HISTORICAL RESOURCE TECHNICAL REPORT
1202 3RD STREET PROMENADE, SANTA MONICA
DECEMBER 2025
556 S Fair Oaks Avenue, Suite 101-514
Pasadena, CA 91105
prepared for
City of Santa Monica
City Planning Division
1685 Main Street
Santa Monica, CA 90401
Cover Photo: J. C. Penny, 1949. Santa Monica History Museum
TABLE OF CONTENTS
1.0 EXECUTIVE SUMMARY .......................................................................................................... 2
2.0 PROJECT SUMMARY .............................................................................................................. 3 PROJECT LOCATION .................................................................................................................................................. 3 PROJECT DESCRIPTION ............................................................................................................................................ 3
3.0 REGULATORY FRAMEWORK ................................................................................................ 5 HISTORICAL RESOURCES UNDER CEQA ......................................................................................................... 5 HISTORIC DESIGNATIONS ....................................................................................................................................... 5 Landmark and Historic District Ordinance of the City of Santa Monica ..................................................... 5
4.0 IDENTIFICATION OF HISTORICAL RESOURCES ................................................................. 7
5.0 DESCRIPTION OF HISTORICAL RESOURCES ....................................................................... 8 PHYSICAL DESCRIPTION .......................................................................................................................................... 8 ALTERATIONS ................................................................................................................................................................ 8 CHARACTER-DEFINING FEATURES .................................................................................................................... 8
6.0 ANALYSIS OF POTENTIAL IMPACTS ................................................................................. 10 FRAMEWORK FOR ANALYSIS ............................................................................................................................ 10 Significance Threshold ................................................................................................................................................ 10 The Secretary of the Interior’s Standards for Rehabilitation ........................................................................ 10 Preservation Brief 25: The Preservation of Historic Signs ............................................................................. 11 ANALYSIS OF POTENTIAL IMPACTS ............................................................................................................... 12 Standards Analysis........................................................................................................................................................ 12 CEQA Analysis ............................................................................................................................................................... 15
7.0 CONCLUSION ......................................................................................................................... 17
8.0 REFERENCES ......................................................................................................................... 18 APPENDIX A ................................................................................................................................ 19 Historic Resources Group 1202 3rd Street Promenade, Santa Monica 2
1.0 EXECUTIVE SUMMARY
United XYZ LLC (the Applicant) proposes to add a digital display screen (the Project) to the existing commercial building located at 1202 3rd Street Promenade in the City of Santa Monica (the Project Site). The building, formerly a J. C. Penney department store constructed in 1949, was designated a Santa Monica Landmark in 2008 and is therefore considered a “historical resource” as defined by the California Environmental Quality Act (CEQA)1 for the purpose of this report. The purpose of this report is to identify potential impacts to historical resources as defined by CEQA that may be caused by the Project.
The Landmark and Historic District Ordinance of the City of Santa Monica (Code of Ordinances, Chapter 9.56) requires a certificate of appropriateness for any proposed alteration, restoration, construction, removal, relocation, or demolition of or to a Landmark (9.56.140) and requires the Landmarks Commission to use the Secretary of the Interior’s Standards for the Treatment of Historic Properties to evaluate any such proposed alteration, restoration, or construction (9.56.140.G). Therefore, this report evaluates the Project against the Standards for Rehabilitation to identify potential impacts to 1202 3rd Street Promenade. The evaluation includes a review of existing documentation on the property; observation of the site; and review of architectural drawings of the proposed alterations. A site visit was conducted in September 2025 to observe existing features and conditions on the Project Site. Research, field inspection, and analysis were performed by John LoCascio, AIA, Principal Architect, a qualified professional who meets the Secretary of the Interior’s Professional Qualifications Standards in Architecture and Historic Architecture. A resume is provided in Appendix A.
This report has determined that, because the proposed digital display screen will obscure most of the fluted corner tower that is the principal architectural feature of the former J. C. Penney building, the Project does not fully conform with Standards 2 and 9; therefore, the Project does not follow the Secretary of the Interior’s Standards for Rehabilitation. However, the Project will not materially alter the J. C. Penney building such that its significance would be materially impaired; all the physical characteristics that convey the building’s significance will remain intact behind the screen. The fluted corner tower and its component features will be obscured when viewed at a distance from Wilshire Boulevard and Third Street but will remain visible on closer view behind the digital display screen which will be offset from the building’s façades; and the building’s other features will remain fully visible, including its scored plaster walls, ribbon windows, blade sign, canopy, storefronts and display windows. Therefore, the Project will not cause a substantial adverse change in the significance of 1202 3rd Street Promenade and will not have a significant effect on the environment as defined by CEQA. 1 California PRC, Section 21084.1.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 3
2.0 PROJECT SUMMARY
Project Location
The Project Site (AIN 4291-002-001) is located at the southwest corner of the intersection of 3rd Street Promenade and Wilshire Boulevard in the City of Santa Monica. It is bounded by Wilshire Boulevard to the north, 3rd Street Promenade to the east, an adjacent commercial property to the south, and a service alley (2nd Court) to the west. A location map is included in Figure 1, below.
FIGURE 1: LOCATION MAP
Project Site outlined in red
Project Description
The Project consists of a new, 1,000-square-foot LED digital display/billboard to wrap around the corner of the east and north façades of the existing City-designated landmark at 1202 3rd Street Promenade. The display will be bracketed by architectural trim. The Project will also re-activate the blade sign at the southeast corner of the building. Renderings of the proposed digital display are provided in Figures 2 and 3, below.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 4 FIGURE 2: PROJECT RENDERING, DAY VIEW
View southwest from Wilshire Boulevard and 3rd Street. Orange Barrel Media FIGURE 3: PROJECT RENDERING, NIGHT VIEW
View southwest from Third Street at Wilshire Boulevard. Orange Barrel Media Historic Resources Group 1202 3rd Street Promenade, Santa Monica 5
3.0 REGULATORY FRAMEWORK
Historical Resources Under CEQA
The California Environmental Quality Act (“CEQA”) is the principal statute governing environmental review of projects occurring in the state and is codified in Public Resources Code (PRC) Section 21000 et seq. CEQA requires lead agencies to determine if a proposed project would have a significant effect on the environment, including significant effects on historical or unique archaeological resources. Under CEQA Section 21084.1, a project that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment.
CEQA Guidelines Section 15064.5 recognizes that historical resources include: (1) resources listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources; (2) resources included in a local register of historical resources, as defined in PRC Section 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g); and (3) any objects, buildings, structures, sites, areas, places, records, or manuscripts which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California by the lead agency, provided the lead agency’s determination is supported by substantial evidence in light of the whole record.
Historic Designations
Historical and cultural resources fall within the jurisdiction of several levels of government. The framework for the identification and, in certain instances, protection of cultural resources is established at the federal level, while the identification, documentation, and protection of such resources are often undertaken by state and local governments. As described below, the principal federal, State, and local laws governing and influencing the preservation of historical resources of national, State, regional, and local significance include:
The National Historic Preservation Act of 1966, as amended; The Secretary of the Interior’s Standards for the Treatment of Historic Properties (Secretary’s Standards);
The California Environmental Quality Act (CEQA);
The California Register of Historical Resources (California Register); The California Public Resources Code;
The Landmark and Historic District Ordinance of the City of Santa Monica (Code of Ordinances Chapter 9.56, added by Ord. No. 2486CCS§§ 1, 2, adopted June 23, 2015).
LANDMARK AND HISTORIC DISTRICT ORDINANCE OF THE CITY OF SANTA MONICA The Landmark and Historic District Ordinance was adopted to establish procedures and provide regulations to protect elements of the City’s cultural, social, economic, political and architectural history; safeguard the City’s historic, aesthetic, and cultural heritage; foster civic pride; protect and enhance the City’s aesthetic and historic attractions as a stimulus to business Historic Resources Group 1202 3rd Street Promenade, Santa Monica 6 and industry; and promote the use of Landmarks, Structures of Merit and Historic Districts for the education, pleasure and welfare of the City’s residents.
The Ordinance established a Landmarks Commission with the power to, among others, designate Structures of Merit, Landmarks and Landmark Parcels (9.56.060.A); and regulate and control the alteration, restoration, construction, removal, relocation or demolition of or to the same, or to a building or structure within a Historic District (9.56.060.C). The Landmarks Commission may approve the landmark designation of a structure, improvement, natural feature or an object if it finds that it meets one or more of the following criteria:
1. It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City.
2. It has aesthetic or artistic interest or value, or other noteworthy interest or value.
3. It is identified with historic personages or with important events in local, state or national history.
4. It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study.
5. It is a significant or a representative example of the work or product of a notable builder, designer or architect.
6. It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City.
The Ordinance requires a certificate of appropriateness for any proposed alteration, restoration, construction, removal, relocation, or demolition of or to a Landmark (9.56.140) and requires the Landmarks Commission to use the Secretary of the Interior’s Standards for the Treatment of Historic Properties to evaluate any such proposed alteration, restoration, or construction (9.56.140.G).
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 7
4.0 IDENTIFICATION OF HISTORICAL RESOURCES
The Project Site is occupied by a two-story commercial building originally constructed in 1949 as a J.C. Penney Co. department store. The property was designated a Santa Monica Landmark in 2008 under Criteria 1 and 6.
The former J.C. Penney building was constructed during the economic prosperity of Santa Monica in the early post-World War II years when expansion of commercial activity along 3rd Street was occurring. The building’s size and prominence on the corner of Wilshire Boulevard and 3rd Street continues to manifest and exemplify the economic development of the City’s Central Business District during the late 1940s. The property also exemplifies a particular and short-lived stylistic phase in the architectural history of the City, the Late Streamline Moderne. Character-defining features of the former J.C. Penney building that are indicative of the Late Streamline Moderne style include its pronounced horizontal northeast corner comprised of its storefront, broad flat curved canopy, and soaring circular fluted tower.2
J. C. Penny, 1949 (Santa Monica History Museum)
2 City of Santa Monica, “Historic Landmark Viewer,”
https://smgov.maps.arcgis.com/apps/instant/attachmentview er/index.html?appid=56607b6926724058aa5822c3d24023eb
(accessed September 5, 2025).
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 8
5.0 DESCRIPTION OF HISTORICAL RESOURCES
Physical Description
The former J.C. Penney department store building at 1202 3rd Street Promenade occupies the entire parcel, with zero setback on all sides. It is a two-story building of concrete construction with a rectangular plan, simple massing, and asymmetrical composition. It has a flat roof with parapets. The exterior walls are of banded cement plaster at the first floor and scored cement plaster at the second floor, over the original honed concrete surface. The upper portion of the north and east wall planes terminate short of the northeast corner, each folding forward into fins that frame a tall, cylindrical concrete tower with fluted walls and a reeded base. A flat, angled metal canopy with curved corners wraps the north and east façades at the base of the tower, sheltering the storefronts and display windows below. A similar, smaller canopy shelters a secondary entrance on the west end of the north façade. Fenestration consists of glazed metal storefront systems and display windows at the first floor, and bezeled ribbon windows at the second floor. There is a continuous base of glazed ceramic tile on the east and north façades, which continues around the display windows on the south end of the east façade and clads the column supporting the canopy over the primary entrance. The primary entrance is asymmetrically located on the east façade and consists of a pair of glazed metal doors flanked by single doors, set within the recessed storefront. The apron in front of the entrance is paved in terrazzo. The secondary entrance on the north façade consists of a pair of glazed metal doors recessed within the storefront. There is a recessed, flush egress door at the south end of the east façade, below a concrete blade sign.
Alterations
The former J. C. Penney department store building has undergone some alterations since its initial construction in 1949. The building has been remodeled twice, first for Banana Republic in 2007 and then for its conversion into Gold’s Gym in 2023. Exterior alterations include the application of scored and banded plaster veneer over the original honed concrete exterior walls; replacement of the storefronts, doors, and show windows on the east and north façades; removal of some of the glazed ceramic tile veneer around the storefronts and show windows; modification of the south show window on the east façade to accommodate an added egress door; addition of three new first-floor windows on the north façade; replacement of the secondary north entrance and display windows with new storefront glazing and entrance doors; and addition of a canopy over the secondary north entrance.
Tenant identification was removed from the blade sign after J. C. Penney vacated the building.
It has remained dormant ever since. In 2015, the Santa Monica Landmarks Commission approved reactivating the blade sign for Banana Republic (14ENT-5031) but that reactivation was never implemented.
Character-defining Features
Every historic building is unique, with its own identity and its own distinctive character.
Character-defining features are those visual aspects and physical elements and materials, constructed or deposited during the property’s period of significance, that give the building its Historic Resources Group 1202 3rd Street Promenade, Santa Monica 9 historic character and contribute to its historic integrity. Character-defining features should be considered in the planning and design of a project so that they are preserved to the maximum extent possible.
In general, retaining character-defining features retains the integrity of the historic property and thus maintains the property’s eligibility as an historical resource. Removal or alteration of a single feature does not necessarily impact the eligibility of an historical resource; significant impacts on an historical resource result from major change or from the cumulative effect of many incremental changes.
The former J. C. Penney Co. department store building is listed as a City Landmark under Criterion 1 as an example of the economic prosperity of Santa Monica in the early post-World War II years and the expansion of commercial activity along 3rd Street at that time; and as an example of a particular and short-lived stylistic phase in the architectural history of the City, the Late Moderne. The property is listed under Criterion 6 as a local icon and defining feature of Santa Monica’s downtown. A period of significance is not identified in the Landmark designation but is presumed to be 1949, the year in which construction was completed and the store opened for business. Therefore, the exterior character-defining features are those that survive from the building’s initial construction and include the following:
Rectangular plan, simple two-story massing, and asymmetrical composition Flat roof with parapets
Solid wall planes on the upper portion of the north and east façades, terminating in fins Tall, cylindrical concrete tower with fluted walls and reeded base Flat, angled metal canopy with curved corners wrapping the north and east façades Bezeled ribbon windows at the second floor
glazed ceramic tile base, surrounds, and column
Terrazzo entrance apron
Concrete blade sign on east façade
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 10
6.0 ANALYSIS OF POTENTIAL IMPACTS
Framework for Analysis
SIGNIFICANCE THRESHOLD
A significant effect under CEQA would occur if a project results in a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5(a).
Substantial adverse change is defined as “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired.”3 According to CEQA Guidelines Section 15064.5(b)(2), the significance of a historical resource is materially impaired when a project demolishes or materially alters in an adverse manner those physical characteristics that:
A. Convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register; or
B. Account for its inclusion in a local register of historical resources pursuant to PRC Section 5020.1(k) or its identification in a historical resources survey meeting the requirements of PRC Section 5024.1(g) Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or
C. Convey its historical significance and that justify its eligibility for inclusion in the California Register as determined by a Lead Agency for purposes of CEQA.
According to CEQA Guidelines Section 15064.4(d)(1-3), in evaluating the significance of the potential environmental effect of a project on historical resources, both direct physical changes to the environment and reasonably foreseeable indirect physical changes are considered:
1. A direct physical change in the environment is a physical change in the environment which is caused by and immediately related to the project.
2. An indirect physical change in the environment is a physical change in the environment which is not immediately related to the project, but which is caused indirectly by the project. If a direct physical change in the environment in turn causes another change in the environment, then the other change is an indirect physical change in the environment.
3. An indirect physical change is to be considered only if that change is a reasonably foreseeable impact which may be caused by the project. A change which is speculative or unlikely to occur is not reasonably foreseeable.4
THE SECRETARY OF THE INTERIOR’S STANDARDS FOR REHABILITATION The relationship of the Secretary of the Interior’s Standards to the CEQA process are discussed under CEQA Guidelines Section 15064.5(b)(3):
Generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for 3 State CEQA Guidelines, Section 15064.5(b)(1).
4 State CEQA Guidelines, Section 15064.4(d)(1-3).
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 11 Rehabilitation and Guidelines for Rehabilitating Historic Buildings” (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a significant impact on the historical resource.
The Secretary of the Interior’s Standards for the Treatment of Historic Properties (“the Standards”) provide guidance for reviewing proposed projects that may affect historic resources. The Standards and associated guidelines address four distinct historic “treatments,” including: (1) preservation; (2) rehabilitation; (3) restoration; and (4) reconstruction. The specific Standards and guidelines associated with each of these possible treatments are provided on the National Park Service’s website regarding the treatment of historic resources.
The intent of the Standards is to assist the long-term preservation of a property’s significance through the preservation, rehabilitation, and maintenance of historic materials and features.
The Standards pertain to historic buildings of all materials, construction types, sizes, and occupancy and encompass the exterior and interior of the buildings. The Standards also encompass related landscape features and the building’s site and environment, as well as attached, adjacent, or related new construction.
The Standards for Rehabilitation (36 CFR 67) address the most prevalent treatment. “Rehabilitation” is defined as “the process of returning a property to a state of utility, through repair or alteration, which makes possible an efficient contemporary use while preserving those portions and features of the property which are significant to its historic, architectural, and cultural values.” As stated in the definition, the treatment “rehabilitation” assumes that at least some repair or alteration of the historic building will be needed in order to provide for an efficient contemporary use; however, these repairs and alterations must not damage or destroy materials, features or finishes that are important in defining the building’s historic character.
PRESERVATION BRIEF 25: THE PRESERVATION OF HISTORIC SIGNS In addition to the Guidelines for Rehabilitating Historic Buildings, the National Park Service has published Preservation Briefs to provide information on preserving, rehabilitating, and restoring historic buildings and help owners recognize and resolve common problems. The Briefs recommend methods and approaches for rehabilitating historic buildings that are consistent with their historic character.
Preservation Brief 25: The Preservation of Historic Signs makes recommendations for the repair and re-use of historic signs and also addresses the design of appropriate new signs for historic buildings. Preservation Brief 25 encourages businesses to fit their sign programs to the building, and presents the following considerations for the design and construction of new signs for historic buildings:
Signs should be viewed as part of an overall graphics system for the building. They do not have to do all the “work” by themselves. The building’s form, name and outstanding features, both decorative and functional, also support the advertising function of a sign.
Signs should work with the building, rather than against it.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 12 New signs should respect the size, scale and design of the historic building. Often features or details of the building will suggest a motif for new signs.
Sign placement is important: new signs should not obscure significant features of the historic building. (Signs above a storefront should fit within the historic signboard, for example.)
New signs should also respect neighboring buildings. They should not shadow or overpower adjacent structures.
Sign materials should be compatible with those of the historic building. Materials characteristic of the building’s period and style, used in contemporary designs, can form effective new signs.
New signs should be attached to the building carefully, both to prevent damage to historic fabric, and to ensure the safety of pedestrians. Fittings should penetrate mortar joints rather than brick, for example, and signloads [sic] should be properly calculated and distributed.5
Analysis of Potential Impacts
STANDARDS ANALYSIS
The Project proposes a new, 1,000-square-foot LED digital display/billboard to wrap around the corner of the east and north façades of the former J. C. Penney & Co. department store. The display will be bracketed by architectural trim. The Project will also re-activate the blade sign at the southeast corner of the building. The Project is evaluated below against the Standards for Rehabilitation.
Standard 1: A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.
The Project does not propose to change the existing use of the former J. C. Penney & Co. department store building. The Project follows Standard 1.
Standard 2: The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.
The Project proposes to alter features that characterize the former J. C. Penney & Co. department store building by obscuring them behind a new, 1,000-square-foot LED digital display/billboard that will wrap the northeast corner of the building, above the historic entrance canopy. The LED screen will be approximately 54 feet 10 inches wide by 18 feet 6 inches high and will be framed at each end by architectural trim that will be furthered detailed through the City’s plan check process. The trim conceals structural elements and provides a clean finish at the edges of the LED screen. The bottom of the screen will approximately align with the 5 Michael J. Auer, “The Preservation of Historic Signs,” U. S.
Department of the Interior, National Park Service, October 1991, 11,
https://home.nps.gov/orgs/1739/upload/preservation-brief25-signs.pdf (accessed October 2025).
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 13 junction of the fluted tower with its reeded base and will extend above the flanking parapets to leave exposed the top seven feet of the tower, approximately 27% of its height from its junction with the reeded base. The new digital display will obscure most of the corner tower and its relationship with the flanking fins and blank wall planes. That architectural composition is collectively the primary and most distinctive feature of the J. C. Penney building, designed to catch the eye of passing motorists and pedestrians on Wilshire Boulevard and 3rd Street. The overall composition and its component parts will remain intact behind the LED screen structure, which will be offset from the face of the building, and will be partially visible from certain vantage points at close proximity; however, the added structure will obscure most of the historic composition from general view. As such, it does not follow the recommendation provided by the NPS in Preservation Brief 25 that new signs should not obscure significant features of a historic building and will alter the visual character of the J. C. Penney building at its most prominent point. Therefore, the Project does not fully comply with Standard 2.
Standard 3: Each property will be recognized as a physical record of its time, place, and use.
Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.
The Project does not propose to add conjectural features or elements from other historic properties or make any changes that create a false sense of historical development. The Project follows Standard 3.
Standard 4: Changes to a property that have acquired significance in their own right will be retained and preserved.
No previous alterations to the former J. C. Penney & Co. department store building have acquired significance in their own right. The Project follows Standard 4.
Standard 5: Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.
The Project will install a new LED display/billboard that will wrap the northeast corner of the former J. C. Penney & Co. department store building. The new digital display will obscure most of the building’s fluted corner tower and its relationship with the flanking fins and blank wall planes, which collectively form the building’s most distinctive architectural feature. However, the tower, fins, and blank walls will remain intact behind the display, which will be offset from the face of the building, and the Project will not affect the building’s other distinctive features and materials including its rectangular plan, simple two-story massing, and asymmetrical composition; flat roof with parapets; flat, angled metal canopy with curved corners wrapping the north and east façades; bezeled ribbon windows; glazed ceramic tile base, surrounds, and column; terrazzo entrance apron; and the dormant concrete blade sign which will be reactivated with current tenant identification lettering. Therefore, the Project follows Standard 5.
Standard 6: Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 14 The former J. C. Penney & Co. department store building has been generally well maintained and appears to be in overall good condition. The Project does not propose to replace deteriorated or missing historic features. Therefore, Standard 6 is not applicable to this Project.
Standard 7: Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used.
The Project does not propose to undertake chemical or physical treatments that cause damage to historic materials. The Project follows Standard 7.
Standard 8: Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.
The Project Site is located in an urbanized area and has been previously disturbed for development; moreover, the Project does not propose excavation that might uncover unknown archaeological resources on the site. Therefore, Standard 8 is not applicable to this Project.
Standard 9: New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.
The Project does not propose new additions or related new construction. The Project proposes exterior alterations to the former J. C. Penney & Co. department store building. The Project will install a new LED display/billboard that will wrap the northeast corner of the building. The new digital display will obscure most of the building’s fluted corner tower and its relationship with the flanking fins and blank wall planes, which collectively form the building’s most distinctive architectural feature, designed to catch the eye of passing motorists and pedestrians on Wilshire Boulevard and 3rd Street. The Project will not destroy historic materials or features; the tower, fins, and blank walls will remain intact behind the display, which will be offset from the face of the building, and will be partially visible from certain vantage points at close proximity.
However, the added structure will obscure most of the historic composition from general view.
As previously noted, it does not follow the guidance provided by the NPS in Preservation Brief 25 which recommends that new signs should not obscure significant features of historic buildings. The proposed new digital display/billboard is thus not compatible with the historic features, size, scale and proportion of the former J. C. Penney building. Therefore, the Project does not fully comply with Standard 9.
Standard 10: New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
The proposed new LED sign will be supported on a steel subframe. The primary structural loads will be suspended from existing concrete beams below the roof deck. Secondary attachments at the perimeter of the structure will be to the concrete wall and will be minimal and reversible.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 15 No penetrations or attachments will be made to the fluted tower. Thus, if the structure were to be removed in the future, the essential form and integrity of the former J. C. Penney & Co. department store building would be unimpaired. Therefore, the Project follows Standard 10.
CEQA ANALYSIS
The preceding analysis demonstrates that the Project does not conform with Standards 2 and 9 and therefore does not entirely follow the Secretary of the Interior’s Standards for Rehabilitation. Projects that comply with the Standards benefit from a regulatory presumption that they would have a less than significant effect on a cultural resource under CEQA.6 However, projects that do not comply with the Standards are not automatically presumed to have a significant effect under CEQA. As discussed previously, a significant effect would occur if a project results in a substantial adverse change in the significance of a historical resource.
Substantial adverse change is defined as the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the resource would be materially impaired. The significance of a historical resource is materially impaired when a project demolishes or materially alters in an adverse manner those characteristics that convey its historical significance and justify its inclusion in, or eligibility for inclusion in, the California Register or that account for its inclusion in a local register.7 The Project will install a new LED display/billboard that will wrap the northeast corner of the former J. C. Penney building and will obscure most of the building’s fluted corner tower and its relationship with the flanking fins and blank wall planes, which collectively form the building’s most distinctive architectural feature. However, in order for this alteration to be considered a substantial adverse change, it must be shown that the integrity and/or significance of the J. C.
Penney building would be materially impaired by the proposed alteration. A resource is not materially impaired unless it is altered in an adverse manner to the point that its physical characteristics fail to convey its historical significance.8 The ability of a historical resource to convey its historical significance is based on an analysis of the resource’s historic integrity. Integrity is defined as “the authenticity of a property’s historic identity, evidenced by the survival of physical characteristics that existed during the property’s historic period.”9 The National Park Service identifies seven aspects that, in various combinations, convey a property’s historic integrity. These seven aspects are location, design, setting, materials, workmanship, feeling, and association. The Project is evaluated below against the seven aspects of integrity to determine if it will alter the former J. C. Penney & Co. building in an adverse manner to the point that its physical characteristics fail to convey its historic significance.
The Project does not propose to relocate the J. C. Penney building or alter its physical environment. Therefore, the property will retain integrity of location and setting. As previously discussed, the Project will obscure most of the building’s fluted corner tower and its relationship with the flanking fins and blank wall planes, which collectively form the building’s most distinctive architectural feature, designed to catch the eye of passing motorists and pedestrians on Wilshire Boulevard and 3rd Street. However, the tower, fins, and blank walls will 6 CEQA Guidelines, § 15064.5(b)(3); see also § 15331.
7 CEQA Guidelines, § 15064.5(b)(2).
8 CEQA Guidelines, § 15064.5(b)(1).
9 California PRC, § 5023.1(d).
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 16 remain intact behind the display, which will be offset from the face of the building, and will be partially visible from certain vantage points at close proximity. The Project will not affect the building’s other distinctive features and materials including its rectangular plan, simple twostory massing, and asymmetrical composition; flat roof with parapets; flat, angled metal canopy with curved corners wrapping the north and east façades; bezeled ribbon windows; glazed ceramic tile base, surrounds, and column; terrazzo entrance apron; and concrete blade sign. All will remain intact and fully visible. Therefore, the building will retain integrity of materials and workmanship, and sufficient integrity of design to continue to convey its Late Moderne architectural style. Because the J. C. Penney building will retain integrity of location, setting, materials, and workmanship, and sufficient integrity of design, it will continue to express the aesthetic and historic sense of a post-World War II department store and its direct link to the economic development of Santa Monica’s Central Business District during the late 1940s.
Therefore, it would retain integrity of feeling and association.
According to National Park Service guidance, “to retain historic integrity a property will always possess several, and usually most, of the [seven] aspects” of integrity;10 and that in order to remain eligible for designation historic properties “must not only retain their essential physical features, but the features must be visible enough to convey their significance.”11 After completion of the Project, the former J. C. Penney & Co. department store building will retain integrity of location, setting, materials, workmanship, feeling, and association, and sufficient integrity of design to convey its historic Late Moderne architectural style. Although the Project will obscure some essential physical features, all of the features will remain intact and visible enough that, together with those features unaffected by the Project, they will continue to convey the building’s historic significance and justify its designation as a local Landmark.
Therefore, the Project will not materially impair the J. C. Penney building such that its physical characteristics fail to convey its historic significance and thus will not result in a substantial adverse change in the significance of a historical resource. 10 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation (Washington, D.C.: U. S.
Department of the Interior, National Park Service, 1990; revised for internet 1995), 44.
11 National Register Bulletin 15, 46.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 17
7.0 CONCLUSION
The Project proposes to install a new, 1,000-square-foot LED digital display/billboard that will wrap the northeast corner of the former J. C. Penney & Co. department store building located at 1202 3rd Street Promenade in the City of Santa Monica. The building was designated a Santa Monica Landmark in 2008 and is therefore considered a “historical resource” as defined by CEQA for the purpose of this report.
The Landmark and Historic District Ordinance of the City of Santa Monica requires a certificate of appropriateness for any proposed alteration, restoration, construction, removal, relocation, or demolition of or to a Landmark and requires the Landmarks Commission to use the Secretary of the Interior’s Standards for the Treatment of Historic Properties to evaluate any such proposed alteration, restoration, or construction. Therefore, this report evaluates the Project against the Standards for Rehabilitation to identify potential impacts to 1202 3rd Street Promenade.
This report has determined that, because the proposed digital display screen will obscure most of the fluted corner tower that is the principal architectural feature of the former J. C. Penney building, the Project does not fully conform with Standards 2 and 9; therefore, the Project does not follow the Secretary of the Interior’s Standards for Rehabilitation. However, the Project will not materially alter the J. C. Penney building such that its significance would be materially impaired; all the physical characteristics that convey the building’s significance will remain intact.
The fluted corner tower and its component features will be obscured when viewed at a distance from Wilshire Boulevard and Third Street but will remain visible on closer view behind the digital display screen which will be offset from the building’s façades; and the building’s other features will remain fully visible, including its scored plaster walls, ribbon windows, blade sign, canopy, storefronts and display windows. The dormant existing concrete blade sign will be reactivated with current tenant identification lettering. The building will retain integrity of location, setting, materials, workmanship, feeling, and association, and sufficient integrity of design to convey its historic Late Moderne architectural style. Therefore, the Project will not cause a substantial adverse change in the significance of 1202 3rd Street Promenade and will not have a significant effect on the environment as defined by CEQA.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 18
8.0 REFERENCES
Auer, Michael J. “The Preservation of Historic Signs.”
Washington, D.C.: U. S. Department of the Interior,
National Park Service, October 1991,
https://home.nps.gov/orgs/1739/upload/preservationbrief-25-signs.pdf (accessed October 2025).
City of Santa Monica. “Findings and Determination of the Landmarks Commission of the City of Santa Monica in
the Matter of the Designation of a Landmark:
Designation of a Commercial Structure Located at 1202
3 rd Street Promenade as a City Landmark,” 08-LM-005,
September 8, 2008.
Santa Monica History Museum Photo Archives.
Santa Monica Public Library. Santa Monica Image
Archives.
State of California, Department of Parks and Recreation. “California Office of Historic Preservation Technical
Assistance Series #6: California Register and National
Register: A Comparison.” Sacramento, CA: Office of
Historic Preservation, 2011.
U.S. Department of the Interior. National Register Bulletin 15: How to Apply the National Register Criteria for
Evaluation. Washington D.C.: National Park Service,
1997.
U.S. Department of the Interior. National Register Bulletin 16: How to Complete the National Register Registration
Form. Washington, D.C.: National Park Service, 1997.
Historic Resources Group 1202 3rd Street Promenade, Santa Monica 19
APPENDIX A
RESUMES OF AUTHORS/CONTRIBUTORS
JOHN LOCASCIO, AIA
Principal Architect
Experience Profile
Years of Experience: 32
California Architect license no: C24223
John LoCascio lives in Altadena, CA and has been with Historic Resources Group since 2011, involved in historic preservation since 2002, and a licensed, practicing architect since 1993.
John’s areas of focus at HRG include historic architecture and technology, building conservation, historic structure reports and federal historic rehabilitation tax credit projects. He provides technical assistance for construction documents; advises on compliance with the Secretary of the Interior’s Standards for Rehabilitation and state regulatory/building code; provides construction monitoring; and prepares paint and materials sampling and analysis services.
John has worked on a wide variety of buildings and structures throughout the United States. He is currently advising on historic tax credit projects in Los Angeles and the San Francisco Bay area and Washington State. In addition, John regularly provides historic architecture consultation for numerous Los Angeles United School District campus modernization projects.
Prior to joining HRG, John served as Executive Director of Claremont Heritage, which included reviewing environmental documents and advising the City of Claremont on planning and design issues. John also worked for 14 years as a project architect in private practice, specializing in custom residential projects.
John LoCascio meets the Secretary of the Interior’s Professional Qualifications Standards in Architecture and Historic Architecture. 556 S Fair Oaks Ave, Suite 101-514
Pasadena, CA 91105
Tel 626-793-2400
historicresourcesgroup.com
Selected Projects
28th Street YMCA Rehabilitation and Adaptive Reuse, Los Angeles Academy Museum of Motion Pictures Rehabilitation
Angelus Funeral Home Historic Tax Credit Project, Los Angeles Climate Pledge Arena Historic Tax Credit Project, Seattle Chapman University VPO Packing House Rehabilitation, Orange Grand Central Air Terminal Rehabilitation & Adaptive Reuse, Glendale Kennedy High School Comprehensive Modernization, Granada Hills Los Angeles International Airport Preservation Plan and HSRs Taft High School Comprehensive Modernization, Woodland Hills University of Southern California Religious Center Rehabilitation Venice High School Comprehensive Modernization, Los Angeles Education
Master of Historic Preservation, University of Southern California Bachelor of Architecture, University of Southern California Honors and Awards
National Trust for Historic Preservation, Richard H. Driehaus Foundation National Preservation Award
Angelus Funeral Home/Paul Williams Family Apartments, 2022 Los Angeles Conservancy Preservation Awards
Academy Museum of Motion Pictures, 2022
Angelus Funeral Home/Paul Williams Family Apartments, 2021 Grand Central Air Terminal, 2017
CBS Columbia Square, 2016
California Preservation Foundation Preservation Design Awards Sandi Simon Center for Dance, 2023
Angelus Funeral Home/Paul Williams Family Apartments, 2021 CBS Columbia Square, 2017
Grand Central Air Terminal, 2016
City of Pasadena Historic Preservation Award
Constance Hotel, 2015
AIA Institute Honor Award
28th Street YMCA, 2015
Professional Affiliations
American Institute of Architects
556 S Fair Oaks Ave, Suite 101-514
Pasadena, CA 91105
Tel 626-793-2400
historicresourcesgroup.com