HOLLYW= OOD HERITAGE, INC. 

 = ;P.O. Box 2586  

Hollyw= ood, CA 90078  

(323) 874-4005 • FAX (323) 465-5993

Chri= stopher Rudd

Seni= or Planner

Holl= ywood Community Redevelopment Agency

6255 Sunset Blvd.

Suit= e 2206

Los = Angeles CA 90028

&nb= sp;

Augu= st 11, 2010

&nb= sp;

RE: Hollywood Boulevard and Franklin Avenue Design District Urban Design Standards and Guidelines

Dear Mr. Rudd,

The Bo= ard of Directors of Hollywood Heritage, its Preservation Issues Committee and its members thank you for the opportunity to review and comment on the proposed, Hollywood Boulevard and Franklin Avenue Design District Urban Design Standa= rds and Guidelines. Our Board and interested members in the architecture and planning professions have review= ed the Plan and helped us prepare these comments.

This Plan was required= by the Redevelopment Plan to include a concerted effort – of the caliber of = the rest of the Plan—on encouraging preservation, restoration, and re-use= of historic structures. Until the historic buildings are specifically identified in this Plan, and specific a= nd directed planning tools developed to protect them, it fails at this require= ment and in fact endangers Hollywood’s historic resources, including mo= st significantly the nationally registered Hollywood Boulevard Commercial and Entertainment District. F= urther, this abrogates CRA responsibility for a clear message in this Plan to the development community, meaning that property owners will continue to feel “ambushed” when the properties are obviously nationally-recognized landmarks.

For nearly three decades Hollywood Heritage has been a staunch advocate of the preservation and protection of Hollywood’s historic resources and has long anticipated= the development of these Plans to aid in preserving what is most significant in Hollywood, while encouraging responsible new and infill development.

The development and distr= ibution of this Plan is, in fact, a part of the recent settlement agreement between= the Agency and Hollywood Heritage. Unfortunately, from our point of view, it does not achieve what we thought was a shared objective: the celebration and protection of Hollywood’s most important resources.

You have done an admirable job both in analyzing the= built form of Hollywood, and of crafting detailed and well-presented guidelines f= or sympathetic new construction. We will offer some edits and comments, but our emphasis is on the following critical issues:

· The final version HBUDP/FADD Plan must be changed to actually protect historic buildings, not simply regulate the new buildings that replace them. = This Plan does not stop incentivizing demolitions of historic buildings, as requ= ired in the Redevelopment Plan. By staying silent on the central subject of the Plan, CRA does a disservice to future developers. The Plan d= oes not give a clear picture of what is historic, and what can happen with it.<= span style=3D'mso-spacerun:yes'> The section below called “HO= W TO MAKE THIS PLAN COMPLIANT” addresses these issues.

This final Plan must be conformed with your Historic Survey. We suggest as well that it be conformed with y= our Sunset Plan. There should be a consistency in the protection of historic resources. For a discussion = of this please see “INTEGRATION OF PLANNING” below.

PLAN PURPOSE: PRESERVATION CENTRAL TO HBUDP=

The Hollywood Boulevard D= istrict was established under Sec 506.2.1 of the Redevelopment Plan. It was intended to solve the clear= and direct conflict between the proposed high intensity land use/zoning allowan= ces in the Hollywood Boulevard area with the existing nationally significant and pedestrian-friendly National Register Historic District. To that end, the Redevelopment pla= n said it

“may include the reduction of density by up to 33% in certain areas to insure the objectives of the District are met.”

At that time, in order to let redevelopment as a who= le proceed, but to stop demolitions, the City Planning department imposed a “D= 221; condition on properties fronting Hollywood Boulevard. This prevented the use of the incr= eased development rights. That “D” condition has remained until today. But LA City Planning is proposing removing it. If this Plan is adopted in current form, this is the fatal step-- re-opening the Boulevard = to demolitions.

The Redevelopment Plan expressly created the HBUDP t= o deal with this crisis. Sec 506.2.1 reads:

“ The objectives of the Distr= ict are to:

1. = Encourage preservation, restoration, = and appropriate reuse of historically and architecturally significant structure= s.

2. = Assure that new development is sympathetic to and complements the existing scale of development;

3. = Provide pedestrian oriented retail us= es along the street level

4. = Encourage entertainment, theater, and tourist related uses

5. = Provide adequate parking for new and existing uses.

6. = Reinforce the existing pedestrian environment.”

Recommendation: The Plan correctly refers to Sec. = 506.2 of the Redevelopment Plan on Page 6. We recommend that the full text of the legal requirements for the Pl= an be quoted there. The om= ission of the full text leaves the impression that the Plan is sufficient in only addressing new developments. = The Plan was required to encourage preservation. That must be added.=

It appears that objectives #2,3,4, and 6 are well-analyzed= and well-covered. =

The fatal step of this Plan is permitting high densities and tall buildings on = the sites of existing low-density historic buildings, and not dealing head on w= ith the conflict of permitted zoning and existing buildings. Of note: The illustration Figure 3-39, sugg= esting the demolition of the Musso and Frank’s building, should be replaced by a drawing showing suggested new constructio= n on a non-historic site.

PLAN PURPOSE: PRESERV= ATION CENTRAL TO FADD

The purpose of the Frankl= in Avenue Design District was outlined in section 505.2 of the 1986 Redevelopm= ent Plan and reconfirmed in the 2003 Redevelopment Plan. The Plan recognized the need for sensitivity and balance in the redevelopment of this area because of the im= pact upon views to and from the Hollywood Hills. At the time, the incompatibi= lity of the proposed development intensity with the neighborhoods was clear and = the goals were not really that limited. The review was expected to include topography, views, and building massing, orientation and bulk:

“ a detailed plan whi= ch addresses preservation of architecturally and/or historically significant buildings, parking, circulation, and views to and from the Hollywood Hills including the height, orientation, and massing of new development within th= is District.”

Recommendation: The Plan correctly refers = to sec 505.2 of the Redevelopment Plan on Page 6.= We recommend that the full text of the legal requirements for the Pl= an be quoted. The omission of th= e full text leaves the impression that the Plan as drafted is legally sufficient.<= span style=3D'mso-spacerun:yes'> As it omits the required issues of preservation, parking, and circulation, and focuses principally on new development, it is not complete. &nbs= p;

PLAN PURPOSE: HOLLYWOOD CORE TRANSITION

Sec 506.2 and 506.2.2 of = the Redevelopment Plan cited a “Hollywood Core Transition District” plan which CRA was required to prepare, focusing especially on the resident= ial areas to the north of Hollywood Boulevard between Vista del Mar and Gower, = and on the east side of Argyle between Carlos and Yucca. This plan was intended to ameliora= te the incompatibility of the intensive proposed Regional Center developments with= the residential neighborhoods around them, dealing with such issues as;

“circulation patterns, landscaping, parking, and,” making sure, “the scale of new construction is not detrimental to the adjacent residential neighborhoods.”

“The objective of this district is to provide fo= r a transition in the scale and intensity of development between Regional Center Commercial uses and residential neighborhoods… development guidelines shall be prepared for this District to ensure that new development is compatible with adjacent residential areas.”(Hollywood Redevelopment Plan)

Recommendation:<= /u> To be legally compliant, CRA must = study compatibility with these areas. There is a glaring inconsistency with the compatibility of unlimited height at Yucca and Vine and the nearby low density neighborhoods.

HOW TO MAKE PLAN COMPLIANT: #1-- ADD MISSING B= ASIC INFORMATION: <= /b>

From Hollywood Heritage’s perspective, the Plan has focused on new development, and has done that job admirably. However, even if that were the sole purpose of the Plans, to make sense of the result the Plan needs to include basic land use information.

·      =             &nb= sp; Existing Land Use Maps: A map of= current land use and development intensities in the Plan areas is missing.

·      =             &nb= sp; Historic Resources Map: A mapp= ing of historic resources is missing. HCM’s, HPOZs, historic districts, and identified historic resources are fundamental basics for a Plan purporting to sensitively devel= op around them. This mapping was included at early roll-outs of these Plans, and = should be added back in.

·            = ;        Proposed Land Use Maps: The current zoning and proposed Community Plan land use and development intensities should be mapped and included in the Plans.

·            = ;        Proposed Land Use Conflicts Map: An overlay map indicating conflict= s of existing land uses with proposed, is missing. Without this, two basic issues of = the Plan are left vague and misunderstood—where are the actual opportunity sites where any development may take place, and where has the existing or proposed development intensity creates a threat to historic buildings.

·            = ;        Redevelopment Plan regulations affecting = this Plan area: The Redevelopm= ent Plan contains restrictions – such as a prohibition against granting housing incentive units on historically significant sites. (Sec 511). These should be restated in this P= lan.

Recommendation: Basic land use mapping must be add= ed to this Plan. To mention the protection of and compatibility with historic resources and existing histor= ic settings without clearly naming them is a glaring inconsistency, especially when that information is readily available.

In the absence of these basic maps,= it is impossible to gauge whether the Plan as a whole is making any sense, meeting its objectives, and legally complying with the Redevelopment Plan. There is really no way to evaluate whether the proposals in this Plan are effective, desirable, or ineffectual= , as they are presented without factual context.

#2--PROVIDE EXPLICIT RECOGNITION OF SIGNIFICANCE

Figure 1-2 illustrates th= at the heart of Hollywood is listed on the National Register of Historic Places.

Historic buildings were t= he reason for drafting this Plan.   They must be fully presented and discussed. The Hollywood Boulevard Commercial= and Entertainment National Register Historic District contains the 103 most important buildings in Hollywood, listed at the national level of significance in the National Register of Historic Places. While some stand alone as individu= al, internationally-recognized monuments such as Grauman&#= 8217;s Chinese, the El Capitan, and the Egyptian Theaters, these landmarks are among 100 other structures on Hollywood Boulevard between La Brea and Argyle to make up the most significant historic district in Hollywood and arguably in Los Angeles, surpassing even downtown’s Broadway in national and international significance.

The D= istrict was formally designated by the National Park Service on behalf of the Secre= tary of the Interior in 1985. At the time there were over 60 contributors and approximately 40 non-contribut= ors which all dated from the period of significance 1905-1935.

Since its listing, the District has seen significant and positive restorations, now having the largest collection of restored historic theaters in use in the nation. The District can coun= t the beneficial reuse of the Broadway and Equitable Buildings, the Hollywood Professional Building, and the Nash Building, and many restorations, spurri= ng the renaissance of Hollywood.

But the District has suff= ered the loss of three contributors, and seen the addition of large developments suc= h as Hollywood and Highland, the W Hotel and Madame Tussaud= ’s. The recent survey of historic reso= urces by Chattel Architecture, and Hollywood Heritage research, have identified n= ew structures previously ineligible due to age, which were constructed between 1935 and 1960 that can now be included in the district as contributors.

Other buildings exist within the Plan boundaries tha= t are potentially historic, but currently covered over due to bad remodeling. Hollywood Heritage is continuing to analyze and update the Hollywood Boulevard National Historic District to include contributors, which have significance, historic association and integrity and have attained the commonly accepted 50-year threshold of age.= The organization believes that a s= mall collection of significant contributors in adjacent lots and side streets, including such landmarks as the Montalban Theat= er have clear association with the historic district and will be included.

Recommendation: Include an explicit discussion in the Plan of the history and significance of the Hollywood core historic buildings and the National Regi= ster and other Districts. Include explicit reference to the where readers may find the listings of addresses. Include clear mapping. Include language clarifying that additional resources are possible as the buildings age and = as bad remodeling are reversed. Include procedures so that potentially significant buildings are stu= died rather than demolished.

#3 -- RECOGNIZE POTENTIAL HISTORIC DIS= TRICTS

Th= e recent survey of Historic Resources in Hollywood identified two significant distri= cts of historic multi-family residential apartment houses located in this Plan area:

approximately between Franklin to the north and Hollywood Boulevard to the south and between Las Palmas to the west and Vine Street to the east

along N Orange Drive and Orchid Ave north of Hollywood Boulevard..

These districts with approximately 60 contributing buildings make up a significant transition zo= ne between the dense commercial urban landscape of Hollywood Boulevard and the bucolic single-family residential character of the foothills.

Recommendation: I= nclude an explicit mapping of these potential historic districts, with a specific boundary. Within the boundary, recognize their character and limit the height of new construction.<= o:p>

#4 --PROVIDE TOOLS FOR PROTECTING HISTORIC RESOURCES

Plan Goals 2.2.1 state th= at historic districts and landmarks shall be conserved.

Each and every reviewer w= ho has worked on this response with Hollywood Heritage returned with the same alar= ming conclusion: the Plan as conceived allows for the radical redevelopment of the National Register Hollywood Boulevard Commercial and Entertainment District= and has the potential to permanently damage the District.   We did not anticipate that t= his Plan, a part of our settlement to protect Hollywood’s resources, would result in a potential adverse effect on our most important resource.

The Plan “Vision= 221; is so well presented,&nbs= p; but the Plan does not provide tools to make the vision happen.   The CRA is the primary steward of the District, along with property owners and interested parties. This Plan must be a primary tool for protection. Compatible and sensitive new development is intensively regulated by this Plan, and equal regulation is critical for protecting that existing development.

Recommendation:<= /u> Buildings that that already exi= st must be analyzed, mapped, and then protected—by design standards, and by= basic land use planning, including density reductions as stated in the Redevelopm= ent Plan.

This is the critically= needed portion of this Plan, and missing. We will participate in getting it done.

Hollywood Heritage rec= ommends that the Hollywood Boulevard Commercial and Entertainment District and all = of the properties within its boundaries be treated in the planning process consistent with the processes adopted by the City of Los Angeles for Histor= ic Preservation Overlay Zones.   As its National Register designation attests, the District meets, and exceeds, the criteria for this local district status. We recommend that both the Sec 511 protections already in the Redevelopment Plan be cited in this Plan, and further that CHM procedures be applied formally, as required in t= he 1986 Community Plan amendment.

<= /p>
#5 -- TRANSFER OF DEVELOPMENT RIG= HTS MUST BENEFIT THE HISTORIC BUILDINGS

Hollywood Heritage commen= ds the suggestion in the Plan to implement the TDR (Transfer of Development Rights) program described in the Redevelopment Plan in Sec. 511.

“The Agency shall promulgate procedures= for such transfers….and shall obtain adequate assurances that the buildings from which the density transfer was taken are preserved…”.

As described, this Plan g= ives the wrong impression that CRA or a Regional Commercial site, are the beneficiar= ies of the TDR program. In order = to support the financial viability of maintaining historic buildings, a TDR program must mandate private compensation for property owners who have land= mark buildings in the Hollywood Boulevard Historic District and the Hollywood No= rth Multi-Family Residential Historic District.   Sale of development potential taken from these historic sites must benefit the historic buildings.

Recommendation: Hollywo= od Heritage recommends that this section of the Plan quote the Redevelopment P= lan regarding TDR’s in its entirety. If CRA is unable to promulgate the= se procedures at this time, a time frame for preparing them must be stated.

#6 – BETTER APPOACH TO BUILDING HEIGHTS STANDARDS

It is the opinion of Holl= ywood Heritage that the Plan as conceived does not encourage the protection and preservation of the Hollywood Boulevard National Historic District and landmarks. In fact it does the opposite, by permitting inappropriate heights rather than using height as a finely tailored preservation tool. <= /span>

Figure 3-20, showing perm= issible heights for new construction, ignores the historic district entirely. While Sec. 3.2.2 A says “Hon= or Existing Scale”, this Plan hasn’t achieved that. If that were true, the maximum bui= lding height would be 150’. The design guidelines have made a sincere attempt to control the des= ign of buildings of greater height, but the permission for that unlimited heigh= t is incompatible.

Under the propos= ed plan a blanket height of 45 ft would be allowable in the center of the Boulevard, an area dominated by one and two story buildings. Of this area all but two bloc= ks are nationally significant. = This 45’ height limit may have been proposed to protect the historic buildings, but it is abstract and doesn’t prevent demolitions. It doesn’t squarely add= ress and solve the basic conflict that gave rise to this plan.
At the western e= nd of the Boulevard height limits of 150 ft are permitted even though this portion of the District includes the most architecturally significant block, the southern side of Hollywood Boulevard between Highland and La Brea. In this stretch of= the boulevard this is a particularly alarming and arbitrary scenario.
At the eastern e= nd of the Boulevard certain parcels within the National register District also fall in the unlimited height district area

Hollywood North= and Orange/Orchid potential multifamily residential historic districts are threatened by a blanket height limit for new construction of 60ft. Height should be limited to existing for landmark buildings, and should be determined by individual neighbor sites to allow for sensitive additions rather than a monolith= ic 60ft height. The traditi= onal patterns of development should also be respected and enforced such as respecting parcel lines, forbidding the joining of no more than two parcels for a single project. Traditional lot coverage requirements and setbacks should be maintained

Blanket heights appear arbitrary. Adding= one property into the 150’ height limit north of Hollywood and Highl= and, simply because CIM owns it, has no valid planning purpose. Adding a 75’ permissible height along a recently-thriving low-rise s= ection of Yucca Street appears arbitrary. Permitting unlimited he= ight for the benefit of Millenium Partners towe= ring over a residential neighborhood that the Plan was supposed to protect appears arbitrary.
The west and east sides of Highland Avenue have two different suggested heights, both overlain on important historic buildings. Sections of the National Regi= ster District are in areas allowing 150’.
At the eastern e= nd of the boulevard there is no transition as height limits are raised to= 105 feet and then again to 150ft and potentially 220ft.

· New information on potential contributors is available, so a thorough examination of the structures on Hollywood Bouleva= rd and on adjacent lots requires careful consideration of the District and its setting.

Recommendation: The maximum building height sta= ndards map Fig 3-20 must be revised—first annotated so that within the Natio= nal Register District and the residential districts the height limit is limited= to what currently exists, and second re-studied and re-reasoned to solve some central planning issues.

#7:&n= bsp; SPOTLIGHT AND QUOTE THE SEC’Y OF INTERIOR STANDARDS

Sec 409 of the Redevelopm= ent Plan requires that

“rehabilitation of buildings determined by the Agency to be of architectural and/or historical significance shall be rehabilitated in accordance with the “Secretary= of the Interior Standards for Rehabilitation”.

This Plan addresses new construction and specific wa= ys to make it compatible, and does an admirable job of that. It has been over 25 years since the Hollywood Boulevard National Historic District was officially designated, a= nd since a Plan to protect the resources was mandated. The community has yet to see design guidelines based on the Secretary of the Interior’s Standards, which acknowledge the importance of this internationally known resource, assist property owners in their preservation, and prevent further adverse effect to the components or to the district as a whole.

Recommendation:= Sec. 4.4 should not excerpt the Secretary of the Interior Standards, but should rather simply present them verbatim. This page should note that their use is a requirement of the Redevelopment Plan. Reinterpr= eting the Standards is a dangerous and unnecessary undertaking. Specific sources must be cited for analyzing the impact of new construction on historic districts, and Hollywo= od Heritage can assist CRA in finalizing this section. Readers should be refer= red to a preservation professional, to the National = Park Service, and other specific sources.

The Standards must be = the starting point for any review in an historic district, including analysis of the effect of an undertaking on the district as a whole.

COMMENTS ON NEW BUILDING AND PARKING D= ESIGN STANDARDS AND GUIDELINES

Proposals in this Plan to encourage sensitive new development are highly detailed and well-considered. The Sec. 3.3 on Architectural Char= acter (p. 26-37) is very comprehensive.

Particular items Hollywood Heritage strongly supports are:

1.&n= bsp; Vision: Page 8

2.&n= bsp; Plan goals: Page 10

3.&n= bsp; Build-to lines: Page 14

4.&n= bsp; Demolitions to create parking lots: Page = 44

5.&n= bsp; Parking structures not visible from major streets; Page 46

6.&n= bsp; Applying standards to district contributors: P 51

What we notice is that gu= idelines are focused on replacing existing empty lots, or more eerily existing histo= ric buildings, with new buildings. We believe a major development opportunity has not been studied—the one = that will start to occur in Hollywood. That is the “low front-tall back” project, where the historic building gets saved and its permissible density gets built behind it. Rather than end up with façade-ectomies like the Bernard’s luggage, it is vital that this realistic scenario be studied with the same = care as we see in the Plan given to wholly new construction.

The other scenario seen nationwide in historic districts is applications to add upper floors to existing buildings. Without formally studying this, the Agency misses the opportunity to deal with the coming applications.

There are sites on Hollyw= ood Boulevard, within the National Register Historic District, which are curren= tly vacant. For these sites, as f= or all properties within the boundaries of the historic district, we believe that = the Secretary of Interior Standards and Guidelines for the Rehabilitation of Historic Properties, which cover both rehabilitation and new infill guideli= nes for new or rehabbed buildings, should be mandated in this Plan. The potential multi-family historic district north of Hollywood Boulevard is Hollywood Boulevard Holan area of extreme sensitivity; this a= rea requires special attention.

The following changes and= edits to the Plan sections of new building and parking design:

Page 46: Surface parking lots should be prohibited on Hollywood Boulevard.
Figure 3-72 should extend the subterranean parking requirement to the entire National Register District area.

Page 11: Hopefully a better example of ground floor retail than the overscaled ba= se of the Hollywood and Vine project can be found.
Page 12: The cause of the “perim= eter block” buildings and “individually differentiated structures” is the zoning code. Historically, the perimeter block buildings continued through the co= mmercially-zoned area of Hollywood on the north-south commercial streets. They were torn down in the 1950’s-the present for parking, destroying the continuity of the commercial area and creating a poorly-functioning<= /span> commercial strip.
Fig 3-2 overlaps zoning code and fire code issues.&nbs= p; Prior to finalizing this plan, these well-intentioned regulatio= ns should be tested against actual sample sites.
Page 33: Historic paint analysis has s= hown that some historic buildings were not the colors cited.

Recommendation: The Plan should be edited to make clear that its standards and guidelines a= re for new compatible construction. Work on existing historic buildings, on historic building storefront= s, and on additions to historic buildings must follow the Secretary of the Interior Standards.

Hollywood Heritage recommends studying the real “second-generation” development applications, which always happen in historic districts—“low front-tall back” buildings, and upper story additions.

Hollywood Heritage suggests strengthening a number of these good initiatives with the following:

1.&n= bsp; Demolition prohibition: Buildings cannot be demolished prior to obtaining a valid building permit and demonstrating financial capability to build.

2.&n= bsp; No empty lot shall be permitted to remain unimproved

3.&n= bsp; Parking lots: Page 44. Add requirement that ille= gally created parking lots shall be improved or removed from use.

<= /span>

USE OF TERM “CONSERVATION”

The words “conservation” and “preservation” are both used in the Redevelopment Plan. Today, in the United States, the t= opics covered in this Plan under “conservation” are generally called “preservation”. “Conservation” is used in the sense of “neighborho= od conservation” for non-historic areas, and used to describe the physic= al activity of restoration and stabilization.

Recommendation:= Hollywood Heritage recommends using standard preservation terms. = This will lead readers to the standard sources of further information, such as t= he National Park Service’s Preservation Briefs and the Secretary of the Interior.

INTEGRATION WITH OTHER CRA PLANNING DOCUMENTS

It is alarming to us that= the documents currently being prepared by the Agency are not integrated in their approaches.

While all of the areas be= ing studied and planned for differ in their “boundariesR= 21; and approaches to certain issues, the recognition, preservation, and design treatment of historic resources, should not be different in their detail, manner = and approach.

The current lack of integ= ration, we assume, is partly due to the fact that different consultants and staff in various agencies developed the new Intensive Historic Resources Survey of t= he Hollywood Redevelopment Project, the Hollywood Boulevard Plan, and the Suns= et Boulevard Plan.

Lack of integration of th= e plans with the survey and with each other will inevitably lead to conflict as des= igns and developments are planned using the guidelines only to have to be altered upon the later “discovery” of historic resources during the planning process.

Recommendation: Address lists and maps of the iden= tified historic resources in each of the plan areas must be included in every plan= ning document.

The high degree of det= ail in standards and guidelines in this Plan may be helpful in your final editing = of the Sunset Plan.

INTEGRATION OF PLANNING DOCUMENTS W= ITH CITY PLANNING

It is also alarming and mysterious to us that the documents currently being prepared by the Agency = and by the Planning Department, though seeming to share similar goals, are not integrated in their approaches.

The current lack of integ= ration, we assume, is partly due to the fact that the new Intensive Historic Resour= ces Survey of the Hollywood Redevelopment Project was prepared by CRA, and has = yet to be incorporated into the revised Community Plan.

Recommendation:= We welcome the opportunity to work= with you proactively to seer that your information gets used by City Planning, a= nd influences their decision-making.

CONCLUSION
The current version of the Hollywood Boulevard and Franklin Avenue Design District Urban Design Standa= rds and Guidelines does not encourage the protection and preservation of resour= ces within the nationally significant Hollywood Boulevard National Register District, the sensitive adjacent neighborhoods such as the newly identified Hollywood North Multi-family Residential District, nor significant individu= al resources throughout the Plan area.

Hollywood Heritage insist= s on the integration of this Plan with the Intensive Survey, Sunset Boulevard Plan, = and Community Plan to ensure that all concerned with protection and development= of resources in the Hollywood Community Plan Area and the Redevelopment Plan A= rea have access to all information on historic resources required to develop responsibly within the area. =

The Agency and the Planni= ng Department, as the permitting agencies of the City responsible for Hollywoo= d, are the stewards of its historic resources. Decisions for development shall not impair the integrity (setting, location, materials, association, and feelin= g) of Hollywood= 217;s historic resources through attrition, demolition, or inappropriate alteration. The Plan should facilitate good preservation practice and stewardship of resources. This approach will ensure the heal= thy economic development of this popular tourist destination and provide a liva= ble community for its residents.

Hollywood Heritage respec= tfully requests that the Plan use the term “preserve” as opposed to “conserve” in the document.&nb= sp; Standard preservation practice for plans in the = United States refer to preservation.

Hollywood Heritages remai= ns appreciative of the Agency’s efforts in this extremely important Plan. We value and respect the Plan’s inclusions. We w= ill work diligently with you to see that caliber of effort in filling in the urgently missing pieces-- to preserve and protect the Hollywood Boulevard Commercial and Entertainment District, its historic residential neighborhoo= ds, and entertainment industry related sites.

Sincerely

Brian Curran

Vice-President, Hollywood Heritage

Cc: CRA: Chris Essel, Leslie Lambert,

Council Offices: CD13 Eric Garcetti, Kelli Bernard, CD4 Tom LaBonge, Rene Weitzer, CD5 Paul Kor= etz, Chris Koontz,

Office of Historic Resources: Ken Bernstein, Janet Hansen

Neighborhood Councils: HSDNC Maripat Donovan, Steve Whiddon, Ed Hunt, CHNC Debbie Wehbe, Scott Campbell, Lau= rie Goldman HUNC Susan Swan, Scott Larson, HHWNC Anastasia Mann, Barbara Witkin, EHNC David Bell, Alfredo Hernandez