicated by yellow arrow. Source: UCSB Library, Flight AJX_1938, Frame 26-78. Edited by Page & Turnbull.

Architectural Style: Craftsman Bungalow
The Craftsman style evolved from the English Arts and Crafts Movement and later, the work of innovative American architects working in the Midwest and California, in particular Frank Lloyd Wright and Greene & Greene. The style was utilized predominantly in residential properties and was dominant in many growing American neighborhoods from the 1900s to the 1930s. The Craftsman magazine, published in the United States from 1901 to 1917, helped to disseminate ideas associated with the style in North America, such as anti-industrialism and emphasis on handcrafted products.

Popularized California during the first decade of the 20th century as the Southern California work of Greene & Greene received critical acclaim, variants of the Craftsman style embraced influences from Japanese architecture, Swiss chalets, and the indoor/outdoor traditions of the Spanish and Mexican homes of the region.

Elaborate and unique homes of the wealthy, such as the Gamble House in Pasadena, represent high style examples while rows of more modest bungalows are found throughout California (Figure 25).

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Craftsman bungalows are typically characterized by low-pitched gabled roofs with wide, unenclosed eave overhangs; decorative beams or braces; exposed rafter tails; tapered square columns or pedestals; and extending porch elements. Small-scale, wood-framed Craftsman bungalows could be constructed easily and affordably and were often available as kit houses, or built from plans in pattern books, through the 1910s. Neighborhoods of Craftsman houses developed into the 1920s as streetcar suburbs (Figure 26)
Figure 25: The Gamble House designed by Greene
& Greene in Pasadena is a high-style example of
the Craftsman style. Source: Page & Turnbull,
2011.

Figure 26: The 1908 “Ye Planry” is an example of a
Craftsman bungalow kit house. Source: First
Edition Catalog of Bungalow Plans, Los Angeles,
1908-1913 via Antiquehome.org.

Based on a review of the 2018 Historic Context Statement survey results, 178 properties in Santa Monica were identified by the survey as “Craftsman” style. Of these, 30 individually significant properties were identified in the Wilshire Montana neighborhood, 18 as potential Landmarks and 12 as potential Structures of Merit. Like 1125 18th Street, all 30 properties were identified as being significant, at least in part, for conveying the “patterns of residential development” in the Wilshire Montana area in the “early decades of the twentieth century”. 12 Twenty of the Craftsman style
properties identified as significant in the Wilshire Montana neighborhood represent relatively modest bungalow-style homes, which display a variety of different Craftsman design elements and types, as well as levels of integrity (Figure 27 through Figure 30). 12 Architectural Resources Group and Historic Resources Group, “Appendix B: Individual Resources,” City of Santa Monica Citywide Historic Resources Inventory, 2018.

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Figure 27. 847 10th Street. Built 1919, identified by the 2018 survey as eligible for designation as a Landmark.

Source: Google Maps.

Figure 28. 918 19th Street. Built in 1924, identified by the 2018 survey as eligible for designation as a
Structure of Merit. Source: Google Maps.

Figure 29. 811 5th Street. Built in 1912, identified by the 2018 survey as eligible for designation as a Structure
of Merit Source: Google Maps.

Figure 30. 908 California Avenue. Built in 1922,
identified by the 2018 survey as eligible for designation as a Landmark. Source: Google Maps.

Builder: M. L. Fuller
M. L. Fuller is listed on the original building permit dated March 3, 1923; however, little is known about his life or professional work. City directories from that year list Fuller as residing at 1253 18th Street, just one block south of the subject property. During this period, many Craftsman bungalows in Los Angeles were constructed using pattern books that supplied standardized plans and elevations, and as a result, designs were often attributed to builders rather than formally trained architects. Developers and contractors frequently hired young architects who had not yet established their own practices or relied on builders with no formal architectural education. Such practices likely contributed to the lack of documentation surrounding Fuller’s career.13 13 U.S., City Directories, 1822-1995 from Ancestry.com; City of Los Angeles Office of Historic Resources, “Sub-Theme: Arts and Crafts Neighborhoods, 1895–1930,” SurveyLA Citywide Historic Context Statement, June 2016.

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V. SITE HISTORY
Site Development
The building permit for the residence at 1125 18th Street, filed March 1923, lists the builder as M. L.

Fuller and describes a one-story building with a composition roof, as was constructed. The earliest known illustration of the subject property comes from the fire insurance maps published by the Sanborn Map Company for Santa Monica in 1950 showing a one-story, single-family residence with a roughly rectangular footprint with a projecting bay and a detached garage (Figure 31). By the 1963 Sanborn map, the secondary residence appears in the rear at the east end of the parcel (Figure 32).

Figure 31. 1950 Sanborn Map Company fire insurance map of Santa Monica, Sheet 3. The subject property is outlined in red. Source: San Francisco Public Library, Fire Insurance Maps Online. Edited by Page & Turnbull.

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Figure 32. 1963 Sanborn Map Company fire insurance map of Santa Monica, Sheet 3. The subject property is outlined in red. Source: San Francisco Public Library, Fire Insurance Maps Online. Edited by Page & Turnbull.

CONSTRUCTION CHRONOLOGY
The following table provides a timeline of documented construction activity at 1125 18th Street beginning in 1923, based on building permit applications on file with the City of Santa Monica. 14 Cancelled and expired permits are not included. Mechanical, electrical, and plumbing permits are not included. Additionally, permits related to the rear residence are not included.

TABLE 1. PERMIT HISTORY FOR 1958 20TH STREET.

Date Filed Permit
App. #
Owner Builder Work
03/04/1923 B1208 M.L. Fuller M.L. Fuller New construction permit at 1125 18th Street for a one-story residence
and garage.
05/03/1949 B5828 Robert T.

Jennings
Federal Termite
Control Service
(contractor)
Unknown work completed.
03/01/1994 EQR0405 Robert F.

Jennings
Grand Construction
Co.

Jack house up, repair foundation, bolt
house to foundation.

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The property has had very few alterations over the years. Alterations that are not reflected in the above permit record include the addition of a ramp alongside the south façade, replacing one window on the north façade, demolishing the detached garage, and replacing the driveway.

Ownership and Occupant History
The following table provides a summary of the ownership and occupancy history of 1125 18th Street, beginning in 1925, compiled from assessor records available through building permit applications from Santa Monica Permit Document Archive, historic newspaper articles, city directories, and other public records available through Ancestry.com.

TABLE 2. OCCUPANT HISTORY FOR 1125 18TH STREET.

Owners and Occupants (Presumed owners in bold)
Dates Occupant(s) Occupation
1925-1926 Samuel Raymond Salesman
Anna Raymond Unknown
1927 Russ Clover Owner of service station
1928 Vacant N/A
1929-1930
Gilbert Edwards Automotive salesman
Anna Edwards None
Bruce Edwards (son) None
Jack Edwards (son) None
Wilma Edwards (daughter) None
1930-1932
Douglas Ross Leat Carpenter
Lily Leat None
Henry Leat None
1933 Vacant N/A
1934-1935 J. W. Engler Unknown
1936 Frank Mulvany Plumber
Vesta Mulvany Unknown
1937-1939 No information found N/A
1940 Robert Maggetti Meter reader for gas company
Teresa Maggetti None
1941-2021
Robert T. Jennings (occupant 1950-
1966) Egg candler at Edgemar Farms
Agnes Jennings (first wife, occupant
1950-1959) None
Joule Jennings (second wife,
occupant 1963-1966) Unknown
Robert F. Jennings (son of Agnes,
occupant 1950-2009) Manufacturer of aircraft parts
Hazel Jennings (daughter-in-law,
occupant 1950-2010) None
Karl Jennings (grandson) Unknown

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Owners and Occupants (Presumed owners in bold)
Harry Balaz (occupant 2002-2021) Unknown
2021-present Joseph Naim Surgeon
Harry Balaz (occupant 2021-present) Unknown
Select Owners and Occupant Biographies
The subject property appears to have changed ownership and occupancy frequently since its construction in 1923. The longest-term residents at the subject property were the Jennings family, who owned 1125 18th Street for 80 years between 1941 and 2021.

Jennings Family (owners and occupants, 1941-2021)
The subject property appears to have been continuously owned and occupied by members of the Jennings family from approximately 1941 until 2021. Robert T. Jennings (1983-1966) was born in Henrietta, Texas and moved to Washington State in the early twentieth 20th. In 1919, Robert T.

Jennings married Agnes Miller (1893-1959) and together had one son, Robert F. Jennings (1920-2009) the following year. By 1935, the Jennings relocated to Los Angeles where Robert T. Jennings began working as an operator for an ice-making plant. In 1959, Agnes passed away. In 1963, Robert T. married his second wife, Joule Ferguson, however he passed away within three years of their nuptials. Their son, Robert F. Jennings, continued to own and occupy the subject property with his wife, Hazel, and their four children, Karl, Bob, Steve, and George. Research did not provide additional information about their lives. Following the passing of Robert F. and Hazel in 2009 and 2010 respectively, Karl Jennings inherited the property until he eventually sold it in 2021.15 15 U.S. Federal Census 1900-1950 through Ancestry.com; PropertyShark, Los Angeles County, California, Jennings Family Trust to Karl Jennings, August 8, 2010, Office of the County Recorder, Los Angeles, CA.

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VI. EVALUATION
This HRA only evaluates the primary residence at 1125 18th Street for local designation eligibility as a Structure of Merit. No evaluation for City of Santa Monica Landmark, California Register, or National Register eligibility is provided.

Local Regulatory Framework
Chapter 9.56 of the Santa Monica Municipal Code (SMMC), commonly known as the Santa Monica Landmark and Historic District Ordinance, identifies the criteria under which a property or collection of properties may be designated locally as a historic resource. Properties may be designated as a Landmark, Structure of Merit, or Contributing Building or Structure to a Historic District by the City’s Landmarks Commission.

City of Santa Monica Structure of Merit
According to § 9.56.080 of the City of Santa Monica’s Landmark and Historic District Ordinance, an improvement may be designated a Structure of Merit if the Landmarks Commission determines that it merits official recognition because it has one of the following characteristics:

A. The structure has been identified in the City’s Historic Resources Inventory.

B. The structure is a minimum of 50 years of age and meets one of the following criteria:

1.The structure is a unique or rare example of an architectural design, detail or historical type.

2.The structure is representative of a style in the City that is no longer prevalent.

3.The structure contributes to a potential Historic District Evaluation of Significance

CITY OF SANTA MONICA STRUCTURE OF MERIT
SMMC 9.56.080(a). The structure has been identified in the City’s Historic Resources Inventory.

As the subject property is identified in the City of Santa Monica’s 2018 Historic Resources Inventory update as a potentially eligible resource for local listing, it technically meets the wording of this criterion. However, it is Page & Turnbull’s opinion that identification as a potential resource in Santa Monica’s Historic Resources Inventory does not alone provide sufficient basis for the individual designation of a property as a Structure of Merit. This criterion recognizes the findings of previous evaluations conducted in support of the inventory and update. It appears to presume that if a property is “identified” in the inventory, it has already been evaluated according to and found significant under at least one of the categories of SMMC 9.56.1080(b) (see below). Therefore, while

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Packet Pg. 1741 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 27 July 8, 2025
the property may meet the text of the criterion as written in SMMC § 9.56.080(a), it does not appear to meet the intent of the criterion.

SMMC 9.56.080(b). The structure is a minimum of 50 years of age and meets one of the following criteria:

The subject property was built in 1923 and, therefore, satisfies the 50-year age criterion.

SMMC 9.56.080(b)(1). The structure is a unique or rare example of an architectural design, detail or historical type.
1125 18th Street is a relatively intact example of a modest Craftsman bungalow built during Santa Monica’s real estate boom of the 1920s. The Craftsman bungalow was a common single-family residential style in the Wilshire Montana neighborhood at the time, as the neighborhood was being developed in response to improved transit access. These smallscale, wood-framed homes were popular due to their ease and affordability of construction.

The building possesses some key characteristics of this housing type, including its one-story height, low-pitched gable roof with overhanging eaves, wood siding, and multi-lite wood frame windows. However, it lacks more distinctive architectural elements typical of Craftsman homes, such as prominent front porches with tapered stone, brick, or stucco columns or decorative beams. Rather than being a unique interpretation of Craftsman style, the idiosyncratic entrance at 1125 18th Street, which consists of a relatively small front porch facing the driveway rather than the public right of way, is a departure from the wide front entry porches which define the character of Craftsman bungalows. As such, 1125 18th Street represents a restrained interpretation, or partial application of the Craftsman style rather than a particularly distinguished or unique example.

The extant Craftsman bungalows and other single-family residences built in the first three decades of the 20th century in the Wilshire Montana neighborhood are not remnants of originally homogenous single-family neighborhoods. Rather, residences like 1125 18th Street represent a middle stage of neighborhood development. Though established in the late 19th and early 20th century, development in these areas progressed slowly and in a patchy fashion until construction of single-family homes accelerated during the 1920s. During and after this period of growth, low-scale apartment complexes and bungalow courts in various Revival styles were constructed alongside single family homes. This pattern created the neighborhood’s varied residential character, an architectural mix which reflects decades-long development patterns in the Green Acres Tract and Wilshire Montana neighborhood.

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Packet Pg. 1742 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 28 July 8, 2025
According to the 2018 Historic Resources Inventory update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to 1125 18th Street. Although some have been lost to redevelopment and others altered to the degree that they have lost integrity, the modest Craftsman bungalow remains a relatively common building type within the neighborhood. Given its modest design and the continued presence of similar properties in the area, 1125 18th Street does not appear to represent a rare or unique example of its type. Therefore, the subject property does not appear to be eligible for listing as a Structure of Merit under this criterion.

SMMC 9.56.080(b)(2). The structure is representative of a style in the City that is no longer prevalent.
1125 18th Street is an example of a modest Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first three decades of the 20th century. As discussed above, 1125 18th Street is one of many remaining Craftsman residences in the Wilshire Montana neighborhood and the City of Santa Monica as a whole. Therefore, the subject property does not appear to be eligible for listing as a Structure of Merit under this criterion.

SMMC 9.56.080(b)(3). The structure contributes to a potential Historic District.

The subject property has not been identified as a contributor to a potential Historic District.

Therefore, it does appear to be eligible for listing as a Structure of Merit under this criterion.

Integrity
To qualify for listing in any local, state, or national historic register, a property or landscape must possess significance under at least one evaluative criterion as described above and retain integrity.

Integrity is defined by the California Office of Historic Preservation as “the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance,” or more simply defined by the National Park Service as “the ability of a property to convey its significance.”16
Page & Turnbull uses established integrity standards outlined by the National Register Bulletin 15:

How to Apply the National Register Criteria for Evaluation. Seven variables, or aspects, which define 16 California Office of Historic Preservation, Technical Assistance Series No. 7: How to Nominate a Resource to the California Register of Historical Resources (Sacramento: California Office of State Publishing, September 4, 2001), 11; and National Park Service, National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation (Washington, D.C.: U.S.

Department of the Interior, National Park Service, 1995), 44.

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Packet Pg. 1743 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 29 July 8, 2025
integrity are used to evaluate a resource’s integrity—location, setting, design, materials, workmanship, feeling, and association.

As 1125 18th Street has not been found eligible for designation as a Structure of Merit under any criterion and thus does not have a period of significance or character-defining features which convey significance, this integrity assessment will be based solely on how closely its current appearance reflects its assumed condition at the time of its construction in 1923. The seven aspects that define integrity are listed below, with discussion relative to the property at 1125 18th Street following each definition.

Location is the place where the historic property was constructed or the place where the historic event occurred.

Discussion: 1125 18th Street retains integrity of location. The subject building has remained situated at its location of original construction since 1923.

Setting addresses the physical environment of the historic property inclusive of the landscape and spatial relationships of the building(s).

Discussion: 1125 18th Street partially retains integrity of setting. The building was constructed during a period of residential growth in the Wilshire Montana neighborhood. Although the surrounding neighborhood has evolved over time, and many buildings that were constructed during the same period as the subject property have been demolished, the subject property’s immediate setting generally retains the character of a residential neighborhood of modest single and multi-family residences.

Design is the combination of elements that create the form, plan, space, structure, and style of the property.

Discussion: 1125 18th Street retains integrity of design. The building appears to have had very few exterior alterations, and most original architectural features remain extant, including the overall form and massing, low pitched front gable roof with an intersecting side gable projection, wood clapboard cladding, and wood windows with simplified prairie-style muntins.

Materials refer to the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form the historic property.

Discussion: 1125 18th Street retains integrity of materials. The exterior wood clapboard cladding and wood window and door frames are all intact and appear to be original. Most windows appear to be original on all façades. Minor exterior alterations include replacing one window on the north façade, repairing the foundation, and replacing roofing.

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Packet Pg. 1744 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 30 July 8, 2025
Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.

Discussion: 1125 18th Street retains integrity of workmanship. As previously stated, the building has had very few exterior alterations, and the workmanship of the architectural features and materials remain extant to express the typical characteristics of a wood-frame residential building constructed in the 1920s.

Feeling is the property’s expression of the aesthetic or historic sense of a particular period of time.

Discussion: 1125 18th Street retains integrity of feeling. The building continues to express the aesthetic and historic sense of a modest bungalow residence with some Craftsman features, constructed in the 1920s.

Association is the direct link between an important historic event or person and the historic property.

Discussion: While 1125 18th Street is not associated with significant patterns or events in history, and is not a significant example of an architectural type, style, or design professional, the building continues to readily convey its identity as a modest bungalow with some Craftsman features, constructed as the Wilshire Montana neighborhood was increasing in density through the early to mid-twentieth century.

Overall, 1125 18th Street retains all seven aspects of integrity relative to its ability to convey its date of construction.

VII. CONCLUSION & STATEMENT OF SIGNIFICANCE
Page & Turnbull conducted a site visit and historic research to inform evaluation of the property at 1125 18th Street according to the criteria for listing as a City of Santa Monica Structure of Merit. The one-story single-family residence was constructed in 1923 by local builder M. L. Fuller in the Green Acres Tract in the Wilshire Montana neighborhood. It is a modest example of a Craftsman bungalow, a type which remains relatively common within the neighborhood and across the city as a whole. 1125 18th Street does not represent a rare or unique example of its type and is not an example of a no-longer-prevalent style. Based on research and analysis, Page & Turnbull finds that 1125 18th Street does not meet any of the criteria for designation as a City of Santa Monica Structure of Merit.

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Packet Pg. 1745 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 31 July 8, 2025
VIII. REFERENCES
Published Works & Reports
Architectural Resources Group and Historic Resources Group. “City of Santa Monica Historic Resources Inventory Update Survey Report,” 2018, with appendices:

Appendix A: Historic Context Statement, March 2018.

Appendix B: Individual Resources Property Sheets, 2018.

Appendix B: District Primary Records, 2018.

California Office of Historic Preservation. Technical Assistance Bulletin No. 7: How to Nominate a Resource to the California Register of Historical Resources. Sacramento: California Office of State Publishing, September 4, 2001.

California Office of Historic Preservation. Technical Assistance Bulletin No. 8: User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory. Sacramento:

California Office of State Publishing. November 2004.

City of Los Angeles Office of Historic Resources. “Sub-Theme: Arts and Crafts Neighborhoods, 1895- 1930.” SurveyLA Citywide Historic Context Statement. June 2016.

Fonda-Bonardi, Mario. “Structure of Merit Designation Application, 1125 18th Street.” Submitted to City of Santa Monica, April 2025.

National Park Service. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Washington, D.C.: U.S. Department of the Interior, National Park Service, 1995.

National Park Service. National Register Bulletin 32: Guidelines for Evaluating and Documenting Properties Associated with Significant Persons. Washington, D.C.: U.S. Department of the Interior, National Park Service, n.d.

Public & Archival Records
Ancestry.com
California State Office of Historic Preservation, Built Environment Resource Directory (BERD), Los Angeles County, updated September 2022.

Los Angeles County Public Works Land Records Information.

Sanborn Fire Insurance Maps. Accessed through San Francisco Public Library online.

Santa Monica Community Development. Permit records.

Santa Monica Municipal Code of Ordinances. Chapter 9.56 Landmarks and Historic Districts.

Accessed online June 6, 2025, https://ecode360.com/42751383.

Santa Monica Public Library Image Archive.

University of California, Santa Barbara Library Air Photo Collection.

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Packet Pg. 1746 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 32 July 8, 2025
Internet Sources
California Office of Historic Preservation, “California Historical Resource Status Codes,” 2003.

Accessed online June 6, 2025,
https://ohp.parks.ca.gov/pages/1069/files/chrstatus%20codes.pdf.

PropertyShark, Los Angeles County, California. Jennings Family Trust to Karl Jennings, August 8, 2010. Office of the County Recorder, Los Angeles, CA.

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Packet Pg. 1747 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Historic Resource Assessment (HRA) 1125 18th Street
[19363O] Santa Monica, CA
PAGE & TURNBULL 33 July 8, 2025
IX. APPENDIX
Preparer Qualifications
This Historic Resource Assessment was prepared by the Los Angeles office of Page & Turnbull, an over 50-year-old preservation architecture and planning consultant. Page & Turnbull is on the City of Santa Monica’s historic preservation professional consultant list. Page & Turnbull staff responsible for this report include Christina Dikas, Principal-in-charge; Stacy Kozakavich, Senior Cultural Resources Planner and project manager; and Amanda Commins, Cultural Resources Planner and primary author. All staff members meet the Secretary of the Interior’s Professional Qualification Standards for Historic Architectural History (36 CFR Part 61).

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Packet Pg. 1748 Attachment: HRA 2025-07-08_1125 18th Street1 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 FINDINGS AND DETERMINATION

OF THE LANDMARKS COMMISSION

OF THE CITY OF SANTA MONICA IN THE MATTER OF

THE DESIGNATION OF A STRUCTURE OF MERIT
DESIGNATION OF RESIDENTIAL 25ENT-0069

STRUCTURE LOCATED AT
1125 18th Street

AS A STRUCTURE OF MERIT
SECTION I. The Santa Monica Conservancy filed a Structure of Merit Nomination application with the City of Santa Monica (City) on April 29, 2025. The Landmarks Commission, having held a Public Hearing on July 14, 2025 hereby finds that the residential front structure meets one or more of the criteria for designation as a Structure of Merit as enumerated in SMMC 9.56.080 and designates the front residential structure as a Structure of Merit based on the following findings:

Criterion A. The structure has been identified in the City’s Historic Resources Inventory as eligible for Structure of Merit designation.

Criterion (B)(1). The structure is a minimum of 50 years of age and …The structure is a unique or rare example of an architectural design, detail or historical type.

The subject building was constructed in 1923 and therefore is more than 50 years of age. 1125 18th Street is a relatively intact example of a modest Craftsman bungalow built during Santa Monica’s real estate boom of the 1920s. The Craftsman bungalow was a common single-family residential style in the Wilshire Montana neighborhood at the time the neighborhood was being developed in response to improved transit access. These small- scale, wood-framed homes were popular due to their ease and affordability of construction. The building possesses some key characteristics of this housing type, including its one-story height, low-pitched gable roof with overhanging eaves, visible rafter tails, angular brackets supporting the entry door gable, wood siding, and multi-lite wood frame windows.

The extant Craftsman bungalows and other single-family residences built in the first three decades of the 20th century in the Wilshire Montana neighborhood are no longer prevalent thus represent a picture into the past of a homogenous single-family neighborhood located within the Wilshire Montana area, and the Green Acres Tract specifically. During and after Santa Monica’s period of growth in the 1920’s, low-scale apartment complexes and bungalow courts in various Revival styles were constructed alongside single family homes. This pattern created the neighborhood’s varied residential character, an architectural mix which reflects decades-long development patterns in the Green Acres Tract and Wilshire Montana neighborhood.

Docusign Envelope ID: 4A28445C-1FA8-4C5D-A847-8C015366AF61

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Packet Pg. 1749 Attachment: Signed STOA_25ENT-0069_(1125_18th (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 The Craftsman bungalow remains a relatively uncommon building type within the neighborhood, specifically the Green Acres Tract of the Wilshire Montana neighborhood. 1125 18th Street, a small modest, vernacular Craftsman style bungalow appears to represent a rare or unique example of its type within this area of Santa Monica.

This vernacular Craftsman bungalow represents a unique and rare variation of the typical Craftsman bungalow architecture. As a late variant constructed in 1923, features such as a bank of windows on the façade, a reduced porch and entry door on a side elevation and asymmetrical window muntins break away from the classic design of Craftsman bungalows.

Criterion (B)(2). The structure is representative of a style in the City that is no longer prevalent.
1125 18th Street is an example of a modest vernacular Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first two decades of the 20th century. 1125 18th Street is single-family one-story Craftsman home representing a style that is no longer prevalent in the Wilshire Montana neighborhood, specifically the Green Acres Tract.

SECTION II. The character-defining features of the primary structure include the following:

Exterior Features, Materials and Craftsmanship
• _Craftsman Vernacular
• _Horizontal wood clapboard siding
• _Exposed rafter tails and bracketed side porch
• _Low-pitched front gable roof with intersecting side gable projection • _Series of double hung windows (west) façade featuring prairie-style muntins and windows framed with wide board surrounds
• _Primary south elevation with side entrance
SECTION lll. The designation includes the main residential structure and excludes all other units and accessory structures located behind the main structure.

SECTION IV. The designation is made in compliance with the California Environmental Quality Act (CEQA), including an exemption under CEQA Guideline 15061(b)(3) (Common Sense Exemption).

SECTION V. I hereby certify that the above Findings and Determination accurately reflect the final determination of the Landmarks Commission of the City of Santa Monica on July 14, 2025 as determined by the following vote:

AYES: Genser, Sloan, Hillbrand, Chair Green
NAYES: O’Connor, Payton
Docusign Envelope ID: 4A28445C-1FA8-4C5D-A847-8C015366AF61

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Packet Pg. 1750 Attachment: Signed STOA_25ENT-0069_(1125_18th (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 ABSTAIN: None
ABSENT: Summers
Each and all of the findings and determinations are based on the competent and substantial evidence, both oral and written, contained in the entire record relating to the decision. All summaries of information contained herein or in the findings are based on the substantial evidence in the record. The absence of any particular fact from any such summary is not an indication that a particular finding is not based in part on that fact.

NOTICE
If this is a final decision not subject to further appeal under the Landmark and Historic District Ordinance of the City of Santa Monica, Santa Monica Municipal Code Chapter

9.56, the time within which judicial review of this decision must be sought is governed by Code of Civil Procedure Section 1094.6, which provision has been adopted by the City pursuant to Municipal Code Section 1.16.010.

Respectfully Submitted
October 13, 2025
Amy Green, Chair
Attest:

Stephanie Reich, AIA, LEED AP
Landmarks Commission Secretary
Docusign Envelope ID: 4A28445C-1FA8-4C5D-A847-8C015366AF61

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Packet Pg. 1751 Attachment: Signed STOA_25ENT-0069_(1125_18th (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

NOTICE OF A PUBLIC HEARING

BEFORE THE SANTA MONICA CITY COUNCIL
SUBJECT: 25ENT-0135 (Structure of Merit Designation Appeal) 1125 18th Street
APPELLANT: Pam O’Connor
PROPERTY OWNER: Houshmand Joseph Naim
A public hearing will be held by the City Council to consider the following request:

Appeal of Landmarks Commission Designation 25ENT-0069 of the front building located at 1125 18th Street as a Structure of Merit. Consideration of compliance with the California Environmental Quality Act (CEQA), including an exemption under CEQA Guideline 15061(b)(3) (Common Sense Exemption). At the time of the public hearing, the City Council will also be considering compliance with the California Environmental Quality Act.

DATE/TIME: TUESDAY, NOVEMBER 18, 2025, AT 5:30 PM
LOCATION: City Council Chamber, Second Floor, Santa Monica City Hall, 1685 Main Street, Santa Monica, California
HOW TO COMMENT:

The City of Santa Monica encourages public comment. Members of the public unable to attend a meeting but wishing to comment on an item(s) listed on the agenda may submit written comments prior to the public hearing via email to [email protected] or via mail to City Clerk, 1685 Main Street, Room 102, Santa Monica, California 90401. Written public comment submitted before 12:00 p.m. on the day of the meeting will be available for online viewing. All written comments shall be made part of the public record. Please note the agenda item number in the subject line of your written comments.

You may also comment in person at the City Council hearing. Please check the agenda for more detailed instructions on how to comment in person.

Address your comments to: City Clerk
Re: 1125 18TH Street Structure of Merit Designation Appeal (25ENT0135) VIA EMAIL: [email protected]
VIA MAIL: 1685 Main Street, Room 102
Santa Monica, CA 90401
MORE INFORMATION: If you want more information about this project, please contact Stephanie Reich at e-mail at [email protected]. For disability-related accommodations, please contact the City Clerk’s Office at (310) 458-8211 at least 72 hours in advance of the meeting. Every attempt will be made to provide the requested accommodation. All written materials are available in alternate languages provided the request is received 72 hours prior to the meeting. Santa Monica Big Blue Bus Lines serve City Hall and the Civic Center area. The Expo Line terminus is located at Colorado Avenue and Fourth Street, and is a short walk to City Hall. Public parking is available in front of City Hall, on Olympic Drive, and in the Civic Center Parking Structure (validation free).

Pursuant to California Government Code Section 65009(b), if this matter is subsequently challenged in Court, the challenge may be limited to only those issues raised at the public hearing described in this notice, or in written correspondence delivered to the City of Santa Monica at, or prior to, the public hearing.

ESPAÑOL : Esto es una noticia pública para revisar aplicaciones proponiendo desarrollo en Santa Monica. Si desea más información, favor de llamar a Ana Fernandez en la División de Planificación al número (310) 458-2201 ext. 2431 o envíe un correo electrónico a [email protected]

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Packet Pg. 1752 Attachment: City Council Public Notice 1125 18th Street Appeal 25ENT-0135 [Revision 1] (7242 : Appeal of 1125 18th Street Structure of Merit 1 REGULAR MEETING

LANDMARKS COMMISSION
MONDAY, JULY 14, 2025
MEETING BEGINS AT 7:00 P.M.

CITY HALL COUNCIL CHAMBERS
1685 MAIN STREET, ROOM 250
CALL TO ORDER Chair Green called the meeting to order at 7:01 PM

PLEDGE OF ALLEGIANCE

ROLL CALL
Roger Genser
Jack Hillbrand
Pam O’Connor
Dolores Sloan
Amy Green, Chair

Absent:

Jodi Summers
Also present:

Regina Szilak, Senior Planner, Acting Commission Liaison Michelle M. Hugard, Deputy City Attorney
Caroline Yeh, Staff Assistant III

1. SPECIAL AGENDA ITEMS
1-A. 7:04 PM
Oath of Office:

Amy Green
Neal I. Payton
Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1753 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 Commissioner Payton introduced himself to the Commission and highlighted his experience in architecture and historic preservation, including that he recently was appointed to the California State Historical Resources Commission. 1-B. Election of Officers
Commissioner O’Connor made the motion to continue the election of officers until all Commissioners are in attendance and Chair Green seconded. A voice vote was held for the motion and was approved unanimously.
1-C. 7:09 PM
Report from Staff:

Regina Szilak, Senior Planner provided the following staff report:

She announced that staff is moving forward the recommendations from the Subcommittee on Racial Justice/Equity in Preservation and the Working Group. Staff is scheduling unconscious bias training for the Commission, likely to happen at the August meeting, and perhaps a special meeting of the Commission. Staff is also planning a Community Meeting as part of the effort, that will be a special meeting. We have a Save the Date for the Special Meeting of the Landmarks Commission for Sunday, August 24 from 2-5 PM. Please make sure to save the date for this Special Landmarks Commission meeting. It’s important everyone attend.

The upcoming August Landmark Commission meeting will be on August 11th. The agenda will include Mills Act contracts and an update on the Mills Act monitoring program.

City Council adopted the bi-annual budget on June 24. The new City Manager, Oliver Chi, most recently at the City of Irvine joined us today, July 14. City Staff is very enthusiastic about his arrival.

The State of the City will occur on July 17. It will be a little different this year, beginning at Reed Park from 4-7PM, with an opening reception at Miles Playhouse, which marks its reopening. It will also be the kick-off to the City’s 150th anniversary. Thanks to Commissioner Summers for beginning the conversation. This is shaping up to be a series of events that will occur all year that will commemorate the City’s founding, and feature many of those who are often left out of the city history, with an emphasis on recognizing the many voices and cultures in the city.

Commissioner Sloan thanked former Commissioner Garvin for her service to the Landmarks Commission. She worked with her in the Pico Neighborhood. Commissioner Garvin carefully and fairly considered the issues before this Commission.

Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1754 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 Commissioner Genser echoed the acknowledgement of former Commissioner Gloria Garvin. She grew into the job, and was passionate about preservation, including tree preservation.
1-D. 7:09 PM
Presentation and Discussion Regarding Mills Act Conflict of Interest – Section 1090 Legislation
Deputy City Attorney Michelle M. Hugard provided a general overview of Mills Act contracts and Government Code Section 1090 conflicts of interest. She noted the analysis under Section 1090 is very fact specific. If any Commissioners have questions on this topic, please do not hesitate to reach out to the City Attorney’s Office. 1-E. 7:25 PM
Landmarks Commissioner Announcements
• None.

2. CONSENT CALENDAR
2-A. Meeting Minutes:

June 9, 2025
2-B. STOA 308 Alta Ave (25ENT-0035) Landmark Designation 2-C. 1810 Broadway, Philomathean Charity Literary and Art Club, Landmark Plaque Text Commissioner Payton requested to vote on only items 2B and 2C since he wasn’t present for the June 9th Landmarks Commission Meeting.

Commissioner O’Connor made the motion to approve items 2B and 2C on the consent calendar as submitted and Commissioner Green seconded. A voice vote was held and approved by all.

Commissioner O’Connor made the motion to approve item 2A on the consent calendar as submitted and Commissioner Green seconded. A roll call was held for the motion and was approved by the following vote:

AYES: Genser, Hillbrand, O’Connor, Sloan, Green
NAYS: None
ABSTAIN: Payton
ABSENT: Summers
Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1755 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 4 3. STUDY SESSION
• None.

4. CONTINUED ITEMS
• None.

5. STAFF ADMINISTRATIVE ITEMS
• None.

6. PUBLIC HEARING

6.A 7:28 PM
1125 18th Street (25ENT-0069): Structure of Merit Designation Application Consideration of designation application 25ENT-0069 for the property located at 1125 18th Street to determine whether the residential structure in whole or in part, should be designated as a Structure of Merit. The Landmarks Commission will consider the application based on whether the application, research and public testimony presented demonstrates that the building meets one or more of the required criteria for Structure of Merit designation pursuant to SMMC Section 9.56.080. Consideration of compliance with the California Environmental Quality Act (CEQA), including an exemption under CEQA Guideline 15061(b)(3) (Common Sense Exemption).

Ex parte communications:

Genser, Sloan, Hillbrand, Payton, and Green has visited the property.

Commissioner Genser made the motion to give the applicant team 12 minutes for their presentation and Commissioner Hillbrand seconded. A voice vote was held and was approved unanimously.

Ms. Szilak presented the staff report recommending denial of the designation of the property as a Structure of Merit because the structure does not appear to be eligible under any of the designation criteria.

The Commission asked about the Structure of Merit review process. Deputy City Attorney Michelle M. Hugard responded.

The project architect, Shahab Ghods spoke on behalf of the property owner in support of the staff’s recommendation to deny the Structure of Merit request. Asked if the structure could be moved, Mr. Ghods expressed concern thatrelocating the structure and lifting the building might compromise the structural integrity of the building, based on an independent contractor’s opinion. Mr. Ghods stated the future project would maintain the existing front yard specimen tree.

Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1756 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 5 Ruthann Lehrer of the Santa Monica Conservancy presented for the applicant team, identifying why designation was warranted.

Public Comment in support of Designation:

Sharon Bialy (on behalf of Neil Risch), Harry Balaz, Elizabeth Van Denburgh Discussion:

Commissioner Genser stated he will likely support the nomination. The project is one of the few remaining examples configured in a unique way with a side entry.

Commissioner O’Connor commented the residence is not a good example or unique version of Craftsman Style architecture and does not support the proposed designation.

O’Connor also discussed the challenges with the Structure of Merit designation as a whole as a problematic form of designation.

Commissioner Sloan liked the building as a variation on the architecture it represents. It represents a history of Santa Monica. Is leaning towards support but wants to hear from the other Commissioners.

Commissioner Hillbrand commented that the residence is a unique example of a vernacular Craftsman Style bungalow, representative of the historic development pattern in the immediate area. He supports the application for designation.

Commissioner Payton agreed with consultant Page & Turnbull’s analysis that the property is not a good example of vernacular style He stated he does not support designation.

Chair Green agreed with elements of both sides of the argument. The property is 100 years-old and has had very little changes done to it, so it is unique and rare. She supports designation.

Commissioner Genser noted that the Page & Turnbull report did say that the property qualifies with all seven aspects of integrity.

Commissioner Genser made the motion to designate the property as a Structure of Merit under Criteria B1 and B2, including the CEQA reference, and Commissioner Sloan seconded.

A roll call was held for the motion to approve the designation, including the CEQA reference, and was approved by the following vote:

AYES: Genser, Hillbrand, Sloan, Green
NAYS: O’Connor, Payton
ABSTAIN: None
ABSENT: Summers
Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1757 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 6 7. RESOLUTIONS
• None.

8. WRITTEN COMMUNICATION
• None.

9. DISCUSSION ITEMS
9-A. 8:55 PM
Report from the Social Justice/Equity in Preservation Subcommittee regarding status of the effort and next steps.

Ms. Szilak reported there is a Special Landmarks Commission meeting planned for August 24. This will be the community wide meeting identified in the Working Group recommendations that gained full support from this Commission and City Council. Staff is also working on providing unconscious bias training for the Commission and Staff. We will also be sending the Commissioners training opportunities as we learn of them.

Commissioner Sloan explained the purpose of the Special Landmarks Commission meeting (Ice Cream Social) August 24, to be attended by Commissioners and community members, including breaking into smaller groups for discussions.

Chair Green noted she will be out of town for her mother’s birthday. Commissioner Genser noted he might get there a few minutes late.
9-B. Update from the 150th Anniversary Subcommittee regarding various associated events.

Ms. Szilak spoke on behalf of Commissioner Summers who was absent. There will be numerous events around the city celebrating the culture and history of the city throughout the year. Go to https://santamonica150.com/ for a full listing of events. 9-C. Report from Landmarks Commission Liaison to the Architectural Review Board (ARB) on recent ARB consideration and action taken on proposed projects involving additions to or modifications of potential historic resources.

Nothing to report.
9-D. Report from Landmarks Commission representative to the Santa Monica Pier Corporation (SMPC) on recent SMPC activities and action taken on proposed projects involving the Landmark Santa Monica Pier.

Nothing to report.

Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1758 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 7 10. PUBLIC INPUT
• None.

ADJOURNMENT
Chair Green adjourned the meeting at 9:13 PM.

Attest:
__________________________
Regina Szilak
Landmarks Commission Liaison
Approved:
__________________________
Amy Green
Chair
Docusign Envelope ID: 23C67A4B-DE8F-474A-BFF1-67D794C7F60B

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Packet Pg. 1759 Attachment: LC Minutes 20250714 Approved (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
SM Landmarks Commission - Structure of Merit designation, 1125 18th Street, Santa Monica, CA 90403
From David Sonnenschein <[email protected]>
Date Mon 7/7/2025 10:11 PM
To Planning Commission Comments <[email protected]>

EXTERNAL
Attn: Stephanie Reich, Design and Historic Preservation Planner Re: Formal Objection to application 25ENT-0069, 1125 18th Street, Santa Monica, CA 90403, to preserve as a Structure of Merit
Dear Ms. Reich,
I am writing to formally express my strong disapproval, and that of several concerned neighbors on our block, regarding the proposed demolition of the single-story residence and garden at 1125 18th Street, Santa Monica, CA 90403, as outlined in the application dated December 6, 2024.

As a long-term resident of over ten years at the neighboring property, 1127 18th Street, I have witnessed first-hand the historical, environmental, and community value of this property. I submit this letter as a formal complaint and request for reconsideration based on the following grounds:

1. Structure of Merit and Historical Value
The existing home at 1125 18th Street is a clear candidate for designation as a “Structure of Merit” under the city’s conservation guidelines. Its architectural integrity, historical significance, human scale, and integration with the surrounding neighborhood contribute to the cultural fabric of this part of Santa Monica. Preserving such properties is essential to maintaining the city’s identity and resisting unsustainable overdevelopment.

2. Environmental and Health Impacts
The property currently includes green space that serves as an essential oasis for local flora, fauna, and community wellbeing. The garden supports native biodiversity, mitigates the urban heat island effect, and contributes to better air quality. Replacing this space with a multistory structure and subterranean garage will significantly reduce green coverage and increase dust, noise, and pollution during and after construction.

3. Cumulative Impact on Parking and Infrastructure
Parking in this neighborhood is already limited, and the forthcoming construction of several multistoried residential buildings along nearby Wilshire Boulevard will drastically increase demand for both street and permit parking. Adding another dense residential structure without an accompanying plan to address cumulative infrastructure strain is shortsighted and detrimental to current residents.

4. Quality of Life and Community Character
The scale and character of the proposed development—reportedly at least a two-story, six-unit condominium with subterranean garage—will significantly alter the residential feel of this neighborhood. The bulk and height of the structure will lead to a loss of light, privacy, and peace for adjacent homes. This kind of development also risks setting a precedent for further demolitions, eroding the livability of our community.

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Packet Pg. 1760 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) We ask that your department halt the demolition approval process and initiate a thorough review to determine whether 1125 18th Street qualifies for conservation status. We further urge the city to consider more sustainable, community-aligned alternatives that preserve the environmental and historical integrity of our neighborhood.

We, the residents of 18th Street, value the preservation of Santa Monica’s unique character and natural beauty. We ask that you honor this commitment and give proper consideration to our voices.

Sincerely,
David Sonnenschein
On behalf of concerned neighbors of 18th Street
Resident, 1127 18th Street, #4
Santa Monica, CA 90403
[email protected]
310 963-0807

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Packet Pg. 1761 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
SM Landmarks Commission - Structure of Merit designation, 1125 18th Street, Santa Monica, CA 90403
From Annie Goeke <[email protected]>
Date Tue 7/8/2025 9:49 AM
To Planning Commission Comments <[email protected]>

EXTERNAL
Attn: Stephanie Reich, Design and Historic Preservation Planner Re: Formal Objection to application 25ENT-0069, 1125 18th Street, Santa Monica, CA 90403, to preserve as a Structure of Merit
Dear Ms. Reich,
I am writing to formally express my strong disapproval, and that of several concerned neighbors on our block, regarding the proposed demolition of the single-story residence and garden at 1125 18th Street, Santa Monica, CA 90403, as outlined in the application dated December 6, 2024.

As a long-term resident of over 15 years at the neighboring property, 1127 18th Street, and a former Commissioner for Santa Monica as well as being on the Board of the Chamber, I have witnessed first-hand the historical, environmental, and community value of this property. I submit this letter as a formal complaint and request for reconsideration based on the following grounds:

1. Structure of Merit and Historical Value
The existing home at 1125 18th Street is a clear candidate for designation as a “Structure of Merit” under the city’s conservation guidelines. Its architectural integrity, historical significance, human scale, and integration with the surrounding neighborhood contribute to the cultural fabric of this part of Santa Monica. Preserving such properties is essential to maintaining the city’s identity and resisting unsustainable overdevelopment.

2. Environmental and Health Impacts
The property currently includes green space that serves as an essential oasis for local flora, fauna, and community wellbeing. The garden supports native biodiversity, mitigates the urban heat island effect, and contributes to better air quality. Replacing this space with a multistory structure and subterranean garage will significantly reduce green coverage and increase dust, noise, and pollution during and after construction.

3. Cumulative Impact on Parking and Infrastructure
Parking in this neighborhood is already limited, and the forthcoming construction of several multi-storied residential buildings along nearby Wilshire Boulevard will drastically increase demand for both street and permit parking. Adding another dense

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Packet Pg. 1762 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) residential structure without an accompanying plan to address cumulative infrastructure strain is shortsighted and detrimental to current residents.

4. Quality of Life and Community Character
The scale and character of the proposed development—reportedly at least a two-story, six-unit condominium with subterranean garage—will significantly alter the residential feel of this neighborhood. The bulk and height of the structure will lead to a loss of light, privacy, and peace for adjacent homes. This kind of development also risks setting a precedent for further demolitions, eroding the livability of our community.

We ask that your department halt the demolition approval process and initiate a thorough review to determine whether 1125 18th Street qualifies for conservation status. We further urge the city to consider more sustainable, community-aligned alternatives that preserve the environmental and historical integrity of our neighborhood. I have been very discouraged by the city's uncontrollable ability to keep Santa Monica City following an agenda that reflects SMART GROWTH.

We, the residents of 18th Street, value the preservation of Santa Monica’s unique character and natural beauty. We ask that you honor this commitment and give proper consideration to our voices.

Sincerely
Anne Goeke
1127 18th Street, #4
Santa Monica, CA 90403
Annie de la Bouillerie Goeke
International Consultant
To learn more: LinkedIn

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Packet Pg. 1763 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
25ENT-0069, 1125 18th St. Email No. 1 (Front House)
From [email protected] <[email protected]>
Date Fri 7/11/2025 11:58 AM
To Planning Commission Comments <[email protected]>

EXTERNAL
To Stephanie Reich - Hello Stephanie,
I'm going to send 2 emails regarding the houses @ 1125 18th Street. This is email No. 1 and concerns the front (westerly) house. As you are aware, I've lived at this location for the last 23 years (since 2002).

My landlord from 2002 until 2022 was Mr. Karl Jennings. He let me know that the 1125 property was owned by the Jennings family since 1930 and that he grew up in the house I live in (rear house 1125 1/2).

As I showed you during your recent visit, the front house moved some 8 inches to the west during the January 1994 earthquake. Remedial repair work was completed in March of 1994 and approved by SM Dept. of Bldg. & Safety. This house was built in 1923 (Permit no. B 1208) and is in excellent original and preserved condition both inside and outside.

I've researched the Building Permit Records for this house and confirmed that there have not been any modifications to the house itself since 1923 requiring a Building Permit excepting the earthquake repairs.

I think this house should be saved from the "wrecking ball" in order to preserve the beauty and integrity inherent in these simple but elegant "Craftsman Style" houses of era's past.

Thank you for your consideration ! Harry Balaz @ 1125 1/2 18th St. [email protected]

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Packet Pg. 1764 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
25ENT-0069, 1125 18th St. - Email No.2 (Rear House)
From [email protected] <[email protected]>
Date Fri 7/11/2025 12:39 PM
To Planning Commission Comments <[email protected]>

EXTERNAL
To: Stephanie Reich, Hello Stephanie,
Email No. 2 concerns the rear house @ 1125 1/2 St. I've lived here for 23 years. The Building Permit records show that this house started construction in early 1951 and was completed in June 1953. This house was originally built as a 700 sq. ft. one bedroom "Granny House". Permit No. B 8631 confirms that the actual construction of the house was done by the owner (Mr. Robert Jennings). In fact, my landlord Karl (Robert's son) explained to me that Robert and his wife Hazel lived in a tent in the backyard of the front house during the 2 1/2 year construction period. 1125 1/2 is not a direct copy of 1125 but all of the components and its general "feel" are identical.

In 1964 a second bedroom was added to the 1125 1/2 house (see Permit No. B 35069). This additional bedroom was not built by Robert Jennings. It was constructed by "United Contractors" during the time period between May and July of 1964. It was the bedroom for Karl Jennings I think the rear house should be saved because of the unique situation of the rear house being personally built (with his own hands) by the resident of the front house. It's my opinion that these 2 houses are the only 2 left in Santa Monica where the "Granny House" is still standing as a "one family" structure.

Thank you for your consideration ! Harry Balaz 1125 1/2 18th St. [email protected]

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Packet Pg. 1765 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
Reference: 25ENT-0069 Structure of Merit Designation Nomination – 1125 18th Street.

From ariel levy <[email protected]>
Date Fri 7/11/2025 6:24 PM
To Planning Commission Comments <[email protected]> Cc Stephanie Reich <[email protected]>
1 attachment (15 KB)
1125 18th Street.docx;

EXTERNAL
Dear Stephanie,
I attach a letter in which I have expressed my thoughts on this application.

Sincerely,
Ariel Levy

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Packet Pg. 1766 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Stephanie Reich, Design and Historic PreservaƟon Planner City Planning Division
1685 Main Street, Mail Stop 28
Santa Monica, CA90401
Friday 11th July
Dear Stephanie,
Reference: 25ENT-0069 Structure of Merit DesignaƟon NominaƟon – 1125 18th Street.

I have lived at 1122 19th Street for the last 30 years and am very familiar with the property, the subject of the designaƟon applicaƟon.

My affecƟon for this property derives from its exquisite craŌsman architecture, meƟculously maintained, and increasingly rare to be seen in our neighborhood.
1626 California Avenue is an example of a craŌsman house which is being developed. But in deference to its architectural and historic beauty, the development is preserving its façade whilst creaƟng, presumably, a modern home behind.

In this age of acceleraƟng development of contemporary buildings in Santa Monica, the historic beauty and character of these older buildings needs to be preserved if we are not to end up with an unremiƫng concrete and glass urbanscape.

There are opportuniƟes to advance development to tackle the housing shortage, without eliminaƟng all the older historic properƟes.

It is crucial in my view that we don’t exƟnguish the original character of this beauƟful city but celebrate and preserve it.

This applicaƟon is just such an opportunity.

Sincerely,
Ariel Levy

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Packet Pg. 1767 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
25ENT-0069
From Laura Moran <[email protected]>
Date Sun 7/13/2025 12:13 AM
To Planning Commission Comments <[email protected]>

EXTERNAL
Dear Ms. Reich,
My name is Laura Moran and my husband, daughter, and I lived at 1125 18th St. from 2009-2011, while my husband completed a fellowship at the John Wayne Cancer Institute.

I heard that the 2 houses on the property are up for demolition, and this is very upsetting to my family and me.

We moved from Illinois and had a friend, that lived in the LA area,  check out several rentals for us, since we could not see them ourselves.  As soon as he stepped foot on the property, he called us to tell us what a rare find this lovely home was, and we rented it right then, sight unseen.

The previous owner had such wonderful stories to tell us about the house since his grandparents, then parents owned the house before him. It made it through a huge earthquake in 1920, and the house was very loved by the original family, then renters after that.

My daughter was a baby when we lived there and she and I would have picnics under the beautiful tree in the front yard, and eat avocados from the tree in the backyard.

With such great homes on the property, and the long history, I really hope it does not get demolished for a new build.

Feel free to contact me with any questions.

Thank you!
Laura Moran
1933 SW Iowa St
Portland, OR 97239
(503)502-2272

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Packet Pg. 1768 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
Opposition to Demolition – Support for Designating 1125 18th St. as a Structure of Merit From Bruce Pomeroy <[email protected]>
Date Sun 7/13/2025 6:38 PM
To Planning Commission Comments <[email protected]>; Stephanie Reich <[email protected]>

EXTERNAL
Re: Opposition to Demolition – Support for Designating 1125 18th St. as a Structure of Merit Dear Members of the Landmark Committee,
I am writing as a concerned resident of Santa Monica to urge the committee to consider designating the property located at 1125 18th St. as a Structure of Merit and to oppose its demolition and proposed replacement with a multi-unit condominium development.

This building is a single-story home with architectural and historical value that contributes significantly to the character and charm of our neighborhood. Its distinctive design, mature tree in the front yard, and well-maintained landscaping provide a sense of continuity and connection to our community’s past, qualities that cannot be replicated by modern high-density developments.

Preserving this property is not just about aesthetics; it’s about maintaining the fabric of a neighborhood that values history, open space, and livability. The green yard and large tree serve as more than visual assets- they support local biodiversity, provide openness, and offer a shared sense of peace for neighbors and passersby.

While responsible development is important, it should not come at the expense of irreplaceable historical resources. I respectfully ask the council to prioritize thoughtful preservation and explore alternatives that allow for housing growth without erasing our community’s architectural heritage.

Thank you for your time and consideration.

Sincerely,
Liz Pomeroy
Teacher at St. Monica’s Preparatory School

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Packet Pg. 1769 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
Opposition to Demolition at 1125 18th Street
From Bruce Pomeroy <[email protected]>
Date Sun 7/13/2025 6:47 PM
To Planning Commission Comments <[email protected]>; Stephanie Reich <[email protected]>

EXTERNAL
To: Santa Monica Landmarks Commission and Planning Commission Re: Opposition to Demolition
25ENT-0069, 1125-18th Street
Dear Commission Members:

Do you know how lucky you are?
In amongst the high rises, the hospitals, the restaurants, the problems, you have lovely remnants of a charming Southern California coastal community.

Why on earth would you let the fewer and fewer charming cottages and huge trees be demolished for yet another soulless building? Within blocks of 1125-18th, on Wilshire and Montana, at least 60 units are already slated for development. Seriously- WHY are even more needed?
In the six months after evacuating from the Palisades in January, we have lived in our daughter’s condo at 1117-18th Street. I have come to love Santa Monica and feel fortunate we had a place to go. Taking a long walk each evening, the smaller homes and bungalows I came to know were beguiling. The setbacks allowed for trees and gardens which are soothing. The neighborhood feeling was palpable.

If for some reason so much development is needed, why at least can’t the density be kept to Wilshire, Montana, and other main streets?
Then there is the matter of the huge, ancient tree in front of the property. How many years would it take to replace that tree? Are people so greedy that the need for green space and openness is ignored in favor of density and profit? Surely the tax base in Santa Monica is robust- so it can’t be for tax dollars?!

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Packet Pg. 1770 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Please, Santa Monica, take this chance to make the right decision to save this special property with its lawn, tree, charm, and relief from the ugliness of all-the-same condos and apartments.

Bottom line? The whole community of Pacific Palisades was lost overnight. We literally cannot go back. Why, given the chance you have right now, wouldn’t you save your community while you can?
Please.

Anne H. Pomeroy
Student Teacher Supervisor at Samo, LACMA art docent, and strong fan of historical preservation

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Packet Pg. 1771 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
Strong objection to demolition at 1125 18th Street
From Bruce Pomeroy <[email protected]>
Date Sun 7/13/2025 7:22 PM
To Planning Commission Comments <[email protected]>; Stephanie Reich <[email protected]>
1 attachment (19 KB)
1125 18th Street - No Demo.docx;

EXTERNAL
Commission Members,
My wife and I are trustees with my daughter in the home she recently bought at 1117 18th Street. We are sorry to hear that consideration is being given to allowing the demolition and construction on the property immediately south.

As a residential and commercial developer over the last 50 years, I well understand the owner’s interest in demolishing the homes at 1125 18th Street and building condominiums. With more than 500 projects in my resume, I have attended hundreds of community hearings and listened to numerous neighborhood concerns.

I have to say, given the impact and understandable opposition to turning a very nice craftsman bungalow into another dense cube of condominiums, were it mine I would not move forward to develop this property – community over profit.

In support of my opposition to the demolition of this property, please see my letter (attached).

Thank you,
Bruce Pomeroy
Bruce Pomeroy Executive Chairman
14956 Camarosa Drive, Pacific Palisades, CA 90272
Main: 602.808.8600 | Mobile: 310.743.3999
evgre.com | [email protected]

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Packet Pg. 1772 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) To: Landmark Commission
From: Bruce Pomeroy
Permit(s): 25ENT-0069
Address: 1125 18th Street
Applicant: Santa Monica Conservancy
Commission Members,
As Pacific Palisades fire evacuees, my wife and I lived with our daughter at 1117 18th Street for the last 5 months. While Santa Monica is characterized by very dense residential development, we were pleased to see grass, trees and some skyline in our daughter’s neighborhood – and specifically, next door.

It would be extremely sad to see the classic bungalow home, amazing mature tree, and the openness of the property destroyed by massive development. Isn’t there already enough of that happening in the City?
In reviewing the file for the hearing with the Landmark Commission, I have noted more support for denying the demolition than the tone of the report suggests. Specifically:
1) The home in question is more than 50 years old;
2) The integrity of the home – location, setting, design, materials, workmanship, feeling, and association - is intact in all respects;
3) The home meets the criteria in section 9.56.080(a) of SMMC. The structure has been identified in the City’s Historic Resources Inventory and the subject property is identified in the City of Santa Monica’s 2018 Historic Resources Inventory update as a potentially eligible resource for local listing. It technically meets the wording of this criterion. While it is Page & Turnbull’s opinion that “identification as a potential resource in Santa Monica’s Historic Resources Inventory does not alone provide sufficient basis for the individual designation of a property as a Structure of Merit”, in fact, it DOES meet the criteria. 4) The Page and Turnbill report states that the Craftsman bungalow does not meet the criteria that it represents a style that is “no longer prevalent” in Santa Monica. That is nonsense. Take a tour of the City and try to say that Craftsman bungalow homes are prevalent! Even of those noted in the 2018 Historic Resources Inventory, the report states that even just since 2018 “some have been removed for site redevelopment and others altered to a degree that they have lost integrity”. Just when will the City draw the line?
I urge you to find that the existing Craftsman home does merit a designation of a Structure of Merit – and deny the request to demolish the property.

Thank you,
Bruce Pomeroy

12.A.j
Packet Pg. 1773 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
Re: Strong objection to demolition at 1125 18th Street
From Sharon Bialy <[email protected]>
Date Sun 7/13/2025 7:43 PM
To Bruce Pomeroy <[email protected]>
Cc Planning Commission Comments <[email protected]>; Stephanie Reich <[email protected]>

EXTERNAL
Stephanie
I am also lending my support and concur with Bruce Pomeroy's letter and will be at the hearing tomorrow evening.

In addition to everything that Mr. Pomeroy brought up, there are a few beautiful craftsman bungalow homes in the area that add to the beauty of Santa Monica.

In particular there is one on 18th street just south of Wilshire. So I don't understand the position that Turnball has taken as it appears to not reflect the reality of the neighborhood and it's history.

Thank you for your consideration.

Sharon
On Sun, Jul 13, 2025 at 7:19 PM Bruce Pomeroy <[email protected]> wrote:

Commission Members,
My wife and I are trustees with my daughter in the home she recently bought at 1117 18th Street.

We are sorry to hear that consideration is being given to allowing the demolition and construction on the property immediately south.

As a residential and commercial developer over the last 50 years, I well understand the owner’s interest in demolishing the homes at 1125 18th Street and building condominiums.  With more than 500 projects in my resume, I have attended hundreds of community hearings and listened to numerous neighborhood concerns.

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Packet Pg. 1774 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) I have to say, given the impact and understandable opposition to turning a very nice craftsman bungalow into another dense cube of condominiums, were it mine I would not move forward to develop this property – community over profit.

In support of my opposition to the demolition of this property, please see my letter (attached).

Thank you,
Bruce Pomeroy
Bruce Pomeroy Executive Chairman
14956 Camarosa Drive, Pacific Palisades, CA 90272
Main: 602.808.8600 | Mobile: 310.743.3999
evgre.com | [email protected]

12.A.j
Packet Pg. 1775 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) To: Landmark Commission
From: Bruce Pomeroy
Permit(s): 25ENT-0069
Address: 1125 18th Street
Applicant: Santa Monica Conservancy
Commission Members,
As Pacific Palisades fire evacuees, my wife and I lived with our daughter at 1117 18th Street for the last 5 months. While Santa Monica is characterized by very dense residential development, we were pleased to see grass, trees and some skyline in our daughter’s neighborhood – and specifically, next door.

It would be extremely sad to see the classic bungalow home, amazing mature tree, and the openness of the property destroyed by massive development. Isn’t there already enough of that happening in the City?
In reviewing the file for the hearing with the Landmark Commission, I have noted more support for denying the demolition than the tone of the report suggests. Specifically:
1) The home in question is more than 50 years old;
2) The integrity of the home – location, setting, design, materials, workmanship, feeling, and association - is intact in all respects;
3) The home meets the criteria in section 9.56.080(a) of SMMC. The structure has been identified in the City’s Historic Resources Inventory and the subject property is identified in the City of Santa Monica’s 2018 Historic Resources Inventory update as a potentially eligible resource for local listing. It technically meets the wording of this criterion. While it is Page & Turnbull’s opinion that “identification as a potential resource in Santa Monica’s Historic Resources Inventory does not alone provide sufficient basis for the individual designation of a property as a Structure of Merit”, in fact, it DOES meet the criteria. 4) The Page and Turnbill report states that the Craftsman bungalow does not meet the criteria that it represents a style that is “no longer prevalent” in Santa Monica. That is nonsense. Take a tour of the City and try to say that Craftsman bungalow homes are prevalent! Even of those noted in the 2018 Historic Resources Inventory, the report states that even just since 2018 “some have been removed for site redevelopment and others altered to a degree that they have lost integrity”. Just when will the City draw the line?
I urge you to find that the existing Craftsman home does merit a designation of a Structure of Merit – and deny the request to demolish the property.

Thank you,
Bruce Pomeroy

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Packet Pg. 1776 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
25ENT-0069 Structure of Merit Designation Nomination 1125 18th Street From Joe Hackett <[email protected]>
Date Sun 7/13/2025 8:53 PM
To Planning Commission Comments <[email protected]>

EXTERNAL
To Whom It May Concern,
The property at 1125 18th St is a beautiful building. It would be a shame to tear it down. My partner and our children walk by it everyday.

We are neighbors who work and live in Santa Monica.

All of our children go to public school here and we are very much a part of the community.

The more buildings we see torn down the more we feel like the diverse community is negatively impacted.

Sincerely
Joe Hackett
323-346-7815
[email protected]

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Packet Pg. 1777 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
Comment on 1125 18th Street (25ENT-0069): Structure of Merit Application From [email protected] <[email protected]>
Date Mon 7/14/2025 12:50 AM
To Planning Commission Comments <[email protected]> Cc Regina Szilak <[email protected]>; Stephanie Reich <[email protected]> 1 attachment (23 KB)
Risch-Comment-on-25ENT-0069.docx;

EXTERNAL
Dear Landmarks Commission:

Attached please find my comment on the Structure of Merit Application 25ENT-0069 for 1125 18th St.

Regina and Stephanie, I am also copying you so you also have a copy of my comment.

Many thanks for you assistance and consideration,
Neil Risch

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Packet Pg. 1778 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Comment on Agenda Item: 1125 18th Street (25ENT-0069): Structure of Merit Application One thing I appreciate most about Santa Monica is its diversity of architecture - reflecting structures from various eras, representing different styles - so we can actually view the evolution of architecture here. We have buildings over 100 years old alongside art deco, mid-century modern and more modern structures all within the same neighborhoods and streets. I also live on 18th St north of Wilshire, and have walked extensively through most of the streets of WilshireMontana, because I am avid walker – I enjoy frequenting the stores and businesses on Montana Ave and frequently walk to the beach on California, Washington and Idaho. I also walk east through the neighborhood to appreciate the various architectural styles in that direction. So I feel I have a good sense of the varied architecture that exists in this beloved (at least to me) section of Santa Monica.

While development of new housing structures is also important for a thriving Santa Monica, preservation of structures that are rare and reflect the history of development in Santa Monica is also paramount to maintain this longstanding architectural history. I believe that the 103 yearold craftsman style house at 1125 18th St meets exactly that standard of historic and rare, reflecting a craftsman style of architecture that was popular in the early 1920s when the structures were built, but are now sparse in the neighborhood.

The Santa Monica Conservancy, in its nomination of this structure, has laid out in far greater detail than I could the description of the history of the house and its construction, its details, the setting and the neighborhood. I have also read the architectural report from the firm of Page & Turnbull, and will focus primarily on the criteria for Structure of Merit in Santa Monica, and whether they have been met. I say this because there is an apparent discrepancy between what the Conservancy has said about the criteria – and in particular the prevalence and rarity of craftsman structures similar to 1125 18th St, versus what Page & Turnbull has said, and their conclusion.

Again, I don’t feel I need to reiterate the Conservancy’s compelling argument (nor the comments in some of the submitted letters). Rather, I will focus on arguments made by Page & Turnbull, who conclude that the building does not meet criteria for Structure of Merit.

The Santa Monica Code 9.56.080 regarding criteria for Structure of Merit states the following:
“For the purposes of this Chapter, an improvement may be designated a Structure of Merit if the Landmarks Commission determines that it merits official recognition because it has one of the following characteristics:

A.

The structure has been identified in the City's Historic Resources Inventory.

B.

The structure is a minimum of 50 years of age and meets one of the following criteria:

1. The structure is a unique or rare example of an architectural design, detail or historical type.

2. The structure is representative of a style in the City that is no longer prevalent.

3. The structure contributes to a potential Historic District.” So, the question appears to be whether the subject house meets either criterion A or B, or both.

I believe it meets both criteria A and B (in disagreement with the report of Page & Turnbull).

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Packet Pg. 1779 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Regarding A, it is unequivocal that the subject house, 1125 18th St, exists in Santa Monica’s Historic Resources Inventory, and has since 2018, and so it “has been identified in the City’s Historic Resources Inventory,” seemingly meeting that criterion. However, Page & Turnbull appear to qualify its identification there, as follows:
“As the subject property is identified in the City of Santa Monica’s 2018 Historic Resources Inventory update as a potentially eligible resource for local listing, it technically meets the wording of this criterion. However, it is Page & Turnbull’s opinion that identification as a potential resource in Santa Monica’s Historic Resources Inventory does not alone provide sufficient basis for the individual designation of a property as a Structure of Merit. This criterion recognizes the findings of previous evaluations conducted in support of the inventory and update. It appears to presume that if a property is “identified” in the inventory, it has already been evaluated according to and found significant under at least one of the categories of SMMC 9.56.1080(b) (see below). Therefore, while the property may meet the text of the criterion as written in SMMC § 9.56.080(a), it does not appear to meet the intent of the criterion.” I believe this to be an overreach by Page & Turnbull. They are now subjugating this explicit criterion to the vagueness of “intent” with an “opinion.” I don’t believe it is up to this firm to determine what the original “intent” of this inventory and its designations have been. In fact, as they point out, other entries in the Historic Resources Inventory (specifically 14 craftsman style houses according to my count in the Wilshire-Montana neighborhood) have the same designation. If the Landmarks Commission were to agree with this interpretation of the Code’s explicit statement, that would effectively nullify all structures with similar entries in the entire Historic Resources Inventory including all of Santa Monica.

Now I will discuss item B, and in particular B.1 and B.2 (since the structure under discussion does not lie within a “potential Historic District”). There appears to be a discrepancy here between the arguments proffered by the Conservancy and Page & Turnbull. The Conservancy has stated the following:
“1. The structure is a unique or rare example of an architectural design, detail or historical type. The subject property is a Craftsman bungalow that was constructed late in the time period for that style’s prevalence – 1923 – and has design features that are unique within the typical framework of that style: the offset entryway placed at a side elevation rather than at the front; the small entry porch reduced to frame the front door; the intersecting cross roof gables; the bank of windows on the front façade with crossed muntins which are asymmetrical, lacking the lower muntin.

2. The structure is representative of a style in the City that is no longer prevalent.

Single-family one-story Craftsman homes represent a style that is no longer prevalent.” By contrast, Page & Turnbull have stated the following in their report:
“According to the 2018 Historic Resources Inventory update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to 1125 18th Street. Although some have been lost to redevelopment and others altered to the degree that they have lost integrity, the modest Craftsman bungalow remains a relatively common building type within the neighborhood.”
I will now discuss this claim of “relatively common building type within the neighborhood.”

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Packet Pg. 1780 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) As I mentioned above, I have walked the Wilshire-Montana neighborhood extensively – and seen all the more recent developments that others have commented on. What I have more closely paid attention to are the older historical structures that still exist. One thing I have noticed is that the western part of Wilshire-Montana seems to have more of these residences than the eastern part. Through investigation, I now understand that my impression has a basis.

I examined the Historic Resources Inventory to identify all craftsman style houses in WilshireMontana. Similar to Page & Turnbull’s findings, I also found 32 such structures (all built between 1906 and 1924), although one had a lack of visibility listing, and another had been demolished since 2018. Of the remaining 30, I then ordered them from west to east, and here is my observation:

Ocean Ave - 1
2nd St - 2
3rd St - 1
4th St - 3
5th St - 5
6th St - 3
California Ave at 6th St – 1
7th St - 2
Lincoln Blvd -1
9th St - 1
California Ave at 9th St – 1
10th St - 2
11th St - 1
14th St - 1
California Ave at 16th St – 1
18th St - 1
19th St - 1
21st St - 1
22nd St - 1
The first thing to notice in the list above is that 19 of the 30 lie west of Lincoln Blvd, and 25 lie west of 14th St. Only 5 lie east of 14th St. Thus, the entire eastern part of Wilshire-Montana is extremely sparse when it comes to craftsman style houses. It appears that while Page & Turnbull correctly determined the number of remaining craftsman houses in Wilshire-Montana, they didn’t further investigate their distribution and density.

But there is another salient issue. Both the Conservancy and Page & Turnbull have documented that 1125 18th St lies within the historic Green Acres section of development, which was from 17th St to 21st St, Wilshire to Washington. According to the above, there remain only 2 existing craftsman houses from that development. If 1125 18th St were demolished, there would be just one remaining, and ultimately potentially none. Allowing for this demolition would effectively eliminate any historic remnants of this style from that era. In other words, evidence suggests that such craftsman style homes from that era are indeed sparse, especially in the eastern part of Wilshire-Montana.

In summary, as a person who treasures living in Santa Monica, and especially the neighborhood in which I live, I feel a strong interest in maintaining the ambiance that gives it a special character – and for me, it is the varied, and especially older and historic homes that dot the

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Packet Pg. 1781 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) landscape, of which 1125 18th St is one valued representative. While I, as others, also understand the need for development, I feel that it should be done judiciously so as not to infringe on our history. I do believe that according to the stated criteria in the Santa Monica code regarding the requirements for Structure of Merit status, the evidence indicates that the house at 1125 18th St meets both criteria A and B.

Sincerely yours,
Neil Risch
1117 18th St
Santa Monca, CA

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Packet Pg. 1782 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
25ent-0069,1125 18th street
From Randal Groves <[email protected]>
Date Mon 7/14/2025 6:55 AM
To Planning Commission Comments <[email protected]>

EXTERNAL
To whom it may concern,
My name is Randal Groves. It has come to my attention the property located at 1125 18 th street in Santa Monica may be subject to redevelopment.

This news comes as little surprise as so many of the single family homes in Santa Monica have suffered a similar fate. However this property is truly special and deserves to be protected the from the wrecking ball.

If only to preserve the spectacular Chinese Elm that was planted by the family of original owner/builder, as I understand from the landlord I rented the property from for many years.

The front house on the property is an example of a classic 1930’s California beach bungalow that my wife and I considered the most perfect home we have ever lived. The dappled western light, filtered by the Elm tree filled the house in the afternoon through the divided light windows, it is sublime. With a breeze coming from the Pacific the temperature was always just right, never a need of anything more than a window adjacent.

It’s a small home but it’s filled with so much love that has been shared by all who have occupied this gem.

For my wife and I the time in this wonderful home were some of the best years of our life together. When the owner of the home was ready to sell they offered the house to us as he understood we would be great stewards in the preservation of his family’s home. Unfortunately the home market in Santa Monica proved to be too expensive for 2 successful film makers.

Please strongly consider preserving this example of the best of California beach bungalow architecture.

Peace,
Randal Groves

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Packet Pg. 1783 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1784 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
1125th 18th St
From Andrea Flores <[email protected]>
Date Mon 7/14/2025 8:08 AM
To Planning Commission Comments <[email protected]>

EXTERNAL
Hi, good morning.

Just wanted to write a brief email in support of my next door neighbor at 1125 18th street. Harry is a wonderful neighbor living in the house on the back, and I would like to be supportive in saying that his house should not be demolished, it’s his home and we like to maintain a peaceful community around here without any heavy construction going on as well.

I kindly ask to reconsider the construction.

Thank you, have a great day.

Andrea F.

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Packet Pg. 1785 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
25ENT-0069, 1125 18th St
From Adrianna Valencia <[email protected]>
Date Mon 7/14/2025 11:52 AM
To Planning Commission Comments <[email protected]>

EXTERNAL
Hello Stephanie,
My name is Adrianna Valencia and I’m reaching out because it has come to my attention that the property @ 1125 18th Street is subject to re-development. This news has greatly saddened me. My husband and I had the great pleasure of living there for 2 short years. Both my husband and I work in Film/TV industry. We moved in when our dear friend another industry colleague moved out. I can’t express the excitement I felt when our friend called us to inform us that the rental was becoming available again.

I’m born and raised in Los Angeles. Growing up in Eagle Rock and Pasadena I have a great admiration for beautiful Craftsman and Bungalows style homes in those neighborhoods. Unfortunately, as soon as we signed our lease we both were called to work on a project in New Orleans in 2020 After only living @ 1125 for 3 months. When the world shut down we remained in New Orleans for an entire year.  We left on April 2020 and returned March 2021. By then the previous owner had decided to sell his family’s property. I loved the history of his home. The property spanned 3 generations. The beautiful Chinese Elm was planted by his father and Karl the previous owner when he was a child. His grandfather built the back house with his own hands. Karl went to school across the street when there was a school there.

In the short amount of time we lived there we built a lovely community there. We had lovely informal gatherings with our neighbors under the Chinese Elm. Most people that walked by were often surprised that this little gem of a house still existed in the neighborhood, in the ever changing glossy Santa Monica. I still miss living there. I miss the beautiful dappled light coming through the original windows.

The sound of the Chinese Elm rhythmically swaying when the ocean wind came from the west. I was shattered when a neighbor sent a photo of the demolished garage. While it was nothing to look at — it was functional.

We were offered to purchase this Gem of a Home. Unfortunately, my husband and I are mere mortals and could not swing Santa Monica property prices. Hind sight is 20/20. I truly hope that the city of Santa Monica considers saving this beautiful gem. Thank you for your time and consideration.

Sincerely,
Adrianna Valencia

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Packet Pg. 1786 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Outlook
SM Landmarks Commission - Structure of Merit designation, 1125 18th Street, Santa Monica, CA 90403
From Morgan Sykes Jaybush <[email protected]>
Date Mon 7/14/2025 12:00 PM
To Planning Commission Comments <[email protected]>

EXTERNAL
Attn: Stephanie Reich, Design and Historic Preservation Planner Dear Ms. Reich,
I am writing to express my strong support of the Structure of Merit designation for the 1923 single family residence at 1125 18th Street.

I am on the Board of the Santa Monica Conservancy, but I am writing to you personally, and not as a part of the Conservancy.

This Craftsman style house is a unique example of the style, which is not just a typical Craftsman that you see in many places in the City and in the County.  It has an asymmetrical street facing facade with wrap-around windows in the main front living room facing the front yard, with the front door actually being located on the side of the house.  Paired with the magnificent tree in the front yard, this house acts as an oasis on this block of 18th Street, which only has 3 original houses left on the block.

Everything else on this block has been torn down and turned into oversized apartment buildings.

We need to preserve the very few single family properties we have like this in neighborhoods which have been intensely densified, such as this particular block, or we will continue to lose all of the character and charm that people move to Santa Monica for in the first place.  There are many many other properties in the City which could be densified, without sacrificing the history and charm of the neighborhood.

Another potential great option could be just densifying the rear portion of the lot, similar to the excellent projects at 2501 2nd St., 401 Ocean Ave., and 1012 2nd St.

Thanks,
Morgan Sykes Jaybush
Creative Director, Legacy LEED AP
Omgivning

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Packet Pg. 1787 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation) O: 2

13.596.5602ext717
M: 323.687.8065
Locatedat:
söm co-space
1301 N. Broadway
Los Angeles, CA 90012

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Packet Pg. 1788 Attachment: LC Public Correspondence 20250714 Item 6A (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1789 Attachment: 05 Levine Act P&T - signed 3-27-25 (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

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Packet Pg. 1790 Attachment: 05 Levine Act P&T - signed 3-27-25 (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Santa Monica City Council
Structure of Merit Designation Appeal
1125 18th Street
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

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Packet Pg. 1791 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • Good evening, Mayor, Councilmembers, and members of the public. • My name is Joseph, and I am here this evening as the property owner to respectfully request a reconsideration of the Structure of Merit designation for 1125 18th Street.
• I would like to begin by expressing my sincere appreciation for Santa Monica’s dedication to preserving its historical heritage. This commitment truly contributes to what makes our city unique.

Item 12-A
November 18, 2025
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Packet Pg. 1792 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • But in this case, I don’t believe the designation truly reflects the actual condition, character, or architectural value of this property.
• Just to give you a little background — I am a physician and surgeon by profession, but I’ve also been interested in restoring and improving properties around Los Angeles for many years.

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November 18, 2025
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Packet Pg. 1793 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • For example, I own a commercial
building at 301 North Avalon Boulevard
in Wilmington — built in 1924 and
designed in the Italian Renaissanc
e
Revival Architecture Style
— which was
listed as a Historic- Cultural Monument
in 2022. I bought it in 2010, and I
welcomed that process, and I still tak
e
great care of it today.

Item 12-A
November 18, 2025
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November 18, 2025

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Packet Pg. 1794 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • I also own a 1908 Craftsman
-
style home in Jefferson Park —
2146 West 31st Street — whic
h
is part of L.A.’s historic district.
• It’s a true piece of history, and
I’ve always been proud to
preserve it. I bought it in 2015,
and since then I have learned a
great deal about Craftsman-
Style Homes. 1125 18th street
is not a Craftsman Style Home.

Item 12-A
November 18, 2025
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Packet Pg. 1795 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • And more recently, I
built a modern single-
family home in
Brentwood,
• completed in 2017 at
444 Tuallitan Road
—a
project that was really
well received by the
neighbors and the
community.

Item 12-A
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Packet Pg. 1796 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • So, when I purchased 1125 18th Street in December 2021, I did so knowing its R2 zoning and its potential — I planned not to erase history, but to contribute something thoughtful and positive to Santa Monica’s evolving community. • I truly believe that real preservation should highlight exceptional examples of history — not restrict the modification of properties that simply don’t meet that level of significance anymore.
• We must find that balance between honoring the past and supporting the need for safe, beautiful, and livable housing for the future.

Item 12-A
November 18, 2025
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Packet Pg. 1797 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure • So tonight, I simply ask the Council to take another look— and allow the demolition permit to move forward — not as a loss of history, but as a step toward a vibrant future for the city we all love.
• Thank you so much for your time and consideration.

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Packet Pg. 1798 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Item 12-A
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Packet Pg. 1799 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Item 12-A
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Packet Pg. 1801 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Item 12-A
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Packet Pg. 1802 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Item 12-A
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Packet Pg. 1803 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1125 18th
Street
Structure of Merit
11/19/2025 1
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Packet Pg. 1804 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Sanborn Map 1935
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2 Item 12-A
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Packet Pg. 1805 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Sanborn Map 1961
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3 Item 12-A
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Packet Pg. 1806 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure

CONTEXT
11/19/2025

4 Item 12-A
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Packet Pg. 1807 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 11/19/2025
5 CONTEXT
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Packet Pg. 1808 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1125 18 TH ST.

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Packet Pg. 1809 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1125 18 TH ST.

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Packet Pg. 1810 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 828 7TH ST.

Another Structure of Merit
Classic Craftsman Bungalow
11/19/2025

8 908 CALIFORNIA AVE.

Landmark Eligible on the HRI
Classic Craftsman Bungalow
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Packet Pg. 1811 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1125 18 TH ST.

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Packet Pg. 1812 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1125 18 TH ST.

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Packet Pg. 1813 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1125 18 TH ST.

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Packet Pg. 1814 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure

SUMMARY
A. Listed on the Historic Resources Inventory
B. More than 50 years old B. 1. The structure is a unique or rare example of an architectural design, detail or historical type o A unique or rare example of a historical type, the single -
family home that initiated residential development in the Wilshire-Montana neighborhood in the 1920s;
o A unique or rare variation of typical Craftsman bungalow design, with a band of windows instead of an open front porch facing the street.

B. 2. The structure is representative of a style in the City that is no longer prevalent.
11/19/2025
12 1125 18 TH ST.

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Packet Pg. 1815 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure Examples of Historic Structures
Combined with New Housing Construction
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Packet Pg. 1816 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 2501 2ND
STREET
11/19/2025
14 before
today (in progress)
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Packet Pg. 1817 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1012 2ND
STREET
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15 Item 12-A
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Packet Pg. 1818 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 11/19/2025
16 401 OCEAN
AVENUE
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Packet Pg. 1819 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 11/19/2025
17 PONO BURGER

AND HIGHRISE
829 BROADWAY
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Packet Pg. 1820 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 11/19/2025
18 THE LAUREL

APARTMENTS

NIKKEI HALL
1413
MICHIGAN AVE.

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Packet Pg. 1821 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure

SUMMARY
A. Listed on the Historic Resources Inventory
B. More than 50 years old B. 1. The structure is a unique or rare example of an architectural design, detail or historical type o A unique or rare example of a historical type, the single -
family home that initiated residential development in the Wilshire-Montana neighborhood in the 1920s;
o A unique or rare variation of typical Craftsman bungalow design, with a band of windows instead of an open front porch facing the street.

B. 2. The structure is representative of a style in the City that is no longer prevalent.
11/19/2025
19 1125 18 TH ST.

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Packet Pg. 1822 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure 1 David Yakobson
From: Elizabeth Pomeroy <[email protected]> Sent: Tuesday, November 18, 2025 1:26 PM
To: councilmtgitems
Subject: Letter Regarding Reference item 12A

EXTERNAL
Dear Members of the Santa Monica City Council,
I am writing to respectfully urge the Council to preserve the bungalow residence 1125 18th St. currently under consideration for redevelopment, and to formally recognize its historic significance. This property represents a rare and increasingly endangered example of a once-common architectural style that played a central role in shaping Santa Monica’s early residential identity.

Bungalow homes were foundational to the development of Santa Monica in the early twentieth century. Designed with modest scale, thoughtful craftsmanship, and a human-centered approach to living, these homes reflect the cultural values and architectural traditions of the city’s formative years. Right now, it is reported that there are only about 27 bungalow homes in Santa Monica. If we keep allowing these to be demolished, this number is going to get smaller and smaller, and a huge part of our city’s history will be gone forever. This is not an exaggeration. Once a historic building is gone, it can not be replaced.

At the same time, Santa Monica has experienced substantial growth in large-scale development. The City currently has 39 projects in its development pipeline, with approximately two-thirds already approved and 23% under construction. Furthermore, over 2,300 new multifamily units are presently being built. How many more do we need? How many more are going to replace the houses and homes that make up this city’s history? These new developments change what Santa Monica is to so many of us.What the City is rapidly losing are the small, historic, single-story homes that once gave our neighborhoods their distinctive character.

Preserving this bungalow is not an impediment to progress; rather, it is an opportunity to ensure that progress does not come at the expense of our cultural and architectural heritage. Historic buildings enrich our community, provide continuity across generations, and maintain the diversity of scale and design that make Santa Monica a unique and livable city.

I respectfully request that the Council give full and careful consideration to the historic value of this property at 1125 18th St. and take appropriate action to protect it. Once lost, this piece of our history cannot be recovered. By preserving it, the City affirms its commitment to honoring its past while thoughtfully shaping its future.

Thank you for your attention and for your continued service to the residents of Santa Monica.

Respectfully,
Liz Pomeroy
1117 18th St. Santa Monica
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1823 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, November 18, 2025 11:57 AM
To: councilmtgitems; Lana Negrete; Ellis Raskin; Caroline Torosis; Jesse Zwick; Dan Hall; Natalya Zernitskaya; Barry Snell
Cc: Oliver Chi; Heidi von Tongeln
Subject: City Council 11/19/25 - Item 12A - Appeal of Decision by Landmarks Commission - DENY Appeal and Uphold the Structure of Merit Designation of 1125 18th Street

EXTERNAL
Mayor Negrete and City Councilmembers,
In the Landmarks Commission meeting on July, 14th when 1125 18th Street was approved as a Structure of Merit. It is so disappointing to see this Appeal put forth by Pam O’Connor, a Landmarks Commissioner, and why so many of us opposed her appointment to that commission.

I request that the City Council DENY THE APPEAL and UPHOLD THE STRUCTURE OF MERIT DESIGNATION OF 1125 18th Street.

The appellant’s appeal analysis is flawed and refuted as follows:

1. Appellant states that the staff report and the City’s historic preservation consultant finds that the property does not meet the City’s criteria for designation as a Structure of Merit.

Refutation: On July 14, 2025 the Planning Commission held a public hearing and in a 4-2 vote designated the front residence as a Structure of Merit under Criteria A, B1 and B2. SMMC 9.56.80 makes clear the Landmark Commission’s authority to designate structures of merit and their disposition. It gives no such power to City Staff or City’s consultants.

2. The appeal states that the “The Structure of Merit Designation is flawed.” Refutation: Staff and appellant argue that 1125 18th Street is not eligible for Structure of Merit under any of criteria - A, B1 and B2. It must only meet one and it meets all three criteria.

Criterion A – The structure has been identified in the City’s Historic Resources inventory as eligible for Structure of Merit designation.

Per the staff report “As the subject residence is identified in the City of Santa Monica’s 2018 HRI updates as a potentially eligible resource for local listing, it technically meets the wording of this criterion.”
Criterion B(1) – The structure is a minimum of 50 years of age and the structure is a unique or rare example of an architectural design, detail or historical type.

Per the staff report the subject building was constructed in 1923 and therefore is more than 50 years of age. In the original staff report the following description was made regarding 1125 18th Street – “The Craftsman bungalow remains a relatively uncommon building type within the neighborhood, Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1824 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 specifically the Green Acres Tract of the Wilshire Montana Neighborhood. 1125 18th Street, a small modest, vernacular Craftsman style bungalow appears to represent a rare or unique example of its type within this area of Santa Monica.” (page 13-14 of 22). Both state preservation standards and local practice allow rarity to be assessed within a neighborhood.

Criterion B(2) – The structure is representative of a style in the City that is no longer prevalent.

The staff report states “The structure is representative of a style in the City that is no longer prevalent. 1125 18th Street is an example of a modest vernacular Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first two decades of the 20th century. 1125 18th Street is single-family one-story Craftsman home representing a style that is no longer prevalent in the Wilshire Montana neighborhood, specifically the Green Acres Tract.” The breadth of the Wilshire Montana neighborhood is an R3 and R2 neighborhood with mostly 2-4 story multifamily apartment and condo buildings. My perspective and survey of the Wilshire Montana neighborhood is that this structure IS REPRESENTATIVE of a style no longer prevalent in our neighborhood, the densest in Santa Monica. A single family one-story Craftsman home is rare in the Wilmont Montana neighborhood and is especially rare on the east side of our neighborhood.

Please help the community save our city and protect this Structure of Merit at 1125 18th Street.

Regards,
Nikki Kolhoff
Santa Monica Resident
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1825 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 David Yakobson
From: Bruce Pomeroy <[email protected]>
Sent: Tuesday, November 18, 2025 11:59 AM
To: councilmtgitems
Subject: 1125 18th Street Structure of Merit Designation Appeal (25ENT-0135)

EXTERNAL
City Clerk and Members of the City Council,
I am strongly opposed to the demolition of the craftsman bungalow home at 1125 18th Street. I would hope the City would be opposed as well.

The character of the City – and the vision expressed on the City’s website – are challenged by rampant, dense development. The City’s website appropriately states that the City:
“Discourages demolition of structures that contribute to defining the character of the City and the distinguishing features and diversity of existing residential neighborhoods by protecting characterdefining buildings, historic resources, and older smaller scale multi-unit structures.” The City website also states that demolition is not permitted “for structures over 40 years of age and identified on the City’s Historic Resources Inventory.” The craftsman bungalow on the subject site is over 50 years of age and IS on the City’s Historic Resources Inventory.

Please aƯirm that the home is a structure of merit and deny it demolition.

Thank you,
Bruce Pomeroy
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1826 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: Wendy Radwan
Sent: Tuesday, November 18, 2025 8:30 AM
To: Stephanie Reich; Regina Szilak; councilmtgitems
Subject: FW: City Council 11/19/25 - Item 12A - Appeal of Decision by Landmarks Commission - DENY Appeal and Uphold the Structure of Merit Designation of 1125 18th Street in Wilshire Montana Neighborhood
Hi,
Please see public comment below for Item 12A for the 12/19 Council meeting.

Stephanie, I’ve saved this to the project Address file.

Thank you,
Wendy
Wendy Radwan
Staff Assistant III
Notary Public
santamonica.gov
Facebook | Twitter | Instagram
Reach the City Planning team anytime at 311!
From: [email protected] <[email protected]>
Sent: Tuesday, November 18, 2025 8:19 AM
To: [email protected]
Subject: Fwd: City Council 11/19/25 - Item 12A - Appeal of Decision by Landmarks Commission - DENY Appeal and Uphold the Structure of Merit Designation of 1125 18th Street in Wilshire Montana Neighborhood

EXTERNAL
From the head of Wilmont, Elizabeth Van Denburgh:

From: [email protected]
To: [email protected], [email protected], [email protected], [email protected], [email protected], [email protected],
[email protected], [email protected] Sent: 11/18/2025 12:23:59 AM Pacific Standard Time
Subject: City Council 11/19/25 - Item 12A - Appeal of Decision by Landmarks Commission - Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1827 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 DENY Appeal and Uphold the Structure of Merit Designation of 1125 18th Street in Wilshire Montana Neighborhood
Mayor Negrete and City Councilmembers,
In the Landmarks Commission meeting on July, 14th when 1125 18th Street (see photo below) was approved as a Structure of Merit, I represented the Wilmont Board who strongly supported the Structure of Merit designation. In this letter, I speak only for myself regarding the Appeal put forth by Pam O’Connor, Landmarks Commissioner.

I respectfully request that the City Council DENY THE APPEAL and UPHOLD THE STRUCTURE OF MERIT DESIGNATION OF 1125 18th Street.

The Wilmont Montana neighborhood is bounded by Ocean Blvd. on the West, Montana Ave. on the north, Wilshire Blvd. on the South and 21st Street on the East. It’s a large chunk of real estate. This is my refutation of the appellant’s and the appeal analysis

1. Appellant states that the staff report and the City’s historic preservation consultant finds that the property does not meet the City’s criteria for designation as a Structure of Merit.

Refutation: On July 14, 2025 the Planning Commission held a public hearing and in a 4-2 vote designated the front residence as a Structure of Merit under Criteria A, B1 and B2. SMMC 9.56.80 makes clear the Landmark Commission’s authority to designate structures of merit and their disposition. It gives no such power to City Staff or City’s consultants.

2. The appeal states that the “The Structure of Merit Designation is flawed.” Refutation: Staff and appellant argue that 1125 18th Street is not eligible for Structure of Merit under any of criteria - A, B1 and B2. It must only meet one and it meets all three criteria.

Criterion A – The structure has been identified in the City’s Historic Resources inventory as eligible for Structure of Merit designation.

Per the staff report “As the subject residence is identified in the City of Santa Monica’s 2018 HRI updates as a potentially eligible resource for local listing, it technically meets the wording of this criterion.” Criterion B(1) – The structure is a minimum of 50 years of age and the structure is a unique or rare example of an architectural design, detail or historical type.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1828 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 Per the staff report the subject building was constructed in 1923 and therefore is more than 50 years of age. In the original staff report the following description was made regarding 1125 18th Street – “The Craftsman bungalow remains a relatively uncommon building type within the neighborhood, specifically the Green Acres Tract of the Wilshire Montana Neighborhood. 1125 18th Street, a small modest, vernacular Craftsman style bungalow appears to represent a rare or unique example of its type within this area of Santa Monica.” (page 13-14 of 22). Both state preservation standards and local practice allow rarity to be assessed within a neighborhood.

Criterion B(2) – The structure is representative of a style in the City that is no longer prevalent.

The staff report states “The structure is representative of a style in the City that is no longer prevalent. 1125 18th Street is an example of a modest vernacular Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first two decades of the 20th century. 1125 18th Street is single-family one-story Craftsman home representing a style that is no longer prevalent in the Wilshire Montana neighborhood, specifically the Green Acres Tract.” The breadth of the Wilshire Montana neighborhood is an R3 and R2 neighborhood with mostly 2-4 story multifamily apartment and condo buildings. My perspective and survey of the Wilshire Montana neighborhood is that this structure IS REPRESENTATIVE of a style no longer prevalent in our neighborhood, the densest in Santa Monica. A single family one-story Craftsman home is rare in the Wilmont Montana neighborhood and is especially rare on the east side of our neighborhood.

Many thanks,
Elizabeth Van Denburgh
Wilmont Chair (speaking only for myself)
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1829 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 4 1125 18th Street - Wilshire Montana Neighborhood
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1830 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: Juan Matute <[email protected]>
Sent: Monday, November 17, 2025 4:47 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Item 12A - Please Deny Structure of Merit Designation Attachments: Mills Act List 11-3-2025.xlsx

EXTERNAL
Please uphold the appeal and deny the Structure of Merit designation for 1125 18th Street.

The building is not a good example of the Craftsman architectural style. It is not a rare example of the style. Over 170 Craftsman buildings were identified as eligible for full landmark status in the City’s historic resource survey.

In addition to upholding the appeal, please consider giving direction to abolish the Structure of Merit category. Recent Structure of Merit designated properties — which do not meet the criteria to be designated as Landmarks — have entered into Mills Act contracts resulting in reduced revenues for City services and funding to our schools. Also, the Structure of Merit category is a misuse of historic preservation which creates a barrier to establishing new housing.

In my spare time, I’m working on an analysis of the avoided government revenues from the 104 Mills Act contracts in Santa Monica (attached). This will take me some time you would like it faster, please instruct staff to create an analysis.

Here is how one landmarked property on the list that is currently for sale is being marketed on the Multiple Listing Service:

A rare opportunity for investors: 1047 9th Street is a Mills Act property, offering significant property tax savings that directly improve net operating income, making this a uniquely attractive turnkey investment in Santa Monica's coveted Wilshire Montana neighborhood. This historic compound consists of three fully updated bungalows on a single lot, each with private outdoor space, in-unit laundry, and two parking spaces with EV-charging capability. These modern amenities, paired with classic architectural charm, ensure strong tenant appeal and low vacancy.

The location boasts an A+ walkability score, just steps from Montana Avenue's premier shopping, dining, fitness studios, and a short stroll to the beach, offering lifestyle convenience that commands premium rental rates. Beyond its current stability, the property also presents clear value-add potential: entitlements allow for the addition of one to two two-bedroom units, with projected rental upside of up to $120,000 annually, while preserving its historic character. This is an exceptional opportunity to acquire a cash-flowing, tax-advantaged asset in one of Santa Monica's most desirable neighborhoods, blending immediate returns with long-term growth potential.

Drive-by only. Interior access provided with accepted offer. Please do not disturb tenants. * Listing Agent 4: Bridgette Campbell, DRE 02187270 | Christie's RE SoCal, DRE 01527644 Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1831 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 —
If the council doesn’t think it is in the public interest for Mills Act tax advantages to be captured by “investors,” then I think it’s time for the city to reconsider the Structure of Merit designation and include a cost-benefit analysis for future Mills Act contracts that considers whether such tax advantages are capitalized and sold to investors, rather than rewarding an owner for historicallyappropriate property maintenance.

Sincerely,
Juan Matute
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1832 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Mills Act Contracts
Property Address Effective Year Application # Zip
130 Adelaide Drive 1998 LCMA-9701 90402
2402 Fourth St., #6 1999 LCMA-9801 90405
2523 Third Street 1999 LCMA-9802 90405
2402 Fourth St., #9 1999 LCMA-9803 90405
2402 Fourth St., #7 1999 LCMA-9804 90405
2402 Fourth St., #14 1999 LCMA-9805 90405
2608 Third Street 2002 LCMA-01-01 90405
2450 Twenty-fifth Street2002 LCMA-01-02 90405
2402 Fourth St., #1 2002 LCMA-01-03 90405
315 Tenth Street 2003 LCMA-02-01 90402
211 Alta Avenue 2003 LCMA-02-02 90402
2402 Fourth St., #2 2003 LCMA-02-03 90405
2612 Third Street 2003 LCMA-02-04 90405
2402 Fourth St., #3 2004 LCMA-02-05 90405
317 Georgina Avenue 2004 LCMA-03-01 90402
555 Seventh Street 2004 LCMA-03-02 90402
2607 Third Street 2004 LCMA-03-03 90405
502 Raymond Avenue 2004 LCMA-03-04 90405
140 Hollister Ave.,#1 2005 04MA-001 90405
140 Hollister Ave., #2 2005 04MA-002 90405
140 Hollister Ave., #3 2005 04MA-003 90405
140 Hollister Ave., #4 2005 04MA-004 90405
2034 La Mesa Drive 2005 04MA-005 90402
147 Georgina Avenue 2005 04MA-006 90402
2511 Beverley Avenue 2005 04MA-007 90405
2402 Fourth St., #4 2005 04MA-008 90405
2621 Second Street 2005 04MA-009 90405
822 Third Street 2005 04MA-010 90403
406 Adelaide Drive 2005 04MA-011 90402
331 Palisades Avenue 2006 05MA-001 90402
710 Adelaide Place 2006 05MA-002 90402
1911 La Mesa Drive 2006 05MA-003 90402
1333 Ocean Avenue 2006 05MA-004 90403
1337 Ocean Avenue 2006 05MA-005 90403
2619 Third Street 2006 05MA-006 90405
404 Georgina Avenue 2006 05MA-007 90402
142 Adelaide Drive 2006 05MA-008 90402
2614 Second Street 2007 06MA-001 90405
501 Twenty-Fourth Street2007 06MA-002 90402
822 Euclid Street 2008 07MA-001 90402
2544 Third Street 2008 07MA-002 90405
2617 Third Street 2009 08MA-001 90405
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1833 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2101 La Mesa Drive 2009 08MA-xxx 90402
514 Palisades Avenue 2009 08MA-002 90402
2219 Ocean Avenue 2010 09MA-001 90405
405 Palisades Avenue 2010 09MA-003 90402
3018 3rd Street 2010 09MA-005 90405
236 Adelaide Drive 2010 09MA-006 90402
2402 Fourth Street #12 2011 10MA-001 90405
2323 5th Street 2011 10MA-003 90405
1063 26th Street 2012 11MA-001 90403
2504 3rd Street 2012 11MA-002 90405
1501-1515 4th Street 2012 11MA-003 90401
2616-2618 3rd Street 2012 11MA-004 90405
642 Kensington Road 2014 13MA-001 90405
1001 3rd Street 2014 13MA-002 90402
128 Hollister Avenue 2014 13MA-003 90405
1602 Georgina Avenue 2015 14MA-002 90402
1047 9th Street 2015 14MA-001 90402
225 Santa Monica Boulevard 2015 14MA-003 90401
947-953 11th Street 2015 14MA-004 90402
401 25th Street 2015 14MA-005 90402
828 7th Street 2016 15ENT-0246 90403
504 Pier Avenue 2017 16ENT-0101 90405
305 Alta Avenue 2017 16ENT-0111 90402
150-156 San Vicente Boulevard 2017 16ENT-0121 90402
212 San Vicente Boulevard2017 16ENT-0123 90402
234 San Vicente Boulevard2017 16ENT-0124 90402
302-312 San Vicente Boulevard 2017 16ENT-0125 90402
437-441 San Vicente Boulevard 2017 16ENT-0126 90402
614-618 San Vicente Boulevard 2017 16ENT-0127 90402
401 Ocean Avenue 2018 17ENT-0137 90402
927 Ocean Avenue 2018 17ENT-0145 90403
909-911 Montana Avenue2018 17ENT-0146 90403
2433 28th Street 2018 17ENT-0152 90405
1659 Ocean Front Walk 2019 17ENT-0151 90401
133 Wadsworth Avenue 2019 18ENT-0135 90405
1305 2nd Street 2019 18ENT-0150 90401
1314 7th Street 2019 18ENT-0223 90401
310-312 Wilshire Boulevard2020 19ENT-0185 90404
451 San Vicente Boulevard2020 19ENT-0200 90402
954 5th Street 2020 19ENT-0208 90403
1129 Ashland Avenue 2020 19ENT-0209 90405
525 Georgina Avenue 2020 19ENT-0210 90402
2518 4th Street 2021 20ENT-0149 90405
2546 3rd Street 2021 20ENT-0174 90405
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1834 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 423 Ocean Avenue 2021 20ENT-0150 90402
608 San Vicente Boulevard2021 20ENT-0147 90402
2524 4th Street 2022 21ENT-0119 90405
2525 4th Street 2022 21ENT-0120 90405
317 Ocean Park Boulevard2022 21ENT-0121 90405
1415 Ocean Avenue 2022 21ENT-0131 90401
124 Hart Avenue 2022 21ENT-0117 90405
2508 4th Street 2022 21ENT-0118 90405
2602 3rd Street 2023 22ENT-0165 90405
818 Grant Street 2024 22ENT-0008 90405
227 Broadway 2024 22ENT-0141 90401
227 Beach Street 2024 22ENT-0152 90405
174 Kinney 2023 22ENT-0133 90405
3014 4th Street 2024 23ENT-0093 90405
518 Adelaide 2025 24ENT-0066 90402
1401 Palisades Beach Road2025 24ENT-0156 90401
1132 Princeton Avenue 2025 24ENT-0090 90403
1138 Princeton Avenue 2025 24ENT-0092 90403
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1835 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 David Yakobson
From: Zennon Ulyate-Crow <[email protected]>
Sent: Monday, November 17, 2025 5:38 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Item 12A - Please Deny Structure of Merit Designation

EXTERNAL
Please uphold the appeal and deny the Structure of Merit designation for 1125 18th Street.

The building is not a good example of the Craftsman architectural style. It is not a rare example of the style. Over 170 Craftsman buildings were identified as eligible for full landmark status in the City’s historic resource survey.

In addition to upholding the appeal please give direction to abolish the Structure of Merit category. Recent Structure of Merit designated properties — which do not meet the criteria to be designated as Landmarks — have entered into Mills Act contracts resulting in reduced revenues for City services and funding to our schools. Also, the Structure of Merit category is a misuse of historic preservation creating a barrier to the production of housing.

Please uphold the appeal and direct staff to abolish the Structure of Merit category.

Sincerely,
All the Best,
Zennon Ulyate-Crow
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1836 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 4 David Yakobson
From: greg chasen <[email protected]>
Sent: Monday, November 17, 2025 6:07 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Item 12A - Please Deny Structure of Merit Designation

EXTERNAL
Please uphold the appeal and deny the Structure of Merit designation for 1125 18th Street. The building is not a good example of the Craftsman architectural style. It is not a rare example of the style. Over 170 Craftsman buildings were identified as eligible for full landmark status in the City’s historic resource survey.

In addition to upholding the appeal please give direction to abolish the Structure of Merit category.

Recent Structure of Merit designated properties — which do not meet the criteria to be designated as Landmarks — have entered into Mills Act contracts resulting in reduced revenues for City services and funding to our schools.

Also, the Structure of Merit category is a misuse of historic preservation creating a barrier to the production of housing. Please uphold the appeal and direct staff to abolish the Structure of Merit category.

Sincerely,
Greg Chasen
1318 10th St
Santa Monica, Ca 90401
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1837 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 5 David Yakobson
From: David Sonnenschein <[email protected]>
Sent: Monday, November 17, 2025 6:50 PM
To: councilmtgitems
Subject: 25ENT-0135 (Structure of Merit Designation Appeal) - SMCC meeting Nov. 18, 2025

EXTERNAL
25ENT-0135 (Structure of Merit Designation Appeal)
1125 18th Street
APPELLANT: Pam O'Connor
APPLICANT: Santa Monica Conservancy
PROPERTY OWNER: Houshmand Joseph Naim
Public Comments for Santa Monica City Council Meeting, Nov. 18, 2025
Submitted by:

David Sonnenschein
Resident, 1127 18th Street, #4
Santa Monica, CA 90403
Re: Opposition to Demolition and Redevelopment at 1125 18th Street Honorable Mayor and Councilmembers,
My name is David Sonnenschein, and I live at 1127 18th Street, directly adjacent to the property at 1125 18th Street, the subject of a pending demolition proposal. I am here today to express my strong objection—shared by several neighbors on our block—to the demolition of the existing single-story residence and its long-standing garden.

We ask the City Council to intervene, to pause the approval process, and to ensure that this property receives a full and fair review for preservation under Santa Monica’s conservation guidelines. Our concerns fall under four key areas:

1. Historical and Cultural Significance
The existing home at 1125 18th Street is a clear candidate for recognition as a Structure of Merit. Its human scale, intact architectural character, and compatibility with the surrounding neighborhood contribute to the historic fabric of this area. Demolishing structures like this accelerates the erosion of Santa Monica’s identity and replaces it with oversized, unsustainable development.

2. Environmental and Health Impacts
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1838 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 6 The property contains mature greenery that plays a real ecological role—cooling the block, supporting native plants and wildlife, and improving air quality. Removing this green space to replace it with a multistory structure and subterranean garage will increase heat, dust, noise, and pollution both during construction and long after it is complete. In a city committed to sustainability, eliminating functional green space is counterproductive.

3. Parking and Infrastructure Strain
Parking in our neighborhood is already extremely constrained. Several large multi-unit developments on nearby Wilshire Boulevard have yet to be completed and will add substantial pressure on both permit and street parking. Approving another dense project without addressing cumulative infrastructure impacts will worsen daily challenges for existing residents.

4. Neighborhood Character and Quality of Life
The proposed development—expected to be at least a two-story, six-unit condominium with an underground garage—would dramatically alter the character of this residential street. It threatens to reduce light, privacy, and peace for adjacent homes. Once such large replacements begin, they set a precedent for more demolitions, accelerating the loss of livability in established neighborhoods like ours.

Request to City Council
We respectfully ask the Council to:

1. Suspend demolition approval until a full historical and conservation review is conducted.

2. Evaluate sustainable and community-aligned alternatives that preserve the environmental and cultural value of the existing property.

3. Protect the character and wellbeing of the 18th Street community, whose residents care deeply about Santa Monica’s heritage and natural beauty.

Thank you for listening to our concerns and for your commitment to thoughtful stewardship of our city.

Submitted by:

David Sonnenschein, on behalf of concerned neighbors of 18th Street Santa Monica, CA 90403
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1839 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 7 David Yakobson
From: Annie Goeke <[email protected]>
Sent: Monday, November 17, 2025 7:46 PM
To: councilmtgitems
Subject: SM City Council Mtg 11/18/25 - comments to submit about 25ENT-0135 (Structure of Merit Designation Appeal)

EXTERNAL
25ENT-0135 (Structure of Merit Designation Appeal)
1125 18th Street
APPELLANT: Pam O'Connor
APPLICANT: Santa Monica Conservancy
PROPERTY OWNER: Houshmand Joseph Naim
Public Comment from Anne Goeke (former Commissioner for COSW) Santa Monica City Council – Nov. 18, 2025
Re: 1125 18th Street – Opposition to Demolition
Honorable Mayor and Council members,
As someone who has been locally involved with Santa Monica - both as Chair Commission of COSW and Board of SM Chamber of Commerce, I urge you to pause the demolition proposal for 1125 18th Street.

This small home and its long-standing garden represent exactly the kind of human-scale, ecologically grounded neighborhood fabric that cities like Santa Monica are rapidly losing.

1. Cultural and Community Value
The home reflects the history and identity of this neighborhood. Preserving structures like this supports community continuity of our shared heritage.

2. Environmental Importance
The mature trees and garden serve as natural cooling, habitat, and air-quality buffers, critical in a warming climate. Removing them for dense development contradicts the city’s sustainability goals.

3. Neighborhood Impacts
Construction of a multi-story, multi-unit project with subterranean parking will intensify pressure on already strained infrastructure, including parking, noise, and traffic. These cumulative impacts must be fully evaluated. Especially as Wilshire, half a block away, has multiple large apartment buildings being constructed in the next few years.

4. Quality of Life and Precedent
Allowing this demolition opens the door to a pattern of oversized redevelopment that threatens light, privacy, and livability for long-term residents. This is something that more and more SM residents are recognizing is a negative impact on our neighborhood.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1840 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 8 Request
I respectfully ask the Council to halt demolition approval until a complete historical and environmental review is conducted and to explore alternatives that align with community wellbeing and ecological stewardship.

Thank you for your commitment to protecting Santa Monica’s neighborhoods and natural assets. — Anne Goeke
Annie de la Bouillerie Goeke
International Consultant
To learn more: LinkedIn
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1841 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 9 David Yakobson
From: Dustin Shahan <[email protected]>
Sent: Monday, November 17, 2025 8:08 PM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Item 12A - Please Deny Structure of Merit Designation

EXTERNAL
Good evening council,
Please uphold the appeal and deny the Structure of Merit designation for 1125 18th Street.

The building is not a good example of the Craftsman architectural style. It is not a rare example of the style. Over 170 Craftsman buildings were identified as eligible for full landmark status in the City’s historic resource survey.

In addition to upholding the appeal please give direction to abolish the Structure of Merit category.

Recent Structure of Merit designated properties — which do not meet the criteria to be designated as Landmarks — have entered into Mills Act contracts resulting in reduced revenues for City services and funding to our schools. Also, the Structure of Merit category is a misuse of historic preservation creating a barrier to the production of housing.

Please uphold the appeal and direct staff to abolish the Structure of Merit category.

Sincerely,
Dustin Shahan
90401
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1842 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 10 David Yakobson
From: Elizabeth Van Denburgh <[email protected]>
Sent: Tuesday, November 18, 2025 12:24 AM
To: Lana Negrete; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Dan Hall; Jesse Zwick; Caroline Torosis; councilmtgitems
Subject: City Council 11/19/25 - Item 12A - Appeal of Decision by Landmarks Commission - DENY Appeal and Uphold the Structure of Merit Designation of 1125 18th Street in Wilshire Montana Neighborhood

EXTERNAL
Mayor Negrete and City Councilmembers,
In the Landmarks Commission meeting on July, 14th when 1125 18th Street (see photo below) was approved as a Structure of Merit, I represented the Wilmont Board who strongly supported the Structure of Merit designation. In this letter, I speak only for myself regarding the Appeal put forth by Pam O’Connor, Landmarks Commissioner.

I respectfully request that the City Council DENY THE APPEAL and UPHOLD THE STRUCTURE OF MERIT DESIGNATION OF 1125 18th Street.

The Wilmont Montana neighborhood is bounded by Ocean Blvd. on the West, Montana Ave. on the north, Wilshire Blvd. on the South and 21st Street on the East. It’s a large chunk of real estate. This is my refutation of the appellant’s and the appeal analysis

1. Appellant states that the staff report and the City’s historic preservation consultant finds that the property does not meet the City’s criteria for designation as a Structure of Merit.

Refutation: On July 14, 2025 the Planning Commission held a public hearing and in a 4-2 vote designated the front residence as a Structure of Merit under Criteria A, B1 and B2. SMMC 9.56.80 makes clear the Landmark Commission’s authority to designate structures of merit and their disposition. It gives no such power to City Staff or City’s consultants.

2. The appeal states that the “The Structure of Merit Designation is flawed.” Refutation: Staff and appellant argue that 1125 18th Street is not eligible for Structure of Merit under any of criteria - A, B1 and B2. It must only meet one and it meets all three criteria.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1843 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 11 Criterion A – The structure has been identified in the City’s Historic Resources inventory as eligible for Structure of Merit designation.

Per the staff report “As the subject residence is identified in the City of Santa Monica’s 2018 HRI updates as a potentially eligible resource for local listing, it technically meets the wording of this criterion.”
Criterion B(1) – The structure is a minimum of 50 years of age and the structure is a unique or rare example of an architectural design, detail or historical type.

Per the staff report the subject building was constructed in 1923 and therefore is more than 50 years of age. In the original staff report the following description was made regarding 1125 18th Street – “The Craftsman bungalow remains a relatively uncommon building type within the neighborhood, specifically the Green Acres Tract of the Wilshire Montana Neighborhood. 1125 18th Street, a small modest, vernacular Craftsman style bungalow appears to represent a rare or unique example of its type within this area of Santa Monica.” (page 13-14 of 22). Both state preservation standards and local practice allow rarity to be assessed within a neighborhood.

Criterion B(2) – The structure is representative of a style in the City that is no longer prevalent.

The staff report states “The structure is representative of a style in the City that is no longer prevalent. 1125 18th Street is an example of a modest vernacular Craftsman bungalow, which was a building type prevalent in the City of Santa Monica through the first two decades of the 20th century. 1125 18th Street is single-family one-story Craftsman home representing a style that is no longer prevalent in the Wilshire Montana neighborhood, specifically the Green Acres Tract.” The breadth of the Wilshire Montana neighborhood is an R3 and R2 neighborhood with mostly 2-4 story multifamily apartment and condo buildings. My perspective and survey of the Wilshire Montana neighborhood is that this structure IS REPRESENTATIVE of a style no longer prevalent in our neighborhood, the densest in Santa Monica. A single family one-story Craftsman home is rare in the Wilmont Montana neighborhood and is especially rare on the east side of our neighborhood.

Many thanks,
Elizabeth Van Denburgh
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1844 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 12 Wilmont Chair (speaking only for myself)
1125 18th Street - Wilshire Montana Neighborhood
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1845 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: Cynthia Rose <[email protected]>
Sent: Monday, November 17, 2025 2:21 PM
To: councilmtgitems; Council Mailbox; Lana Negrete; Caroline Torosis; Jesse Zwick; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Dan Hall; Oliver Chi Subject: Agenda item 12A

EXTERNAL
Dear Santa Monica City Council
I’m writing as an impacted community member to support upholding the appeal of the designations of a Structure Merit for 1125 18th Street and to reject the proposed inappropriate designation for a building that does not represent a good example of the Craftsman architectural style.

Over 170 Craftsman buildings have been identified as eligible for full landmark status in the City’s historic resource survey — 1125 18th Street is not a rare example of the style.

In addition to supporting upholding the appeal, please also consider direction to staff to abolish the Structure of Merit category completely. Recently —through what should be considered inappropriate use of Structure of Merit Designations —properties which do not meet the criteria have been designated as Landmarks. These properties have now unfairly entered into Mills Act contracts and will result in reduced revenues for our City services and reduced funding for our schools at time when every dollar counts.

This misuse of the Structure of Merit in a historic preservation category depletes needed City revenue and creates an inappropriate barrier to the critical production of much needed housing.

In conclusion: please uphold the appeal and direct staff to abolish the Structure of Merit category — an action that will prevent its misuse moving forward with inappropriate designations that result in unfairly reducing revenue and increased barriers to building housing both of which support the needs of our community.

With respect and gratitude,
Cynthia Rose
Sent from imobile device, please excuse random acts of autocorrect....

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1846 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 David Yakobson
From: Cynthia Rose <[email protected]>
Sent: Monday, November 17, 2025 2:15 PM
To: councilmtgitems; Council Mailbox; Lana Negrete; Caroline Torosis; Jesse Zwick; Ellis Raskin; Barry Snell; Natalya Zernitskaya; Dan Hall; Oliver Chi Subject: Agenda item 12A

EXTERNAL
Dear Santa Monica City Council
I’m writing as an impacted community member to support upholding the appeal of the designations a Structure Merit for 1125 18th Street and reject the proposed inappropriate designation for a building that does not represent a good example of the Craftsman architectural style.

Over 170 Craftsman buildings have been identified as eligible for full landmark status in the City’s historic resource survey — 1125 18th Street is not a rare example of the style.

In addition to supporting you to upholding the appeal, please also consider direction to staff to abolish the Structure of Merit category completely. Recently —through what appears to be inappropriate use of Structure of Merit Designations —properties which do not meet the criteria have been designated as Landmarks. These properties have now unfairly entered into Mills Act contracts and will result in reduced revenues for our City services and funding for our schools at time when every dollar counts.

This misuse of the Structure of Merit in a historic preservation category depletes needed City revenue and creates an inappropriate barrier to the critical production of much needed housing.

In conclusion: please uphold the appeal and direct staff to abolish the Structure of Merit category — an action that will prevent its misuse moving forward with inappropriate designations that result in unfairly reducing revenue and increase barriers to building housing which support the needs of our community.

With respect and gratitude,
Cynthia Rose
Sent from imobile device, please excuse random acts of autocorrect....

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1847 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: Eli Gill <[email protected]>
Sent: Monday, November 17, 2025 11:30 AM
To: Lana Negrete; Caroline Torosis; Jesse Zwick; Dan Hall; Ellis Raskin; Barry Snell; Natalya Zernitskaya; councilmtgitems
Subject: Item 12A - Please Deny Structure of Merit Designation

EXTERNAL
Please uphold the appeal and deny the Structure of Merit designation for 1125 18th Street.

The building is not a good example of the Craftsman architectural style. It is not a rare example of the style. Over 170 Craftsman buildings were identified as eligible for full landmark status in the City’s historic resource survey.

In addition to upholding the appeal please give direction to abolish the Structure of Merit category.

Recent Structure of Merit designated properties — which do not meet the criteria to be designated as Landmarks — have entered into Mills Act contracts resulting in reduced revenues for City services and funding to our schools. Also, the Structure of Merit category is a misuse of historic preservation creating a barrier to the production of housing.

Please uphold the appeal and direct staff to abolish the Structure of Merit category.

Sincerely,
Eli Gill
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1848 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 David Yakobson
From: Ruthann Lehrer <[email protected]>
Sent: Monday, November 17, 2025 11:33 AM
To: councilmtgitems; [email protected]
Cc: Sharon Bialy
Subject: Re: comment on 25ENT-0135 1125 18th St Structure of Merit from Neil Risch

EXTERNAL
Item 12A
On Monday, November 17, 2025 at 11:31:25 AM PST, [email protected] <[email protected]> wrote:

Dear Santa Monica City Council,
Attached please find my comments on action 25ENT-0135, the appeal of the Landmarks Commission decision on Structure of Merit for 1125 18th St, Santa Monica.

Sincerely yours,
Neil Risch
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1849 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 David Yakobson
From: [email protected]
Sent: Monday, November 17, 2025 11:30 AM
To: councilmtgitems
Cc: Ruthann Lehrer; Sharon Bialy
Subject: comment on 25ENT-0135 1125 18th St Structure of Merit from Neil Risch Attachments: Comment_on_25ENT-0135.docx

EXTERNAL
Dear Santa Monica City Council,
Attached please find my comments on action 25ENT-0135, the appeal of the Landmarks Commission decision on Structure of Merit for 1125 18th St, Santa Monica.

Sincerely yours,
Neil Risch
Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1850 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Comments on the Appeal of the Structure of Merit Designation of 1125 18th Street Submitted by Neil Risch, Resident of 18th Street
I. Introduction
My name is Neil Risch, and I live in the immediate neighborhood of 1125 18th Street. I have been following this property and the broader preservation context of the Wilshire-Montana (Wilmont) area for many years. I submitted testimony during the Landmarks Commission hearing in July, and I am writing again now to urge the City Council to uphold the Commission’s vote designating the property as a Structure of Merit. My original comments on 25ENT-0069 are addended to the end of this document. I will not reiterate those comments but respond specifically to this appeal (25ENT-0135) from Commissioner O’Connor as well as the supporting staff report from Stephanie Reich.

As I wrote earlier, I care deeply about the character of this neighborhood, the few remaining early houses (especially the craftsman ones, which are particularly scarce now) that tell the story of its development, and the fair and consistent application of our historic preservation ordinance. My comments reflect personal knowledge of the area, review of the administrative record, and my own research, including a map I prepared of all Craftsman houses in Wilmont (attached as Exhibit A). I have walked the entire Wilmont neighborhood, seen and photographed all 30 craftsman houses listed in the HRI as eligible for Landmark or Structure of Merit status, and thus have a perspective on their prevalence and distribution across Wilmont.

For the record, I’m going to start by providing some documentation regarding this process.

First, a description of the authority of the Landmarks Commission:
§ 9.56.060 Powers.

In addition to any other powers set forth in this Chapter or in the Zoning Ordinance, the Landmarks Commission shall have the power to:

A. Designate Structures of Merit, Landmarks and Landmark Parcels, and to make any preliminary or supplemental designations, determinations or decisions, as additions thereto, in order to effectuate the purposes of this Chapter. Except as provided in Section

9.56.110, the designation of any improvement as a Structure of Merit, Landmark, or Contributing Building or Structure shall only include the exterior features of the improvement and shall not include any portion of its interior space.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1851 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) B. Conduct studies and evaluations of applications requesting the designation of a Historic District, make determinations and recommendations as such appropriateness for consideration of such applications, and make any preliminary or supplemental designations, determinations or decisions, as additions thereto, in order to effectuate the purposes of this Chapter.

C. Regulate and control the alteration, restoration, construction, removal, relocation or demolition, in whole or in part, of or to a Structure of Merit, a Landmark or Landmark Parcel, or of or to a building or structure within a Historic District, and make any preliminary or supplemental designations, determinations, decisions, as additions thereto, in order to effectuate the purposes of this Chapter.

This code makes clear the Landmark Commissions’ authority to designate structures of merit and their disposition.

Next, from the Santa Monica Code of Ordinances, here again are the criteria for Structures of Merit:
§ 9.56.080 Structure of Merit Criteria.

For the purposes of this Chapter, an improvement may be designated a Structure of Merit if the Landmarks Commission determines that it merits official recognition because it has one of the following characteristics:

A. The structure has been identified in the City's Historic Resources Inventory.

B. The structure is a minimum of 50 years of age and meets one of the following criteria:

1. The structure is a unique or rare example of an architectural design, detail or historical type.

2. The structure is representative of a style in the City that is no longer prevalent.

3. The structure contributes to a potential Historic District.

Because Criterion A above involves the Historic Resources Inventory, it is important to note its definition and characteristics from the Santa Monica City Website:
“The Historic Resources Inventory (HRI) is a database containing building descriptions and evaluations of potential historic resources in Santa Monica. Each property listed on the HRI Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1852 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) has been evaluated by professionals using accepted industry standards and criteria.

City staff uses the HRI to identify properties of potential historic significance.” Because the status of the HRI and its entries have been questioned by the appellant and staff, I have bolded the relevant text – i.e. that properties only enter the HRI if placed there by professionals using accepted industry standards and criteria. In other words, being in the HRI has significant status based on expert opinion.

I will now move on to review the process by which the Landmarks Commission made its determination and the basis of the appeal and staff report.

The Landmarks Commission reviewed extensive evidence, weighed testimony and deliberated at length. All commissioners voiced their opinions, including the appellant Commissioner O’Conner; all opinions were acknowledged and discussed. After the discussion, the Commission adopted formal Findings supporting the designation of the house at 1125 18th St as a Structure of Merit. Four of the six commissioners present voted in favor. Their decision was supported by substantial evidence and meets the requirements of SMMC 9.56.080, as documented both in the minutes of the meeting and in the Findings and Determinations.

The appeal does not demonstrate factual or legal error in this process, which was done strictly according to rules, also acknowledged in the minutes. Rather, the appeal expresses disagreement with the final vote — largely based on policy preferences, misinterpretation of the ordinance, and a misunderstanding of how rarity and representativeness are evaluated under Criteria B.1 and B.2. Disagreement is not grounds for overturning a designation.

For the reasons set forth below, I respectfully suggest that the Council deny the appeal and uphold the Structure of Merit designation.

II. Summary of the Commission’s Action
On July 14, the Landmarks Commission held a duly noticed public hearing on the nomination submitted by the Santa Monica Conservancy for Structure of Merit designation of 1125 18th Street. The Commission:

1. Received testimony from multiple neighbors and community representatives (including me) in support of the nomination.

2. Reviewed the staff report and the report from Page & Turnbull, which were also discussed at the hearing.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1853 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation)

3. Considered the property’s identification in the City’s Historical Resources Inventory (HRI).

4. Discussed the property’s architectural characteristics, integrity, and context within Wilmont and the Green Acres Tract.

5. Deliberated extensively, including clear statements from commissioners explaining why they found Criteria A, B.1, and B.2 satisfied.

6. Voted 4–2 to designate the structure as a Structure of Merit.

7. Adopted written Findings affirming that three criteria were met (A, B1 and B2).

These findings are part of the administrative record and must be given weight. A City Council appeal should not function as a second staff review, as the Landmarks Commission has extensive qualifications, expertise and experience to make their judgment. Rather, it is a review of a formal decision supported by substantial evidence.

III. Applicable Criteria and the Appellant Misstatements A. Only one criterion is required under SMMC 9.56.080
The ordinance states that a Structure of Merit must meet one or more criteria. The Commission found the property met three. The appeal focuses on trying to disprove all three simultaneously, but that is unnecessary; any single satisfied criterion is legally sufficient.

B. The criteria must be applied as written
Nowhere does the ordinance indicate:
• A requirement of architectural “excellence”
• A requirement that the structure be an exemplar of the highest style • A citywide rarity standard
• A requirement that the property be “impeccable” or “just like” houses in Ocean Park or North of Montana
• A limitation excluding modest homes from being Merits Staff and the appellant frequently bring up standards that do not exist in the code.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1854 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) C. Staff and appellant’s arguments about “intent” of entries in the HRI (reflecting the report of Page and Turnbull)
Staff and appellant repeatedly argue that Criterion A was “not intended” to be used as written. If the City wishes to change the criterion, it may amend the ordinance. While the ordinance remains in effect, it must be applied as written — exactly as the Commission did. Furthermore, as I stated above, trying to disqualify entries in the HRI simply because they were only observed superficially is a disservice to the “professionals” who placed the structures into the HRI. Indeed, by contrast, it is striking that of the 6 commissioners at the hearing discussing the house at 1125 18th St, 5 had visited the house and seen it directly – only one did not, and that was the appellant, Commissioner O’Connor. So her judgment was not based on actually seeing the house (while she critiques those who placed it in the HRI, who actually did see it).

D. Substantial Evidence Standard
The question on appeal is not whether the appellant, staff, or even Page & Turnbull disagreed. The question is whether the Commission’s decision is supported by substantial evidence in the record. It is.

IV. Response to the Appeal and Staff Report: Criterion A Criterion A:

A Structure of Merit is a structure that is “identified in the City’s Historical Resources Inventory.”
As described above, this criterion is satisfied on its face as it is listed in the HRI. However, in response to discussion at the Commission hearing, it is NOT the only criterion satisfied – as B1 and B2 are as well.

V. Response to the Appeal and Staff Report: Criterion B.1 (Unique or Rare) B.1:
“The structure represents a unique, rare, or particularly fine example of an architectural, cultural, or historic type.”
The appellant claims that because the house is a modest Craftsman, it cannot be rare. This misunderstands the criterion and the factual record.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1855 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Rarity is evaluated within context, not citywide
Both state preservation standards and local practice allow rarity to be assessed within:
• A neighborhood
• A tract
• A development pattern
• A surviving cluster
• The original context of the building
Staff improperly applies a citywide rarity test — which contradicts the intent of the Structure of Merit category, used precisely to preserve contextually rare resources.

Exhibit A: Craftsman houses in Wilmont
As I mentioned above, I surveyed all 30 craftsman houses in the HRI eligible for 5S3 or 5S3* designation. Several more are listed in the HRI, but they have been demolished or greatly altered and are not included. My attached map (Exhibit A) shows clearly:
• Most Craftsman houses (5S3 and 5S3*) cluster west of 11th Street. • Only three Craftsman houses remain east of 14th Street. The map clearly shows the scarcity of Craftsman houses in the entire eastern part of Wilmont, and extending all the way into Northeast Santa Monica – where none remain. • All three are Structures of Merit.
• In the Green Acres Tract (17th–21st, Wilshire–Washington), only two remain — including 1125 18th Street.

This nullifies the appellant’s assertion that Craftsman bungalows remain “relatively common” in this part of Wilmont. They are extremely rare in the property’s immediate and broader context. I can also attest that the house at 1125 18th Street is unique both in its design and presentation when compared to all other Craftsman houses in Wilmont.

I would also point out that Commissioner O’Connor has argued strenuously in her appeal and at the hearing for the elimination of the Structure of Merit category altogether. In Wilmont, among the remaining Craftsman houses, 16 are considered eligible for Landmark status while 14 are considered eligible for Structure of Merit status. Thus, eliminating the Structure of Merit category would lead to the potential demolition of nearly half the remaining Craftsman houses in Wilmont, and especially deplete entirely the eastern half of the neighborhood.

Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1856 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) The house has unusual architectural features noted by commissioners Commissioners highlighted:
• The front-gabled vernacular form uncommon east of 14th • Original porch massing
• Distinctive rafter tails
• Early 1900s construction within an area largely built up in the 1920s–40s These characteristics combine to make the house rare for its context. The ordinance does not require architectural grandeur — only rarity.

Reliance only on Page & Turnbull is misplaced
Page & Turnbull evaluated rarity based on citywide examples and higher-style Craftsman homes. But Criterion B.1 expressly applies even to “very modest” structures if they are contextually rare — which is exactly what the Commission found. And as I have pointed out, and was missed by Page & Turnbull, the entire eastern half of Wilmont is nearly completely devoid of Craftsman style houses from that era.

VI. Response to the Appeal and Staff Report: Criterion B.2 (Style No Longer Prevalent) B.2:
“The structure represents an architectural style which is no longer prevalent in the city or is no longer being constructed.”
This criterion is also clearly met.

Single-family Craftsman houses in Wilmont are no longer prevalent My exhibit A shows:
• Craftsman houses have been almost entirely eliminated from eastern Wilmont. • The remaining examples exist in scattered, isolated pockets. • In the Green Acres Tract specifically, the house represents one of only two surviving examples of its era and style.

The Commission specifically relied on B.2 in adopting findings Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1857 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) The minutes reflect several commissioners’ statements affirming this criterion, supported by both the HRI and testimony.

VII. Integrity
By all accounts, including the report of Page & Turnbull and acknowledged by the Commissioners, the subject house has all 7 features characterizing being intact; indeed, it is likely rare in that attribute, compared to at least several of the other Craftsman houses in Wilmont, that have been subject to various degrees of alteration (upon my observation).

VIII. Response to NIMBYism and Development arguments of Appellant At the July 14th Landmarks Commission hearing, Commissioner O’Connor argued strenuously that the Structure of Merit nomination was simply NIMBYism. Specifically (one can listen to the recorded audio of the hearing), Commissioner O’Connor, by selfdescription went into a “Rant” over the Structure of Merit Category. She mentions that some of the neighbors in their statements complain about pending parking problems, and that it is going to change the character of the neighborhood. She then states “This clearly is a NIMBY not in my backyard effort.” She then criticizes Structure of Merit altogether. She characterizes this as “We don’t want new development – we don’t want more housing.” She then says that Structure of Merit is just being used to avoid development. She argues to eliminate the Structure of Merit altogether. She says “this is being misused to sap housing production. I think that’s the case with this. Using Structure of Merit this way is obstructionist.”
These comments clearly define the intent of the appeal – which focused on development at the expense of preservation. These comments are incorrect and misplaced in several respects. First, the nomination came from the Santa Monica Conservancy, not from neighbors. The Conservancy has no claim of “not in my backyard.” Second, it was also strongly supported by the Wilmont Coalition, which has broad interests in the entirety of Wilmont and not specifically on 18th St. Third – it is inappropriate to critique comments of individuals in the neighborhood. By ordinance, they were SPECIFICALLY solicited to make comments about the proposed demolition, and it is disrespectful to out of hand negate their interests and concerns.

Furthermore, the disposition of this house has little if anything to do with development.

Indeed, there are many parcels available in Wilmont that could be further developed without destroying historic structures – including an empty lot right across the street at Item 12-A
November 18, 2025

12.A.l
Packet Pg. 1858 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1142 18th St. Indeed, 3 large new apartment complexes are slated for development after demolishing existing structures on Wilshire Blvd within a few blocks of this house. Again, this has nothing to do with stifling development – it has to do with preserving rare historical structures and not sacrificing them when plentiful alternatives exist.

IX. The Commission’s Findings Are Supported by Substantial Evidence The record contains:
• A formal HRI listing (Criterion A)
• Architectural analysis by the Conservancy, supported by the Wilmont Coalition • Public testimony about rarity and context
• A distribution map (Exhibit A) demonstrating contextual rarity • Commissioner statements supporting each finding
• Integrity analysis
• The Commission's adopted Findings
• A 4–2 vote after extended deliberation
This easily meets the substantial evidence standard.

Council may disagree with the Commission, staff may disagree, consultants may disagree — but disagreement is not grounds to overturn a qualified determination.

X. Evolution of Craftsman houses in the HRI
It is also of relevance to examine the evolution of Craftsman houses in the HRI. In the 2010 Survey in the HRI, there were 19 houses in Wilmont with the designation of 5S3* (Structure of Merit). In the 2018 survey, among the 19, 8 are still listed as 5S3*, but 11 (58%) have transitioned to 5S3 (Landmark). This is of critical importance; these 11 houses would have been subject to demolition and potentially no longer in existence if the Structure of Merit had not been in place. We can imagine a similar fate for the majority of Craftsman houses in Wilmont. Indeed, there is a prospect that this house, along with others, may achieve Landmark status in the next update of the HRI.

XI. Conclusion
Item 12-A
November 18, 2025

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Packet Pg. 1859 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1125 18th Street meets three of the criteria for Structure of Merit designation under SMMC

9.56.080 (when, in fact, only one is required). The Landmarks Commission’s decision is grounded in the administrative record, supported by substantial evidence, and consistent with both the letter and purpose of the ordinance. In addition to that, it clearly represents a broad majority opinion. It was the majority expert opinion of the Landmarks Commission (4 to 2), it was the expert opinion of the Santa Monica Conservancy, it was the expert opinion of the Wilmont Coalition, and the expert opinion of the HRI. The minority opinion is far less supported, and the appeal is really centered on criticism of the Structure of Merit designation altogether rather than this particular house. The appellant’s appeal is not in any way substantively different from the opinion she expressed at the Landmarks Commission hearing. In addition, the staff report is also nearly identical to what staff presented at the July 14 hearing. In other words, no new findings or concerns are presented in the appeal or the staff report – simply a reiteration of opinions previously expressed. Restated opinions do not form a valid basis for an appeal.

For these reasons, I respectfully request that the City Council:

DENY THE APPEAL
and
UPHOLD THE STRUCTURE OF MERIT DESIGNATION OF 1125 18th STREET.

Sincerely yours,
Neil Risch
1117 18th St
Santa Monica, CA
Item 12-A
November 18, 2025

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Packet Pg. 1860 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Exhibit A
Item 12-A
November 18, 2025

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Packet Pg. 1861 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Original Comments on 25ENT-0069 Submitted July, 2025
Comment on Agenda Item: 1125 18th Street (25ENT-0069): Structure of Merit Application One thing I appreciate most about Santa Monica is its diversity of architecture - reflecting structures from various eras, representing different styles - so we can actually view the evolution of architecture here. We have buildings over 100 years old alongside art deco, mid-century modern and more modern structures all within the same neighborhoods and streets. I also live on 18th St north of Wilshire, and have walked extensively through most of the streets of WilshireMontana, because I am avid walker – I enjoy frequenting the stores and businesses on Montana Ave and frequently walk to the beach on California, Washington and Idaho. I also walk east through the neighborhood to appreciate the various architectural styles in that direction. So I feel I have a good sense of the varied architecture that exists in this beloved (at least to me) section of Santa Monica.

While development of new housing structures is also important for a thriving Santa Monica, preservation of structures that are rare and reflect the history of development in Santa Monica is also paramount to maintain this longstanding architectural history. I believe that the 103 yearold craftsman style house at 1125 18th St meets exactly that standard of historic and rare, reflecting a craftsman style of architecture that was popular in the early 1920s when the structures were built, but are now sparse in the neighborhood.

The Santa Monica Conservancy, in its nomination of this structure, has laid out in far greater detail than I could the description of the history of the house and its construction, its details, the setting and the neighborhood. I have also read the architectural report from the firm of Page & Turnbull, and will focus primarily on the criteria for Structure of Merit in Santa Monica, and whether they have been met. I say this because there is an apparent discrepancy between what the Conservancy has said about the criteria – and in particular the prevalence and rarity of craftsman structures similar to 1125 18th St, versus what Page & Turnbull has said, and their conclusion.

Again, I don’t feel I need to reiterate the Conservancy’s compelling argument (nor the comments in some of the submitted letters). Rather, I will focus on arguments made by Page & Turnbull, who conclude that the building does not meet criteria for Structure of Merit.

The Santa Monica Code 9.56.080 regarding criteria for Structure of Merit states the following:
“For the purposes of this Chapter, an improvement may be designated a Structure of Merit if the Landmarks Commission determines that it merits official recognition because it has one of the following characteristics:

A.

The structure has been identified in the City's Historic Resources Inventory.

B.

The structure is a minimum of 50 years of age and meets one of the following criteria:

1. The structure is a unique or rare example of an architectural design, detail or historical type.

2. The structure is representative of a style in the City that is no longer prevalent.

3. Item 12-A
November 18, 2025

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Packet Pg. 1862 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) The structure contributes to a potential Historic District.” So, the question appears to be whether the subject house meets either criterion A or B, or both.

I believe it meets both criteria A and B (in disagreement with the report of Page & Turnbull).

Regarding A, it is unequivocal that the subject house, 1125 18th St, exists in Santa Monica’s Historic Resources Inventory, and has since 2018, and so it “has been identified in the City’s Historic Resources Inventory,” seemingly meeting that criterion. However, Page & Turnbull appear to qualify its identification there, as follows:
“As the subject property is identified in the City of Santa Monica’s 2018 Historic Resources Inventory update as a potentially eligible resource for local listing, it technically meets the wording of this criterion. However, it is Page & Turnbull’s opinion that identification as a potential resource in Santa Monica’s Historic Resources Inventory does not alone provide sufficient basis for the individual designation of a property as a Structure of Merit. This criterion recognizes the findings of previous evaluations conducted in support of the inventory and update. It appears to presume that if a property is “identified” in the inventory, it has already been evaluated according to and found significant under at least one of the categories of SMMC 9.56.1080(b) (see below). Therefore, while the property may meet the text of the criterion as written in SMMC § 9.56.080(a), it does not appear to meet the intent of the criterion.” I believe this to be an overreach by Page & Turnbull. They are now subjugating this explicit criterion to the vagueness of “intent” with an “opinion.” I don’t believe it is up to this firm to determine what the original “intent” of this inventory and its designations have been. In fact, as they point out, other entries in the Historic Resources Inventory (specifically 14 craftsman style houses according to my count in the Wilshire-Montana neighborhood) have the same designation. If the Landmarks Commission were to agree with this interpretation of the Code’s explicit statement, that would effectively nullify all structures with similar entries in the entire Historic Resources Inventory including all of Santa Monica.

Now I will discuss item B, and in particular B.1 and B.2 (since the structure under discussion does not lie within a “potential Historic District”). There appears to be a discrepancy here between the arguments proffered by the Conservancy and Page & Turnbull. The Conservancy has stated the following:
“1. The structure is a unique or rare example of an architectural design, detail or historical type. The subject property is a Craftsman bungalow that was constructed late in the time period for that style’s prevalence – 1923 – and has design features that are unique within the typical framework of that style: the offset entryway placed at a side elevation rather than at the front; the small entry porch reduced to frame the front door; the intersecting cross roof gables; the bank of windows on the front façade with crossed muntins which are asymmetrical, lacking the lower muntin.

2. The structure is representative of a style in the City that is no longer prevalent.

Single-family one-story Craftsman homes represent a style that is no longer prevalent.” By contrast, Page & Turnbull have stated the following in their report:
“According to the 2018 Historic Resources Inventory update, 178 Craftsman-style buildings were deemed individually eligible citywide, with 30 of these located in Wilshire Montana. Of those, roughly 20 are comparable in scale and character to 1125 18th Street. Although some have been lost to redevelopment and others altered to the degree that they have lost Item 12-A
November 18, 2025

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Packet Pg. 1863 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) integrity, the modest Craftsman bungalow remains a relatively common building type within the neighborhood.”
I will now discuss this claim of “relatively common building type within the neighborhood.” As I mentioned above, I have walked the Wilshire-Montana neighborhood extensively – and seen all the more recent developments that others have commented on. What I have more closely paid attention to are the older historical structures that still exist. One thing I have noticed is that the western part of Wilshire-Montana seems to have more of these residences than the eastern part. Through investigation, I now understand that my impression has a basis.

I examined the Historic Resources Inventory to identify all craftsman style houses in WilshireMontana. Similar to Page & Turnbull’s findings, I also found 32 such structures (all built between 1906 and 1924), although one had a lack of visibility listing, and another had been demolished since 2018. Of the remaining 30, I then ordered them from west to east, and here is my observation:

Ocean Ave - 1
2nd St - 2
3rd St - 1
4th St - 3
5th St - 5
6th St - 3
California Ave at 6th St – 1
7th St - 2
Lincoln Blvd -1
9th St - 1
California Ave at 9th St – 1
10th St - 2
11th St - 1
14th St - 1
California Ave at 16th St – 1
18th St - 1
19th St - 1
21st St - 1
22nd St - 1
The first thing to notice in the list above is that 19 of the 30 lie west of Lincoln Blvd, and 25 lie west of 14th St. Only 5 lie east of 14th St. Thus, the entire eastern part of Wilshire-Montana is extremely sparse when it comes to craftsman style houses. It appears that while Page & Turnbull correctly determined the number of remaining craftsman houses in Wilshire-Montana, they didn’t further investigate their distribution and density.

But there is another salient issue. Both the Conservancy and Page & Turnbull have documented that 1125 18th St lies within the historic Green Acres section of development, which was from 17th St to 21st St, Wilshire to Washington. According to the above, there remain only 2 existing craftsman houses from that development. If 1125 18th St were demolished, there would be just one remaining, and ultimately potentially none. Allowing for this demolition would effectively eliminate any historic remnants of this style from that era. In other words, evidence suggests that such craftsman style homes from that era are indeed sparse, especially in the eastern part of Wilshire-Montana.

Item 12-A
November 18, 2025

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Packet Pg. 1864 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) In summary, as a person who treasures living in Santa Monica, and especially the neighborhood in which I live, I feel a strong interest in maintaining the ambiance that gives it a special character – and for me, it is the varied, and especially older and historic homes that dot the landscape, of which 1125 18th St is one valued representative. While I, as others, also understand the need for development, I feel that it should be done judiciously so as not to infringe on our history. I do believe that according to the stated criteria in the Santa Monica code regarding the requirements for Structure of Merit status, the evidence indicates that the house at 1125 18th St meets both criteria A and B.

Sincerely yours,
Neil Risch
1117 18th St
Santa Monca, CA
Item 12-A
November 18, 2025

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Packet Pg. 1865 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 4 David Yakobson
From: Tracey Alexander <[email protected]>
Sent: Monday, November 17, 2025 11:51 AM
To: councilmtgitems
Subject: ITEM 12A - Deny the Structure of Merit Designation

EXTERNAL
Hello,
I urge you to please uphold the appeal and deny the Structure of Merit designation for 1125 18th Street. The building is not a good example of the Craftsman architectural style. It is simply not a special or rare example of the style.

Over 170 Craftsman buildings have been identified as eligible for full landmark status in the City's historic resource survey.

In addition to upholding the appeal please give direction to abolish the Structure of Merit category. Recent Structure of Merit designated properties - which do not meet the criteria to be designated as landmarks - have entered into Mills Acts contracts resulting in significantly reduced revenue for Santa Monica City services and the funding of our schools.

This is a moment when the city must focus its resources on economic recovery, fiscal stability and revitalization.

Sincerely,
Tracey Alexander
Housing Advocate Santa Monica Forward
Item 12-A
November 18, 2025

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Packet Pg. 1866 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: [email protected]
Sent: Sunday, November 16, 2025 12:49 PM
To: councilmtgitems
Subject: 1125 18th Street Structure of Merit Designation Appeal (25ENT-0135) - Agenda Item 12A

EXTERNAL
Dear Santa Monica City Council Members,
I'm writing today to urge the City Council to uphold the "Structure of Merit Designation" for the house at 1125 18th Street. This was previously approved by the City's Landmarks Commission during its meeting of July 14, 2025 (see 25ENT-0069). It is my understanding that all 20 written comments made in response to 25ENT-0069 are to be part of the record of the current appeal (25ENT-0135). It is also my understanding that the July 14, 2025 meeting minutes are part of that record.

I attended the July 14 meeting, submitted written comments and spoke at the meeting. I was impressed by the fact that the Commissioners themselves took their own time to visit the property and the surrounding neighborhood prior to the meeting. They did more than just review photographs ! I have lived at the 1125 property for 23 years and am very familiar with both houses that are there. One of my takeaways from the July 14 meeting was that there was a great deal of back and forth discussion about whether 1125 was sufficiently distinctive to warrant a "Structure of Merit" designation. I decided I needed to see for myself how 1125 compared to other Craftsman style houses in Santa Monica.

I reviewed the Historical Resources Inventory (H.R.I.) and identified some 150 Craftsman style houses in Santa Monica that were considered eligible for either a "Landmark" or "Structure of Merit" designation. Over the span of 2 weeks I looked at all the eligible Craftsman houses in Santa Monica that are on the H.R.I. I discovered that 10 of the listed houses are no longer in existence so that leaves 140 to compare 1125 to.

Through these visits I was able to determine that there are 3 areas where I believe the house at 1125 exhibits characteristics that differentiate it from all the other Craftsman style houses listed in the H.R.I.

The first is the location of the primary entry door which is typically near the front of all houses. At 1125 this door is on the south side (face) of the house instead of on the front (westerly) face. Every Craftsman house in Santa Monica (SM) has its entry on the front face of the house so the side entry feature of 1125 differentiates it from all other SM Craftsman houses in a significant and unique way.

The second characteristic I found concerns the number and placement of it's windows. Its easy to see that the entire front face (west) of the house is all side by side windows. This is a significant departure from all other craftsman houses I looked at. Also, the south side has 4 large windows that are almost in a side by side configuration and, still further, the main entry door is about 80% glass and acts like a very large window. This condition is distinctive.

The third point I'd like to bring up is technically not a feature or characteristic but concerns the house's location in Santa Monica and lack of other nearby Craftsman houses. 1125 is the only surviving Craftsman house in the "Green Acres" tract that encompasses about 10 square city blocks. The boundaries are Washington, 17th, Wilshire and 21st. In fact, if you look at the area between Montana & Wilshire and go east of 14th St. all the way to Centinela Ave. there are only 2 others. In my opinion, this situation makes 1125 very rare indeed ! So in consideration of the foregoing, I'll close by saying that I believe the house at 1125 18th Street is a significant asset to the City of Santa Monica and eminently worth saving ! Thank you for your attention and consideration in this matter ! Harry Balaz - 1125 1/2 18th Street
Item 12-A
November 18, 2025

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Packet Pg. 1867 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 1 David Yakobson
From: Joseph Naim <[email protected]>
Sent: Friday, November 14, 2025 4:15 PM
To: councilmtgitems
Subject: Item 12 A City Council Meeting 11/18/2025
Attachments: FILE_8448.docx

EXTERNAL
Hello,
Please add my comments as property owner for the above hearing:

Thanks
Item 12 A
1125 18th Street Structure of Merit Designation Appeal
~ H. Joseph Naim
~ H. Joseph Naim M.D., FACS, FASMBS
Item 12-A
November 18, 2025

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Packet Pg. 1868 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 2 David Yakobson
From: Ruthann Lehrer <[email protected]>
Sent: Saturday, November 15, 2025 9:58 AM
To: councilmtgitems
Subject: Item 12A November 18 Council agenda

EXTERNAL
Re: Item 12 A Public Hearing on Structure of Merit Designation for 1125 18th Street.

Honorable Councilmembers,

Because the appeal statement for the Structure of Merit designation for 1125 18th Street raises issues related to the City’s historic preservation program, the Santa Monica Conservancy would like to provide some context information about those issues.

DEMOLITION PERMIT REVIEW
City policy, going back decades, conforms with best practice in historic preservation by requiring that buildings 40 years old or more that seek a demolition permit are subject to a short waiting period that allows for community review to prevent the inadvertent or undisclosed loss of potential historic resources.

The Santa Monica Conservancy, which monitors demolition permits, has the necessary professional experience and knowledge to identify properties proposed for demolition that meet the criteria for designation under the City’s Landmarks Ordinance. With just four applications submitted in the past five years, we ensure that evidence for designation is highly credible before filing. We are very selective about filing applications.

The City’s Historic Resources Inventory (HRI) is a database of properties deemed to have the potential to meet the city’s criteria for designation by the city’s impartial consultants. The Conservancy pays special attention to properties listed in the HRI when making evaluations. Listing on the HRI must be disclosed to buyers in real estate transactions, so those purchasing buildings with an intention to demolish them are not taken by surprise.

Demolition review is the only opportunity that the general public or local non-profits have to file Landmark or Structure of Merit applications, as the fee for proactive nominations is over $6,400 – much higher than in any other California City.

Occasionally, the Santa Monica Conservancy’s assessment of cultural and historical value does not align with a city-hired consultant’s findings. Because a decision to designate is a discretionary one, findings can vary. This is why our seven-member Landmarks Commission is the appropriate decisionmaking body. The Conservancy’s in-depth knowledge of Santa Monica’s architectural evolution, cultural histories, and other historical associations can bring a nuanced, contextual perspective not always uncovered by outside consultants.

Item 12-A
November 18, 2025

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Packet Pg. 1869 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 3 STRUCTURE OF MERIT CATEGORY
Revisions to the Landmarks Ordinance are not the subject of the public hearing challenging the Structure of Merit designation of 1125 18th Street, but because it is discussed in the appeal, here is some background information on that category of designation.

A two-tier designation classification has been part of our Landmarks Ordinance since its inception in 1975. While this is not typical among California cities, there are other places that utilize tiered classification systems to address particular circumstances. Santa Monica’s Landmarks Ordinance has been reviewed and evaluated by our State Historic Preservation Office (SHPO) and found to be consistent with State and Federal standards for local ordinances. Consequently, Santa Monica has been deemed a Certified Local Government by the SHPO, resulting in the delegation of certain federal and state review authority to the local government.

In Santa Monica a second tier of designation was considered necessary because in a small city where rapid redevelopment has occurred for the past fifty years, our tiered system allows us to tailor our preservation efforts to designate a very limited supply of highly regulated individual landmarks and historic districts as well provide a less regulated tier that captures even fewer structures that exhibit high levels of significance in only certain aspects such as being the last or rare example of their kind.

Nonetheless, the Structure of Merit definitions and criteria as written have long been found difficult to work with and in need of revision. Beginning in the early 2000s, the Landmarks Commission established an Ordinance Subcommittee to make recommendations for amendments, but that project was abandoned in favor of other city priorities.

The appeal statement for 1125 18th Street reminds us of the need to update the Structure of Merit designation criteria, as well as make other needed revisions to the 1975 ordinance. Moving ahead will require the leadership of qualified historic preservation experts, which we hope the City will be in a position to fund in the near future.

HISTORIC PRESERVATION AND HOUSING DEVELOPMENT
Since our ordinance was passed in 1975, Santa Monica has never used historic preservation laws to interfere with housing production or any other kind of development. This is a record the Conservancy has worked hard to establish and maintain. While dedicated to identifying and protecting our historic cultural assets, we recognize that change must be accommodated for historic resources to survive into the future.

In Santa Monica, we have pioneered new solutions to the marrying of preservation and new construction through special code provisions. These provisions provide incentives to enable the preservation of designated historic resources on sites that also include compatible new density. Santa Monica has a number of projects that serve as creative and successful models that blend historic preservation with new construction. Examples of these projects include but are not limited to, 829 Broadway, 1415 Michigan Avenue, 1012 Second Street, 401 Ocean Avenue, as well as pending projects such as 101 Wilshire Boulevard and 101 Santa Monica Boulevard.

Item 12-A
November 18, 2025

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Packet Pg. 1870 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Good evening, Mayor, Councilmembers, and members of the public My name is Joseph, and I’m here tonight as the property owner to respectfully ask that you reconsider the Structure of Merit designation for 1125 18th Street.

I want to start by saying how much I appreciate Santa Monica’s commitment to preserving its history. It really is one of the things that makes this city so special.

But in this particular case, I don’t believe the designation truly reflects the actual condition, character, or architectural value of this property.

Just to give you a little background — I am a physician and surgeon by profession, but I’ve also been interested in restoring and improving properties around Los Angeles for many years.

For example, I own a commercial building at 301 North Avalon Boulevard in Wilmington — built in 1924, and designed in the Italian Renaissance Revival Architecture Style— which was listed as a HistoricCultural Monument in 2022. I bought it in 2010, and I actually welcomed that process, and I still take great care of it today.

I also own a 1908 Craftsman-style home in Jefferson Park — 2146 West 31st Street — which is part of L.A.’s historic district.

It’s a true piece of history, and I’ve always been proud to preserve it. I bought it in 2015, and since then I have learned a great deal about Item 12-A
November 18, 2025

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Packet Pg. 1871 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Craftsman- Style Homes. 1125 18th street is not a Craftsman Style Home.

And more recently, I built a modern single-family home in Brentwood, completed in 2017 at 444 Tuallitan Road — a project that was really well received by the neighbors and the community.

So, when I purchased 1125 18th Street in December 2021, I did so knowing its R2 zoning and it’s potential — I planned not to erase history, but to contribute something thoughtful and positive to Santa Monica’s evolving community.

I truly believe that real preservation should highlight exceptional examples of history — not restrict the modification of properties that simply don’t meet that level of significance anymore.

We have to find that balance between honoring the past and supporting the need for safe, beautiful, and livable housing for the future.

So tonight, I simply ask the Council to take another look— and allow the demolition permit to move forward — not as a loss of history, but as a step toward a vibrant future for the city we all love.

Thank you so much for your time and consideration.

Item 12-A
November 18, 2025

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Packet Pg. 1872 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) 4 David Yakobson
From: Shabnam Naim <[email protected]>
Sent: Saturday, November 15, 2025 11:39 AM
To: councilmtgitems
Subject: Item 12A, City Council meeting 11/18/2025

EXTERNAL
Re: Structure of Merit designation of 1125 18th Street
Santa Monica City Council
1685 Main Street
Santa Monica, CA 90401
Dear Mayor and Councilmembers,
I hope this letter finds you well. I am writing as a concerned resident of West Los Angeles to express my support for the appeal regarding the Structure of Merit designation of 1125 18th Street.

As a neighbor and community member, I believe that it is crucial to balance historical preservation with the urgent need for more housing in our city. While preserving our heritage is important, we must also consider the broader impact on our community, including the availability of housing to meet the growing demand.

I kindly urge the Council to take into account the need for more housing and to ensure that the designation truly reflects the property’s historical significance without hindering the community’s growth and development.

Thank you for your time and consideration.

Sincerely,
Shabnam Salehi
Item 12-A
November 18, 2025

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Packet Pg. 1873 Attachment: Written Comments [Revision 3] (7242 : Appeal of 1125 18th Street Structure of Merit Designation) Item 6-A
Appeal of Landmarks
Commission Designation of
1125 18th Street
City Council
November 18, 2025
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

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Packet Pg. 1874 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Appeal of Landmarks Commission Designation
1125 18th Street as a Structure of Merit
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

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Packet Pg. 1875 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 • Approve Appeal 25ENT-0135, appeal of the Landmarks Commission’s decision to designate the property located at 1125 18th Street as a Structure of Merit
• Deny Designation Application 25ENT-0069 to designate the property located at 1125 18th Street as a Structure of Merit.

Alternatively
• If the City Council disapproves the appeal and approves the designation application to designate the property as either a City Landmark or Structureof Merit, as described in Alternative Actions, adopt the Landmarks Commission findings and alternative findings under “California Environmental Quality Act Compliance”.

Recommended Action
Item 12-A
November 18, 2025
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November 18, 2025

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Packet Pg. 1876 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Background
• The property owner filed a demolition permit application. • The Santa Monica Conservancy filed an application to designate the property as a Structure of Merit.
• The City hired Page & Turnbull to provide a Historic Resource Assessment (HRA) as part of the review process.

Item 12-A
November 18, 2025
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November 18, 2025

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Packet Pg. 1877 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Background
• Page & Turnbull found the property does not meet the criteria for Structure of Merit and is therefor ineligible for designation. Staff agrees and recommends denial.
• The Landmarks Commission designated the property as a Structure of Merit in a 4-2 vote.
• Commissioner Pam O’Connor appealed the designation.

Item 12-A
November 18, 2025
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Packet Pg. 1878 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 1125 18th Street Description
• Located on the east side of 18th
Street north of Wilshire Boulevard,
South of California Avenue
• 50 x 175 lot / R2 Low Density
Residential Zone
• Constructed in 1923
Vernacular/Craftsman Bungalow
• 952 SF One-story wood frame
building with wood siding and
composition shingles
Aerial View of property at 1125 18th Street
Item 12-A
November 18, 2025
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November 18, 2025

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Packet Pg. 1879 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Building Analysis
• Single-family wood-frame residential structure with a lowpitched front gable roof with an intersecting side gable projection
• Building is set back from the street on the property
• Smaller residence on property behind
• Wood Siding, Wood Windows, Asphalt Shingle Roofing
• Building is a modest/ Vernacular example of a Craftsman Bungalow
Item 12-A
November 18, 2025
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November 18, 2025

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Packet Pg. 1880 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Craftsman Bungalow in Santa Monica
84710thStreet.Built1919, identified bythe 2018
surveyas eligible for designation as a
Landmark.
91819th Street. Builtin1924, identified by the
2018surveyas eligible fordesignationas
a Structure of Merit.
811 5th Street. Built in1912, identified by the
2018surveyas eligible fordesignation
as a Structure of Merit
908California Avenue.Builtin 1922,
identified by the 2018 survey as eligible for
designation as a Landmark.

Item 12-A
November 18, 2025
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November 18, 2025

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Packet Pg. 1881 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Craftsman Bungalow in Santa Monica
Based on a review of the 2018 Historic Context Statement survey results:
• 178 properties in Santa Monica identified as “Craftsman” style
• 30 individually significant properties identified in the Wilshire Montana neighborhood
• 18 potential Landmarks
• 12 potential Structure of Merit
• 20 properties represent modest bungalow-style homes
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November 18, 2025
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Packet Pg. 1882 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Designation Criteria
SMMC 9.56.080 establishes that an improvement may be designated as a Structure of Merit Criteria if it has one of the following characteristics:
(a) The structure has been identified in the City’s Historic Resources Inventory
(b) The structure is a minimum of 50 years of age and meets one of the following criteria:

1. The structure is a unique or rare example of an architectural design, detail or historical type

2. The structure if representative of a style in the City that is no longer prevalent

3. The structure contributes to a potential Historic Districts Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1883 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Designation Criteria – Staff Recommendation
SMMC 9.56.080(a). The structure has been identified in the City’s Historic Resources Inventory.
• Residence is identified in the 2018 Historic Resources Inventory (HRI) and technically meets wording of criterion
• Considerations in applying criterion
• Residence was not identified prior to the 2018 Historic Resources Inventory (HRI)
• HRI is a “windshield survey”
• Upon further analysis, property does not appear to meet criteria for Structure of Merit
Therefore, the property does not appear eligible under this Criterion • Landmarks Commission has not previously designated a Structure of Merit based solely on this criterion
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1884 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Designation Criteria – Staff Recommendation
SMMC 9.56.080(b). The structure is a minimum of 50 years of age and meets one of the following criteria
• The subject property was built in 1923 and, therefore, satisfies the 50-year age threshold.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1885 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Designation Criteria – Staff Recommendation
SMMC 9.56.080(b)(1). The structure is a unique or rare example of an architectural design, detail or historicaltype.
• 178 properties in Santa Monica identified as “Craftsman” style • 30 individually significant properties identified in the Wilshire Montana neighborhood
• 18 potential Landmarks
• 12 potential Structure of Merit
• 20 properties represent modest bungalow-style homes
• 1125 18th Street does not appearto represent a rare or unique example of its type.

Therefore, the subject property does not appearto be eligible under this criterion.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1886 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Designation Criteria – Staff Recommendation
OR SMMC 9.56.080(b)(2). The structure is representative of a style in the City that is no longer prevalent.
• 1125 18th Streetis an example of a modest Craftsman bungalow • Building type prevalentin the City of Santa Monica through the firstthree decades ofthe 20th century
• Remains prevalent in the city
• Structure was first listed in the 2018 HRI and through research does not appear to meet this criteria
• 178 properties in Santa Monica identified as “Craftsman” style • 30 individually significant properties identified in the Wilshire Montana neighborhood • 18 potential Landmarks
• 12 potential Structure of Merit
• 20 properties represent modest bungalow-style homes
Therefore,the subject property does notappearto be eligible underthis criterion.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1887 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Designation Criteria – Staff Recommendation
SMMC 9.56.080(b)(3). The structure contributes to a potential Historic District. • The subject property has not been identified as a contributor to a potential Historic District.

Therefore, it does not appear to be eligible under this criterion.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1888 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 1125 18th Street Landmarks Commission Action
Structure of Merit Designation
Criterion A. The structure has been identified in the City’s Historic Resources Inventory as eligible for Structure of Merit designation.

Criterion (B)(1). The structure is a minimum of 50 years of age, and the structure is a unique or rare example of an architectural design, detail or historical type.
• The building is a relatively intact example of a modest Craftsman bungalow
• It remains a relatively uncommon building type within the neighborhood, specifically the Green Acres Tract of the Wilshire Montana neighborhood.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1889 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Criterion (B)(2). The structure is representative of a style in the City that is no longer prevalent.

Specifically, the Craftsman Home represents a style that is no longer prevalent in the Green Acres Tract of the Wilshire Montana Neighborhood. 1125 18th Street Landmarks Commission Action
Structure of Merit Designation
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1890 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Appeal Statement

1. Findings for Structure of Merit cannot be met
• Commissioner’s findings based on the rarity of the building type in the Green Acres Tract

2. The Structure of Merit Designation is flawed.
• This is outside the scope of the appeal before the Council Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1891 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Appeal Analysis
Staff agrees that the Structure of Merit findings cannot be met • Vernacular/Modest Craftsman was never prevalent in the Green Acres Tract
• Green Acres Tract is a very small area within the Wilshire Montana Neighborhood
• Staff and the City’s consultant found that the property type and modest bungalow style is not unique or rare in the city or in the Wilshire Montana neighborhood.
• It is not consistent with professional practice or past practice to identify the rarity of a property based on the small area of a single development tract.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1892 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 • Approve Appeal 25ENT-0135, appeal of the Landmarks Commission’s decision to designate the property located at 1125 18th Street as a Structure of Merit
• Deny Designation Application 25ENT-0069 to designate the property located at 1125 18th Street as a Structure of Merit.

Alternatively
• If the City Council disapproves the appeal and approves the designation application to designate the property as either a City Landmark or Structureof Merit, as described in Alternative Actions, adopt the Landmarks Commission findings and alternative findings under “California Environmental Quality Act Compliance”.

Recommended Action
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1893 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Questions
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1894 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Alternative CEQA Finding
• Pursuant to CEQA Guidelines Section 15061(b)(3) it can be seen with certainty that there is no possibility that approving an application and designating the property as a Landmark 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 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.

Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1895 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025 Appeal of Landmarks Commission Designation
1125 18th Street as a Structure of Merit
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1896 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025

1. The Structure of Merit Designation is flawed.
• There are other cities with tiered systems of designation, • The Code defines a Structure of Merit criteria therefore Landmarks Commission may designate a property as a Structure of Merit if it meets required findings
• Structure of Merit Criteria allows for a different and lower threshold than the Landmarks Designation Criteria
• A designated Structure of Merit is eligible for demolition after a certain waiting period. Any modifications to a Structure of Merit are reviewed by staff or the Architectural Review Board for compliance with the Secretary of Interior’s Standards.

Appeal Analysis
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1897 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit Appeal of Landmarks Commission SOM Designation 1125 18th Street| City Council | 11.18.2025

1. The Structure of Merit Designation is flawed.
• A designated Landmark may not be demolished with the
exception of an approved Certificate of Economic Hardship.

In the history of the preservation program, no designated Landmark structures have been demolished
• Any modifications to a designated Landmark must be
reviewed by City staff or the Landmarks Commission for
compliance with the Secretary of Interior’s Standards.

Appeal Analysis
Item 12-A
November 18, 2025
Item 12-A
November 18, 2025

12.A.m
Packet Pg. 1898 Attachment: PowerPoint Presentation (7242 : Appeal of 1125 18th Street Structure of Merit City Council
Report
City Council Meeting: November 18, 2025
Agenda Item: 16.A
1 of 1
To: Mayor and City Council
From: Nikima Newsome, City Clerk, Records and Election Services Department Subject: Appointment to one scheduled vacancy on the Transient Occupancy Tax Advisory Committee for a term ending on June 30, 2027
Prepared By: David Yakobson, Staff Assistant III
Approved Forwarded to Council
Attachments:

A. Applicant List

16.A
Packet Pg. 1899
City of Santa Monica
Boards and Commissions Applicants
Transient Occupancy Advisory Committee
Name Application Date
Ginsburg, Scott A. 11/07/2025
TOTAL APPLICANTS: 1

16.A.a
Packet Pg. 1900 Attachment: Applicant List (7370 : 16.A. Appointment to one seat on the Transient Occupancy Tax Advisory Committee (5 mins.)) City Council
Report
City Council Meeting: November 18, 2025
Agenda Item: 16.B
1 of 1
To: Mayor and City Council
From: Nikima Newsome, City Clerk, Records and Election Services Department Subject: Appointment to one vacancy on the Housing Commission for terms ending on June 30, 2028. Continued from the October 28, 2025 meeting to meet quorum requirements
Prepared By: David Yakobson, Staff Assistant III
Approved Forwarded to Council
Attachments:

A. Applicant List

16.B
Packet Pg. 1901
City of Santa Monica
Boards and Commissions Applicants
Housing Commission
Name Application Date
Badawy, Adam 7/25/2025
Gerwitz, Richard 10/7/2025
Gudgel, Timothy W. 5/30/2025
Harris, Gregory 6/13/2025
Jones Jr., Nathaniel I. 6/30/2025
Kozicki, William 7/28/2025
Marasco, Theresa 6/17/2025
Rakhshani, Raymond 5/29/2025
Rush, Lynda 4/17/2025
Watenmaker, Noah 7/24/2025
TOTAL APPLICANTS: 10

16.B.a
Packet Pg. 1902 Attachment: Applicant List [Revision 1] (7396 : 16.B. Appointment to one seat on the Housing Commission (5 mins.)) City Council
Report
City Council Meeting: November 18, 2025
Agenda Item: 16.C
1 of 1
To: Mayor and City Council
From: Oliver Chi, City Manager, City Manager's Office
Subject: Request of Councilmembers Hall and Zernitskaya that Council approve use of up to $6,000 of Council discretionary funds to support Samohi’s Legado Latino club in offsetting expenses incurred during the community’s observation of Día de los Muertos at the Santa Monica History Museum Prepared By: Sergio Ramirez, Chief of Staff
Approved Forwarded to Council
Attachments:

A. Financial Support for Legado Latino Día de los Muertos Ofrenda - Hall, Zernitskaya
B. Discretionary Funds Tracking_20251112

16.C
Packet Pg. 1903
Meeting: November 18, 2025
16 ITEM BY COUNCILMEMBERS DAN HALL AND NATALYA ZERNITSKAYA Request of Councilmembers Hall and Zernitskaya that Council approve use of up to $6,000 of Council discretionary funds to support Samohi’s Legado Latino club in offsetting expenses incurred during the community’s observation of Día de los Muertos at the Santa Monica History Museum.

In past years, Council has periodically allocated funding from its discretionary budget to support youth-led cultural and educational programming in our community.

Building on that tradition, we are requesting a total allocation of up to $6,000 to support Santa Monica High School’s Legado Latino club and their annual installation of an ofrenda at the Santa Monica History Museum’s Día de los Muertos observance. This student-led effort honors Mexican culture and aims to celebrate the community’s cultural roots and promote understanding through an inclusive and educational experience. This request aligns with Council’s past support for student initiatives that uplift youth voices, expand cultural literacy, and celebrate the diversity that defines Santa Monica.

In order to reinforce the City’s commitment to inclusion, education, and the arts, and ensure that our local students continue to see themselves and their culture reflected in civic life,
WE THEREFORE MOVE THAT THE COUNCIL:

1. Allocate up to $6,000 to defray costs spent by Legado Latino students to install their ofrenda for Día de los Muertos at the Santa Monica History Museum. Costs shall be split evenly across Councilmembers Hall and Zernitskaya’s allocations, up to $3,000 out of each.

2. Direct staff to disburse the funds to the Association of Mexican American Educators, care of Dr. Guadalupe Mireles-Toumayan, which acts as the tax ID entity for Legado Latino.
# # #

16.C.a
Packet Pg. 1904 Attachment: Financial Support for Legado Latino Día de los Muertos Ofrenda - Hall, Zernitskaya (7410 : Supporting Legado Latino) FY 2025-26 Council Discretionary Funds
Updated: 11/4/2025 Council Discretionary Funds 01100001.532330.Project# FY 2025-26 - New Appropriation and allocations
Project# Account
Description
Description Amount Programmed Date Mayor
Negrete
Mayor Pro
Tem Torosis
CM Hall CM Raskin CM Snell CM
Zernitskaya
CM Zwick
FY 2025-26 - New
Appropriation
140,000.00 Budget Adoption FY25-26, 6/24/25,
Council meeting, 10/14/25, Item 11B $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $20,000.00 $ 20,000.00 -
-
-
-
-
-
-
-
Total $ 140,000.00
$ 140,000.00 Unprogrammed Balance Available $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $20,000.00 $ 20,000.00

16.C.b
Packet Pg. 1905 Attachment: Discretionary Funds Tracking_20251112 (7410 : Supporting Legado Latino) City Council
Report
City Council Meeting: November 18, 2025
Agenda Item: 16.D
1 of 1
To: Mayor and City Council
From: Oliver Chi, City Manager, City Manager's Office
Subject: A Request of Councilmember Snell and Mayor Pro Tem Torosis that the City Council approve use of up to $2,000 of Council discretionary funds to support Santa Monica College's 9th Annual GIVING THANKS(giving) taking place Monday and Tuesday, November 24th and 25th to help provide holiday groceries and support for SMC students
Prepared By: Sergio Ramirez, Chief of Staff
Approved Forwarded to Council
Attachments:

A. SMC's GIVING THANKS(giving
B. Discretionary Funds Tracking_20251112

16.D
Packet Pg. 1906
Memo
To: Oliver Chi, City Manager
From: Barry Snell, City Councilmember
Caroline Torosis, Mayor Pro Tem
Date: November 10, 2025
Re: A Request of Councilmember Snell and Mayor Pro Tem Torosis that the City Council approve use of up to $2,000 of Council discretionary funds to support Santa Monica College's 9th Annual GIVING THANKS(giving) taking place Monday and Tuesday, November 24th and 25th to help provide holiday groceries and support for SMC students.

Santa Monica College Foundation’s 9th annual GIVING THANKS(giving) distributes holiday groceries to 2,400+ students in need. This event also raises critical funds to support SMC’s Basic Needs Program and EmergencyGrant Fund to support students throughout the year.

Santa Monica College's 9th Annual GIVING THANKS(giving) taking place Monday and Tuesday, November 24th and 25th on the Main Campus from 11a-7p, rain or shine. The event centers food security by providing an abundance of fresh, seasonal holiday groceries including grains, produce, and other shelf-stable items for students to feed a family of 4-6 members along with other special treats including a whole pumpkin pie and $50 grocery gift card.

Therefore, we recommend allocating up to $2,000 for the Annual GIVING THANKS(giving) event.

Sponsorship for this shall be split evenly across Councilmember Snell and Mayor Pro Team Torosis allocation, $1,000 out of each.

Please agendize this matter for City Council consideration at our November 18, 2025, meeting.

16.D.a
Packet Pg. 1907 Attachment: SMC's GIVING THANKS(giving (7411 : Santa Monica College's 9th Annual GIVING THANKS(giving)) FY 2025-26 Council Discretionary Funds
Updated: 11/4/2025 Council Discretionary Funds 01100001.532330.Project# FY 2025-26 - New Appropriation and allocations
Project# Account
Description
Description Amount Programmed Date Mayor
Negrete
Mayor Pro
Tem Torosis
CM Hall CM Raskin CM Snell CM
Zernitskaya
CM Zwick
FY 2025-26 - New
Appropriation
140,000.00 Budget Adoption FY25-26, 6/24/25,
Council meeting, 10/14/25, Item 11B $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $20,000.00 $ 20,000.00 -
-
-
-
-
-
-
-
Total $ 140,000.00
$ 140,000.00 Unprogrammed Balance Available $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $ 20,000.00 $20,000.00 $ 20,000.00

16.D.b
Packet Pg. 1908 Attachment: Discretionary Funds Tracking_20251112 (7411 : Santa Monica College's 9th Annual GIVING

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