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 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).
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.