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agenda-report Appeal of Decision by Landmarks Commission to Designate the Front Residence on the Property Located at 1125 18th Street as Structure of Merit New Item Received. 8/6/2026

Santa Monica City Council
November 18, 2025

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agenda-report Appeal of Decision by Landmarks Commission to Designate the Front Residence on the Property Located at 1125 18th Street as Structure of Merit New Item Received. 8/6/2026
Meeting
November 18, 2025
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Santa Monica City Council
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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 2 of 22
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 3 of 22
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 4 of 22
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 5 of 22
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. 6 of 22
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. 8 of 22
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. 10 of 22
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 11 of 22
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 12 of 22
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 14 of 22
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 15 of 22
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. 17 of 22
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 18 of 22
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 19 of 22
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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