Written Comments — Santa Monica City Council, November 18, 2025

Santa Monica City Council
Structure of Merit Designation Appeal
1125 18th Street
Item 12-A
November 18, 2025
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November 18, 2025
• 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.

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• 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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• 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 Historic- Cultural Monument
in 2022. I bought it in 2010, and I
welcomed that process, and I still take
great care of it today.

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• I also own a 1908 Craftsmanstyle 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 CraftsmanStyle Homes. 1125 18th street is not a Craftsman Style Home.

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• And more recently, I
built a modern singlefamily home in
Brentwood,
• completed in 2017 at
444 Tuallitan Road — a
project that was really
well received by the
neighbors and the
community.

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• 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.

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• 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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1125 18th
Street
Structure of Merit
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Sanborn Map 1935
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Sanborn Map 1961
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CONTEXT
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5 CONTEXT
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1125 18 TH ST.

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1125 18 TH ST.

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828 7TH ST.

Another Structure of Merit
Classic Craftsman Bungalow
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8 908 CALIFORNIA AVE.

Landmark Eligible on the HRI
Classic Craftsman Bungalow
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1125 18 TH ST.

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1125 18 TH ST.

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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 singlefamily 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.
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12 1125 18 TH ST.

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Examples of Historic Structures
Combined with New Housing Construction
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2501 2ND
STREET
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14 before
today (in progress)
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1012 2ND
STREET
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15 Item 12-A
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16 401 OCEAN
AVENUE
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17 PONO BURGER

AND HIGHRISE
829 BROADWAY
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18 THE LAUREL

APARTMENTS

NIKKEI HALL
1413
MICHIGAN AVE.

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

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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
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
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
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
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
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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
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.

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
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.

Many thanks,
Elizabeth Van Denburgh
Wilmont Chair (speaking only for myself)
Item 12-A
November 18, 2025
4 1125 18th Street - Wilshire Montana Neighborhood
Item 12-A
November 18, 2025
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
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
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
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November 18, 2025
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
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November 18, 2025
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
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.

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
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.

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
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

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
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
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
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
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.

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
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.

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.

Item 12-A
November 18, 2025
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 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.

Many thanks,
Elizabeth Van Denburgh
Item 12-A
November 18, 2025
12 Wilmont Chair (speaking only for myself)
1125 18th Street - Wilshire Montana Neighborhood
Item 12-A
November 18, 2025
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
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
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.

In addition to upholding the appeal please give direction to abolish the Structure of Merit category.

Please uphold the appeal and direct staff to abolish the Structure of Merit category.

Sincerely,
Eli Gill
Item 12-A
November 18, 2025
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
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
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.

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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
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

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.

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November 18, 2025
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.

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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.

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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
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
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
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
Exhibit A
Item 12-A
November 18, 2025
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:

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

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
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
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
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
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
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
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
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
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
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
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
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

Santa Monica City CouncilNovember 18, 2025

Santa Monica City Council
November 18, 2025