Ms

HOLLYWOOD HERITAGE, INC. =

 P.O. Box 2586  

Hollywood, CA 90078  =

(323) 874-4005 • FAX (323) 465-5993

Christopher Rudd

Senior Planner

Hollywood Community Redevelopment Agency

6255 Sunset Boulevard

Suite 2206

Hollywood, CA 90028

August 11, 2010

RE: Sunset Boulevard and Civic Center = Urban Design Plan and Civic Center Guidelines

Dear Mr. Rudd:

The Board of Directors of Hollywood Heritage, its Preservation Issues Committee= and its members congratulates CRA on its drafting of the Sunset Boulevard Urban Design Plan. While we are imp= ressed with several aspects of this design plan, we are concerned about the omissi= on of some particular issues that prevent this Plan from being successful and legally compliant.

The purpose of this Plan, as stated in the Redevelopment Plan, was to protect residential neighborhoods from Regional Center (large scale neighbor= ing) development. Many of these are historic neighborhoods. Until= the protections are added into this Plan, it is not compliant with its legal requirements.

Hollywood Heritage has conveyed our concerns verbally before at the various public workshops and during private meetings with staff, however we sincerely hope that this formal response will help in revising the current draft plan. In an effort to be clear and conci= se, Hollywood Heritage is focusing our comments on our primary purpose in this process--- preserving existing historic resources, both on Sunset Boulevard= and in adjacent neighborhoods.

We do not believe that silence on this subject in this Plan is acceptable, and ca= nnot agree that Sec. 511 of the Redevelopment Plan is a satisfactory substitute = for the neighborhood protections mandated for this Plan.

PLAN PURPOSE: NEIGHBORHOOD PROTECTION= :<= span style=3D'mso-spacerun:yes'>

The purpose of the Sunset Boulevard Plan was articulated in Sec 506.2.2 of the = 1986 Redevelopment Plan and in the follow up 2003 amendment to the Redevelopment Plan. The “Hollywood Co= re Transition District” Plan was to ameliorate the incompatibility of the intensive proposed developments on Sunset with the residential neighborhoods around it. The topics were re= quired to be

“circulation patterns, landscaping, park= ing, and the scale of new construction,” which were to be, “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 compa= tible with adjacent residential areas.”(Hollywood Redevelopment Plan)<= /o:p>

Since that time, the neighborhoods south of Sunset have improved dramatically, ow= ing to community and homeowner activism cleaning up properties, parks, and crime. The blight in this are= a is reversing, and property owners need aggressive protection in order to conti= nue the improvements.

The Redevelopment Plan mandated particular geographic areas to be covered by th= is Plan, and it appears some are missing.&nbs= p; If those are covered instead by another Plan, that must be made explicit.

Recommendation: These legal requirements for this = plan need to be stated in the Sunset Plan introduction, with a map showing the specific area required to be covered.    The Plan has grown in = vision beyond the legal requirements, and does not appear to cover the legally req= uired areas. Clarity is needed on how it meets the requirements stated in the Redevelopment Plan.

MISSING PLANNING INFORMATION:

The information that is always the backbone of Urban Design Plans to protect residential neighborhoods is not included in the Plan. These include;<= /o:p>

·        Hollywood Core Transition District Map: In order to provide compliance wit= h the Redevelopment Plan, a map showing the areas the Plan was mandated to protect must be included

·        Existing Land Use Map: A map = of current land use and development intensities in the Plan area must be included. Without this, the n= eed to “transition” in any particular area is unknown, and the effect = of the Plan on its goal is unknown.

·        Neighborhood Identification: The neighborhoods that the Plan ostensibly is supposed to protect have not been identified. The map on page 3= 0 is insufficient. Without identif= ying the neighborhoods, which require protection, a Plan can’t begin to gr= asp the characteristics of them in any detail, and how Regional Center developm= ent will affect them.

·        Proposed Land Use Map: This should actually be two maps—one for current zoning, and one for the proposed Community Plan.

·        Conflicts Map: Currently there is= no clarity in the Plan as to where new development can be expected occur.&= nbsp; An overlay map of proposed land uses and development intensities, indicating conflicts with existing land uses, is missing. Without actual mapping, the basis = for the Plan is conspicuously absent: where are the potential development sites; where are the threatened neighborhoods; where is up-zo= ning creating a threat that is not currently there; how will Regional development actu= ally affect neighborhoods with increased traffic, shade and shadow, etc; and of course where is this develo= pment threatening historic buildings and neighborhoods.

Recommendation: The Plan must show the basic land = use mapping in order to demonstrate compliance with the Redevelopment Plan. We recommend that these maps be in= cluded in a revised draft. No one can evaluate whether the proposals in this Plan are effective, or desirable, wh= en they are presented without the context of what the plan is designed to prot= ect.

MISSING INFORMATION REGARDING HISTORIC BUILDINGS:

·        Hi= storic Resources Map- Neighborhoods: Hollywood Heritage is doubly distu= rbed by this particular mapping omission because many of these communities have = been recognized for 25 years as historic neighborhoods—since the time the Redevelopment Plan was adopted-- meriting specific levels of protection and= the availability of new expanded historic resource information provided by the recently completed Intensive Hollywood Resources Survey. In the section of the draft plan entitled “Preserving Neighborhood Character”, the Plan mentions= and provides a map of the residential enclaves Leland Way and Selma-LaBaig. The historic residential neighborh= ood districts of Afton Square (located between DeLongpre Ave and Fountain Ave, between Vine St and Gower St.) and newly identified neighborhood clusters l= ike Colegrove (located roughly between Highland and Wilcox and between Leland W= ay and Fountain Ave.) Sunset Historic District (located roughly between McCadd= en and Schrader Blvd, between Selma and Sunset; with a branch to the south) and the Mansfield District (roughly between Orange and Citrus, between DeLongpre and Fountain), which are historic, should be specifically mapped.

·        Hi= storic Resources Map—Individual Landmarks: No effort has been made to integrate informat= ion publicly available for 25 years or the 2009 Intensive Hollywood Resources Survey by Chattel Architecture into this plan. This Plan must have a map that identifies all HCMs, historic districts, and identified historic resources within the boundaries covered by the plan.= On Sunset Boulevard, Sunset between McCadden and Wilcox is the only = area mentioned as being historic, while Sunset Boulevard between Wilcox and Wilt= on also has an incredibly significant collection of structures including; three historic studios, 3 historic theaters, and other identified monuments.=

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Recommendation: This Plan must= have a map that identifies all HCMs, historic districts, and identified historic resources within the boundaries covered by the plan. These maps must be included = in a revised draft. No one can eva= luate whether the proposals in this Plan are effective, or desirable, when they a= re presented without the context of what the plan is designed to protect.

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ACTUAL NEIGHBORHOOD PROTECTION:

Key Concept E in the Plan is a desirable sentiment, but the Plan does not address three of the usual critical ways planning protects neighborhoods:

1.&n= bsp;     Neighborhood protection: The Pl= an offers guidelines for new construction on the residential streets themselve= s, but leaves out the guidelines that will protect those residential areas = from large scale Regional Center development.&n= bsp; For example, the drawing on page 37 indicates that a base building of parking structures backing on the residential streets is desirable.

2.&n= bsp;      Preservation standards are critical for protecting existing landmarks in the Regional Center area, and for protecting historic neighborhoods from incompatible intrusions. Whil= e this Plan tries hard to mandate compatible new construction, in historic neighborhoods the overarching legally applicable controls under the Redevelopment Plan Sec 409 are the Secretary of the Interior Standards, whi= ch the Plan fails to mention.

3.&n= bsp;     Encouraging upgrading and preservation of existing buildings: Because new development is only pa= rt of the future, it is critical to deal with upgrading and adding to existing= properties. Adaptive re-use, additions to existing properties, solving parking issues for existing buildings, implementing streetscape improvements at existing buildings, sup= port for diversity of uses —these are the building blocks of planning to address existing buildings. <= o:p>

Recommendation: We recommend that the Plan clearly articulate how Key Concept E is achieved—how it protects residential neighborhoods. (We see ideas = in the Plan, requiring building “bases” to be compatible height-wise w= ith adjacent residential neighborhoods.) In order to clear up confusion, the Pl= an must cite and explain the Secretary of the Interior Standards.

Many standard neighborhood protections are also missing, which if added could ma= ke this Plan compliant with its purpose:

<= span style=3D'mso-list:Ignore'>·        reducing the permitted density of an area below the density otherwise permitted in o= rder to preserve clusters of houses (Sec 505 Redevelopment Plan)

<= span style=3D'mso-list:Ignore'>·        providing incentives to restoration and upgrading of historic properties in the Implementation Plan

<= span style=3D'mso-list:Ignore'>·        providing assistance to property-owners—such as Oakland’s “Rehab Right”—to encourage appropriate remodeling

<= span style=3D'mso-list:Ignore'>·        providing reasoned examples of additions to existing buildings to show how densities = can be increased without destroying existing neighborhood character<= /span>

<= span style=3D'mso-list:Ignore'>·        prohibiting through traffic in selective locations;

<= span style=3D'mso-list:Ignore'>·        prohibiting street level open garages facing residential areas;

<= span style=3D'mso-list:Ignore'>·        prohibiting loading docks adjacent to residential areas;

<= span style=3D'mso-list:Ignore'>·        limiting parcel assembly;

<= span style=3D'mso-list:Ignore'>·        limiting building height and shade and shadow on homes;

<= span style=3D'mso-list:Ignore'>·        requiring multi-parcel new residential buildings to respect side yards of their underlying lots; <= /span>

<= span style=3D'mso-list:Ignore'>·        providing affirmative street tree and public improvement programs for the existing residential areas; etc. =

NEW CONSTRUCTION/URBAN DESIGN GUIDELINES:

Hollywood Heritage can complete its response when the needed basic land use mapping is provided.= The effects – and effectiveness-- of the ideas proposed in the Plan is hard to gauge now. We reserve the right to make further comment upon receipt of a more complete draft. It is unclear, for exa= mple, whether the Selma Avenue guidelines are a desirable “guideline” controlling the scale of buildings that zoning now allows, or a new and arbitrary “permission slip”.

Comments to date include:

• =    As noted above, recommendations and standards with regards to residential construction in or around historic neighborhoods is missing.

Towers should= not be allowed to be built to the line but should be set back on a base no higher than 30ft or 2-3 stories as is consistent with the existing fab= ric. page 35

It is not sol= ely a building base that should be limited to respond to the scale of a residential neighborhood. P 46

The unlimited= height on Vine Street between DeLongpre and Fountain does not provide neighborhood protection.

Page 46 shows= Fig 3.12 for Selma Avenue showing “Citizen News- New Office Building”. If this= is meant to suggest demolition of a landmark for a new high rise, it is i= mproper

MORE NUANCED UNDERSTANDING OF URBAN FORM

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Hollywood Heritage argues that the Plan’s future vision for urban form-- as sho= wn in Key Concept A-- “Distinct Urban Form and Skyline”—is t= oo simplistic. It looks at transportation corridors as the reason for intense high-rise development. We believe that the future of this nationally-recognized area should be based on more nuanced and detailed understanding, one which considers that much of the area is built out and h= as historic buildings.

Hollywood Heritage sees that this Plan focuses on new design ideas, which may be posi= tive and appropriate. They seem to= have arisen in part in response to developer proposals for regionally-based large scale buildings, principally office and hotel buildings:<= /p>

·        A new fo= cus on pedestrianization of Sunset Boulevard, and an intensification of development along Selma Avenue, both emphasizing east-west streets and corridors.

·        A new fo= cus on a Civic Center, trying to make a cohesive whole out of the current and futu= re municipal buildings and open spaces. This includes the idea attracting large numbers of people into and f= rom low-density residential neighborhoods to an area south of Sunset, but not f= or neighborhood-serving uses.

·        A new fo= cus on intensifying development along Selma Avenue, suggesting massive possible new high-rise construction with even the bases of new buildings towering over t= he existing.

Historic buildings should be protected and integral to the plan’s urban form vision. And design goals for new construction like tower and base design, v= iew corridors, and plazas are only a part of the picture. The Plan hasn’t wrestled with “second generation planning”— the recognition that large numbers of buildings in the area already exist, will continue to exist, and= can’t afford to be made obsolete.



·        Unlike the Hollywood Boulevard/Franklin Plan, this plan does not analyze the patte= rns of existing buildings, and cites examples exclusively from other cities, wh= ich are not appropriate.

·        North-south street connections between neighborhoods and the already-existing commercial corridors are critical. Holly= wood Heritage looks for an equal focus in this Plan on the north-south streets—Cahuenga, Vine, “The Sunset District Loop”. The p= lan tries to deal with the compelling need to upgrade the pedestrian experience= , so people can and will walk to the grocery stores, dry cleaners, and music shops. (This issue was brough= t up by the public in the Plan workshops.) Increasing the focus on pedestrianiza= tion at north-south streets to support the neighborhoods should be added to the Implementation Plan, guiding future public expenditures.

·        Hollywood Heritage looks for a more nuanced understanding of the importance of econom= ics and circulation on urban form. The key to economic success in Hollywood is capturing the purchasing power of i= ts residential neighborhoods—keeping the economic function of Main Street.     Hol= lywood Heritage suggests the existing main streets and boulevards won’t sust= ain economic diversity and health if turned solely into tourist and entertainme= nt venues and high rises. <= /o:p>

Recommendation: The Plan must incorporate more nua= nced issues into the urban form discussion, recognizing the need for north-south streets to be supported and upgraded to enable economic health, and the nee= d to understand, respect, and protect historic buildings.

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 being studied and planned for differ in their “boundaries” and approaches to certain issues, the recognition, preservation, and design treatment of historic resources, should not be different in their detail, manner a= nd approach. The current lack of= integration, we assume, is partly due to the fact that the new Intensive Historic Resour= ces Survey of the Hollywood Redevelopment Project (now complete), the Hollywood Boulevard Plan, the Sunset Boulevard Plan, and the revised Draft Hollywood Community Plan were and are being developed by different consultants and st= aff in various agencies. Lack of integration of the plans with the survey and with each other will inevitably lead to conflict as designs and developments are planned using the guidelin= es only to have to be altered upon the later “discovery” of histor= ic resources during the planning process.&nbs= p;

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.

IN CONCLUSION Hollywood Heritage encourages a fu= ll treatment of the issues of historic resource and residential neighborhood preservation and protection in this plan.&= nbsp; The inclusion of the necessary land use, historic resources, and conflicts maps omitted from the plan are a necessity for the plan to make sense. To achieve the mandated purpose, the preservation, rehabilitation and re-use of existing structures must be included, recommending specific planning tools to encourage neighborhood protection and sustainability while addressing new additions a= nd infill to sensitive historic, residential and transitional areas. These actions will move this Plan = closer to the goals of encouraging new appropriate design and development in the Sunset District while celebrating historic resources and sustaining existing residential communities.

Sincerely,

Brian Curran

Vice-President, Hollywood Heritage

Cc: CRA: Chris Essel, Leslie Lambert, =

C= ouncil Offices: CD13 Eric Garcetti,= Kelli Bernard, CD4 Tom LaBonge, Rene Weitzer, CD5 Paul Koretz, Chris Koontz,

O= ffice of Historic Resources: Ken Bern= stein, Janet Hansen

N= eighborhood Councils: HSDNC Maripat Dono= van, Steve Whiddon, Ed Hunt, CHNC Debbie Wehbe, Scott Campbell, Laurie Goldman H= UNC Susan Swan, Scott Larson, HHWNC Anastasia Mann, Barbara Witkin, EHNC David Bell, Alfredo Hernandez