City of
Santa Monica
Planning and Community Development Department
City Planning Division
(310) 458-8341
APPEAL FORM
(Please Type or Print all Information)
Application Number Filed:
By:
APPELLANT NAME: J a c k H i l l b r a n d
APPELLANT ADDRESS: 1323 18 th S t r e e t , U n i t D , S a n t a M o n i c a , C A 9 0 4 0 4
CONTACT PERSON: J a c k H i l l b r a n d
Phone: 415 - 710 - 4702
(all correspondence will be mailed to this address)
Address: 1323 18 th S t r e e t , U n i t D ,
S a n t a M o n i c a , C A 9 0 4 0 4
PROJECT CASE NUMBER(S) : 26ENT-0089
PROJECT ADDRESS: 1921 20th Street
APPLICANT: Santa Monica Conservancy
ORIGINAL HEARING DATE: September 14, 2026
ACTION BEING APPEALED: Denial of Landmark Designation of 1921 20th Street 26ENT-0218
9/22/26
Jack Hillbrand
Please state the specific reason(s) for the appeal (use separate sheet if necessary):
Is the appeal related to the discretionary action and findings issued for the proposed project? Yes No If yes, explain:
See Attachment
.
Is the appeal related to the conditions of approval? Yes No If yes, which conditions and why:
See Attachment
Is the appeal related to design issues? Yes No If yes, explain Is the appeal related to compatibility issues such as building height, massing, pedestrian orientation, etc.? Yes No If yes, explain:
Is the appeal related to non-compliance with the Santa Monica Municipal Code? Yes No
If yes, which Code section(s) does the project not comply with and why:
Is the appeal related to environmental impacts associated with the project? Yes No If yes, explain:
See Attachment
Is the appeal related to other issues? Yes No If yes, explain:
See Attachment
APPELLANT SIGNATURE:
NOTE: A hearing date on the appeal will not be scheduled until sufficient information regarding the basis for the appeal has been received to enable City Planning Division staff to prepare the required analysis for the staff report.
1 CITY OF SANTA MONICA
LANDMARKS COMMISSION APPEAL
Landmark Designation Application 26ENT-0089
1921 20th Street — City Council Appeal
Appellant: Commissioner Jack Hillbrand, Architect
AIA, NCARB, LEED, CA.gov SME
Santa Monica Landmarks Commission
I. Procedural Basis and Standing
The decision of the Landmarks Commission to deny designation of 1921 20th Street as a City Landmark is subject to appeal to the City Council under SMMC §9.56.180 within ten days of the Commission's action.
This appeal is filed because the Commission's denial is not supported by the substantial evidence in the record, contradicts the findings of the city-retained expert consultant, misapplied and in part ignored National Park Service guidance upon which professional consistency in the field of Historic Preservation relies[1].
II. Summary of the Appeal
III. Grounds for Appeal
Ground 1: The Commission Failed to Give Adequate Weight to the City-Retained Expert's Findings
The City of Santa Monica retained HRG to conduct a Historic Resource Assessment precisely because professional expertise is required to evaluate eligibility, and because the City does not have a Qualified Historian or Architectural Historian on staff. The 2018 Historic Resources Inventory had independently and previously identified the property as appearing eligible for Landmark designation, citing its Craftsman architecture, distinctive characteristics, and significance for representing early patterns of residential development in the Pico neighborhood. HRG’s assessment confirmed and expanded on that finding, concluding that the property is eligible under Criteria 1, 2, and 4, and that it retains integrity of
STATEMENT OF APPEAL
The city retained Historic Resources Group (HRG) — a qualified professional preservation consulting firm under the Code of Federal Regulations, 36 CFR Part 61 — specifically to assess whether 1921 20th Street meets the criteria for Landmark designation. HRG's architectural historian concluded that it meets Criteria 1, 2, and 4. The 2018 Historic Resources Inventory had already identified the property as potentially eligible for Landmark designation. The Santa Monica Conservancy filed a thorough, documented nomination. The Commission nonetheless denied designation, relying on staff analysis that contradicts established preservation standards, dismisses the qualified expert's findings without adequate documentation, and gives an appearance of partiality due to the strenuous efforts made to discredit the qualified professional findings — in contrast to the unbiased expert report prepared under federal professional standards[1].
2 location, design, materials, workmanship, feeling, and association. Staff disagreed with every assertion of the consultant; this disagreement was based on opinion, not a substantive, impartial rebuttal supported by competing, qualified, professional analysis. Accepting staff’s non-expert opinion and conjectural assertions over two independent professional assessments is an inadequate basis for denial.
Ground 2: Staff's Integrity Analysis Misapplied and Ignored National Park Service Best Practice Guidelines
● Integrity, as defined by the National Park Service, refers to the authenticity of a property's historic identity — the presence of the physical characteristics that existed during its period of significance. ● Condition refers to the current state of repair of those materials. A building in poor condition can retain high integrity if its original fabric — however deteriorated — remains in place and unaltered.
Staff's conclusion that "rehabilitating the residence in a manner that would retain sufficient original materials in accordance with SOI Standards would be challenging where replacement of a majority of the materials is likely" is an improper speculative future projection of what might happen — and a fundamental misunderstanding of the scope of the Secretary of the Interior's Standards. Thus, it is not an assessment of integrity according to professional standards and guidelines. Furthermore, according to the advice of the Santa Monica City Attorney’s Office, it is improper to consider the impacts of any future rehabilitation or project involving a historic resource as part of the nomination process. Proposed repairs or improvements can only be considered as part of the Certificate of Appropriateness review of submitted plans.
● Designation protects a resource so that rehabilitation can occur in accordance with SOI Standards.
The possibility that rehabilitation might be difficult is not a criterion for denial under SMMC §9.56.100. ● If it were, any neglected historic property could be denied designation precisely because its owner had failed to maintain it — a perverse incentive that undermines the entire purpose of the preservation ordinance.
Ground 3: Staff's Recommendation Distorted the Professional Record to Serve the Owner's Desired Outcome
The proper way for staff to have handled the owner's stated intention to demolish would have been to present it as what it was: an owner objection, appended to an accurate summary of the professional findings. Instead, staff's analysis recast the HRG report's conclusions, selectively emphasized the property's condition, and speculated about future rehabilitation project scoping and costs — not to provide an accurate factual record, but to arrive at a recommendation consistent with the owner's preference. The result was that the Commission deliberated on a distorted record rather than the actual evidence of significance.
This is the most technically significant error in the record. Staff concluded that the property has lost integrity of materials, workmanship, feeling, and association primarily because it is in poor condition due to deferred maintenance. This conflates two distinct concepts that the National Park Service explicitly treats separately[1]:
The Secretary of the Interior's Standards do not equate deferred maintenance with loss of integrity[2].
Deterioration of original materials is not the same as replacement or loss of those materials.
HRG — applying the SOI Standards according to professional guidance — reached the opposite conclusion: that the property retains integrity across six of the seven aspects[1][2]. The Commission's record does not contain a professional rebuttal to HRG's integrity analysis. It contains only staff's disagreement based on opinion and speculation about future work on the property. 3 Ground 4: The Commission's Analysis Under Criterion 1 Artificially Severs the Property's Association with the Early History of the Pico Neighborhood Staff's characterization of the subject property as a "remnant" of an "insignificant" earlier period inverts and ignores the events documented in the application and supported by HRG as significant. The low 25% build-out rate in the Erkenbrecher Tract was not a sign of neglect or a failed attempt at development, as one commissioner characterized it. It was the direct result of how the tract was originally platted. In 1904, the Erkenbrecher Syndicate deliberately subdivided the area east of 20th Street into large 5-acre farm lots for working-class and semi-rural residents — distinct from the standard 50×150 lots to the west — because it was not yet within the city limit at the time the tract was recorded. It was a coherent settlement pattern exemplified by the Unfrieds' efforts on the 3-acre parcel they purchased, and robust enough to produce Santa Monica's first neighborhood association, the Fairview Heights Improvement Association, which successfully won city services and street renamings still in use today (Delaware, Virginia, Kansas Avenues).
Furthermore, it was precisely because these large parcels remained intact for decades that they became the large multi-family lots staff credits as "the more significant period of growth." The subject property is not an insignificant leftover — it is physical evidence of the agrarian settlement pattern that made the later apartment boom possible. Dismissing it as a "remnant" erases the causal link between the two eras staff treats as unrelated.
Staff additionally argued that the later contributions of the Unfried family — their charter membership in the Fairview Heights Improvement Association, their construction of Unfried Hall, their experience with the city's racist anti-dancing ordinance, and their forced departure from Santa Monica — are "separate and apart from the history of the subject property" because those events occurred after the Unfrieds sold 1921 20th Street in 1920.
The subject property is the physical origin point of the Unfried family's presence in Fairview Heights on a three-acre parcel. Simon Unfried built it in 1913 as his family home; it was the household from which the family participated in the founding of Santa Monica's first neighborhood organization, and it is the only surviving physical remnant of the Unfrieds' later contributions to the development of Fairview Heights.
All of their subsequent buildings — the store, the Delaware house, Unfried Hall — have been demolished.
This structure alone remains to represent their story.
Ground 4: The Commission's Analysis Under Criterion 4 Is Internally Contradictory
Staff acknowledged that the Airplane Bungalow subtype "has always been a rare subtype in the city of Santa Monica" — a type documented in cities and towns across the United States — and that 315 10th Street, known as the Aeroplane Bungalow, is already a designated City Landmark. Staff then denied Criterion 4 eligibility on the grounds that 1921 20th Street is a "simple example" of this rare subtype.
This reasoning is contradictory. If the subtype is rare in Santa Monica, the rarity itself is a basis for Criterion 4 eligibility — "unique or rare example of an architectural design, detail or historical type." The The Criterion 1 standard asks whether the property "exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City." The Unfried story manifests: the early history of Santa Monica's working-class immigrant community; the founding of the city's first neighborhood improvement association; the impact of racially motivated municipal ordinances on community commerce; the establishment of a new segregated district in the city; and the resilience of Fairview Heights as a neighborhood. That story begins at 1921 20th Street. The Commission's denial under Criterion 1 was based on acceptance of an unsubstantiated rebuttal of the work of a professional historian qualified under the criteria of the National Park Service, and the well-documented history presented in the application.[1]
4 designation of 315 10th Street demonstrates that the city has already recognized the Aeroplane Bungalow as a type worthy of Landmark protection. The existence of one designated example does not foreclose designation of a second with different historical associations and typological features.
Furthermore, HRG's qualified architectural historian demonstrated that 1921 20th Street is not a "simple" example of the type — it is an excellent, essentially unaltered specimen exhibiting the type's defining characteristic features: the complex irregular plan, the sleeping porch producing the cockpit-like second story that gave the type its name, the porte-cochere with brick piers and planter box, the exposed structural elements, and the flared wood cladding[2]. The application materials and HRG's assessment document this in detail. Staff's characterization as a "simple subtype" is not supported by the physical evidence in the record. Evidence produced by the applicant at the public hearing — a plan book image of a Craftsman Airplane Bungalow — further indicates that characteristics of the subject property were representative of the subtype's typical variance, not a lesser expression of it.
IV. Requested Relief
The appellant respectfully requests that the City Council:
● Reverse the Landmarks Commission's denial of Designation Application 26ENT-0089 and designate the primary structure at 1921 20th Street as a City Landmark; ● Adopt findings consistent with the HRG Historic Resource Assessment under Landmark Criteria 1, 2, and 4; and
● Define and describe an associated Landmark Parcel as the primary residential structure and parcel at 1921 20th Street, excluding the non-contributing rear accessory structures.
Footnotes
[1]
36 CFR Part 61 — Procedures for State, Tribal, and Local Government Historic Preservation Programs. This regulation establishes the minimum professional qualification standards for historians, architectural historians, architects, and archaeologists performing work under federal historic preservation programs. HRG staff meet or exceed these standards. See Appendix A for the relevant qualification requirements. [2]
The Secretary of the Interior's Standards for the Treatment of Historic Properties (36 CFR Part 68) and the companion NPS guidance document How to Apply the National Register Criteria for Evaluation (NPS Bulletin 15) govern integrity assessment for historic resources. These standards distinguish condition from integrity and explicitly acknowledge that deteriorated materials may retain integrity of design, workmanship, and feeling. See Appendix B for the relevant excerpts.
5 APPENDIX A
36 CFR Part 61 — Professional Qualification Standards
The following minimum qualifications are established under the Code of Federal Regulations for professionals performing historic preservation work under federal programs. HRG's professional staff meet or exceed these criteria.
Historian
The minimum professional qualifications in history are a graduate degree in history or a closely related field; or a bachelor's degree in history or a closely related field plus one of the following:
● At least two years of full-time experience in research, writing, teaching, interpretation, or other demonstrable professional activity with an academic institution, historical organization or agency, museum, or other professional institution; or
● Substantial contribution through research and publication to the body of scholarly knowledge in the field of history.
Architectural Historian
The minimum professional qualifications in architectural history are a graduate degree in architectural history, art history, historic preservation, or closely related field, with coursework in American architectural history; or a bachelor's degree in architectural history, art history, historic preservation, or closely related field plus one of the following:
● At least two years of full-time experience in research, writing, or teaching in American architectural history or restoration architecture with an academic institution, historical organization or agency, museum, or other professional institution; or
● Substantial contribution through research and publication to the body of scholarly knowledge in the field of American architectural history.
Architect
The minimum professional qualifications in architecture are a professional degree in architecture plus at least two years of full-time professional experience in architecture; or State licensure in architecture.
Source:
- 36 CFR Part 61 — Procedures for State, Tribal, and Local Government Historic Preservation Programs. - Appendix A — Minimum Professional Qualifications Standards.
APPENDIX B
National Park Service Guidance: Integrity vs. Condition Secretary of the Interior's Standards — Relevant Excerpts
1. Integrity Defined (NPS Bulletin 15)
Integrity is the ability of a property to convey its significance. The National Register recognizes seven aspects of integrity:
● Location — the place where the historic property was constructed or the place where the historic event occurred.
● Design — the combination of elements that create the form, plan, space, structure, and style of a property.
● Setting — the physical environment of a historic property. ● Materials — the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property. 6 ● Workmanship — the physical evidence of the crafts of a particular culture or people during any given period in history.
● Feeling — a property's expression of the aesthetic or historic sense of a particular period of time. ● Association — the direct link between an important historic event or person and a historic property.
2. Integrity Is Not Condition
The NPS guidance is explicit that physical condition and historic integrity are distinct concepts that must be evaluated separately:
"To retain historic integrity a property will always possess several, and usually most, of the aspects.
The loss of some historic fabric through deterioration, alteration or addition does not automatically mean that a property has lost its integrity… Integrity enables a property to illustrate its significance." Further, NPS Bulletin 15 cautions that evaluators should not confuse deterioration of original fabric with loss of integrity:
"Determining whether a property retains integrity requires considering the property as a whole, not just its condition. A deteriorated property may retain integrity if it retains the physical characteristics that existed during its period of significance, even if those characteristics are in poor repair."
3. The Secretary of the Interior's Standards for Rehabilitation (36 CFR Part 68) The Standards for Rehabilitation are the basis on which future work on a designated historic resource is evaluated. They are not a threshold test for designation eligibility. Specifically:
"The Standards (Department of Interior regulations, 36 CFR 67) define Rehabilitation as the act or process of making possible a compatible use for a property through repair, alterations, and additions while preserving those portions or features which convey its historical, cultural, or architectural values."
The Standards are applied to proposed work after designation — they do not govern whether a property is eligible for designation in the first instance. Speculating that rehabilitation might require replacement of materials is not a basis for denying designation; rather, designation is precisely the mechanism that ensures any future rehabilitation would be reviewed against the Standards, protecting the resource from inappropriate intervention.
4. Application to This Case
Staff's analysis concludes that the property has lost integrity of materials, workmanship, feeling, and association because it is in poor condition. This application is inconsistent with NPS guidance, which requires evaluators to assess whether the original physical characteristics are present — not whether they are in good repair.
The Unfried House retains its original wood clapboard siding, fenestration, roof form, exposed rafter tails, porte-cochere, brick chimney, and interior features essentially unaltered since 1913. The deterioration of those features due to deferred maintenance does not constitute their loss or replacement under NPS integrity standards. HRG's assessment, applying these standards correctly, found integrity across six of the seven aspects. Staff's contrary conclusion rests on a conflation of condition and integrity that NPS guidance explicitly prohibits.
Sources:
- NPS Bulletin 15 — How to Apply the National Register Criteria for Evaluation; - Secretary of the Interior's Standards for the Treatment of Historic Properties (36 CFR Part 68); - NPS Preservation Brief 17 — Architectural Character: Identifying the Visual Aspects of Historic Buildings as an Aid to Preserving Their Character.