Mr. Thomas Rothmann
City Planner
Los Angeles City Planning Department July
14, 2006
200 N. Spring Street, 7th Floor
Los Angeles, CA. 90012
Attn: Mr. Thomas Rothmann
Re: Response to LA Planning Department’s Mitigated Negative Declaration (MND), dated, June 5, 2006 For Environmental Case: ENV-2006-2587-MND; Related Cases: DIR-2006-2586-SPR for the project described as 6-Story 96,681 SF Office Building at 6040 West Sunset Boulevard, Hollywood
The MND submitted for the construction of a new 6-story structure at 6040 Sunset Boulevard fails in both its notification process and in the review of “potentially significant impacts” it would have on adjacent historic resources.
Notification
The MND was supposedly publicized on June 15, 2006. The Community Redevelopment Agency, the two adjacent property owners, and Hollywood Heritage received no notification of the MND. In fact, we received notification through the CRA that the MND would be published July 5. This led to questions as to why the June 30 hearing was occurring. The CRA told us that due to the delay in issuing the MND, there would be a second hearing in late July for the MND.
The CRA was in communication with the LA Planning Department, we were told, and they were the lead agency on this case. We assumed between the two of them that the information was correct and as no one had reviewed an MND as required by CEQA that no MND did exist. Hollywood Heritage normally receives MNDs as an interested party, as defined by CEQA and since the historic status of the surrounding buildings was based on a survey originally conducted through Hollywood Heritage, as contracted by the CRA.
Continuing this list of CEQA and planning surprises, the CRA heard that the MND had indeed been published June 15 and relayed this information to us on June 28, along with a copy of the MND via email. Needless to say, this process did not meet the requirements of CEQA for either notification or due process. At the June 30 hearing, Hollywood Heritage did ask for an extension so as to have all parties better understand the complexities of the situation concerning construction impacts both short and long-term. This was also done to make an attempt, as someone had to do, to try and bring this procedure into compliance with the CEQA notification process.
As a result of this, the hearing officer did extend the deadline for responses to July 14. Though not quite the required amount of 20 days from publishing, which was effectively, June 28, it was a step toward resolving the issue. Hollywood Heritage therefore questions the legality of the CEQA process in this case, but is responding by July 14. More time is needed as materials presented at the hearing have not been made available for review as promised at the June 30 hearing.
Failure of MND to Address Potentially Significant Negative Impacts
The MND ignores the historic significance of the adjacent property at 6000 Sunset Boulevard (East-West Studios) and thereby does not address potential negative impacts caused by this project as required under CEQA. This structure was given historic status in the 1986 FEIR prepared for the Hollywood Redevelopment Plan and again in the 2003 FEIR for the Plan’s amendment.
The structure at 6000 Sunset Boulevard has been listed as eligible for designation as a local landmark in 1986 (which is a consideration of the California Register), and again confirmed this status in 2003, and is included in the 448 buildings referred to in the 2003 FEIR. The 2003 FEIR refers to Section 511 of the Plan which “addresses the preservation, rehabilitation, and retention of properties within the Project Area” (page III.D-4). It goes on to state how Section 511 deals with de-designation from the list and the process required. Preparing an MND as done here would supersede the Hollywood Redevelopment Plan, and is therefore not allowed.
By ignoring the status granted to this property in the two adopted FEIRs and the proper procedures to deal with such a designated structure, as explained in Section 511 of the Hollywood Redevelopment Plan, the MND is deficient in its primary evidence and therefore must be considered defective in its conclusions. If no historic status is examined, the obviously, no accurate conclusions or potential negative impacts can be made, evaluated, and, if possible, mitigated.
What negative impact would occur at 6000 Sunset Boulevard that would endanger its historic status? The 1986 and 2003 FEIR Historic Structure Surveys were based on the building’s position next to the Sunset-Gower Studios and its historic relationship to the studio (formerly Columbia Pictures Studio). The actual use of the building, and thus historic relationship and/or significance, was not examined. (“The extensive research necessary to identify other properties which could possess historic, but not architectural importance, was outside the scope of the current study. Therefore, it may be possible that additional structures, not currently documented . . . could be found to qualify for designation programs based solely on historic significance.” Determination of Eligibility Report, Hollywood Project Area, Architectural/Historical Survey. Johnson-Huemann Research and Hollywood Heritage, September 1984, pages 4–5.)
Though the building was given historic status as previously mentioned, further review of its historical significance would give it a much higher level of protected status. Its designation of local significance would now be more appropriate as National Register of Historic Places eligibility when the activities within the building are taken into account.
This is based on the use of the building as a recording studio from the 1950s to the present. Most important is the fact that the five main recording studios, in particular studios 1, 2, & 3, are in their original condition from 1965. This would be from the time when the period of significance for the building becomes most important (see attachment from Hollywood Heritage Newsletter, vol. 25, no. 1, May 2006). By maintaining the building as a recording studio, these interior spaces can remain intact and in their original use. If the ability to record here is endangered, as the Technicolor building project would cause to happen, then the survival of the spaces, in their original condition, is highly doubtful due to their specific purpose and design. Therefore any significant negative impact on the use of the building as a recording studio would be a severe negative impact that would endanger the historic status of 6000 Sunset Boulevard (East-West Studios) as defined by CEQA regulations.
Conclusion
Hollywood Heritage must oppose the MND as lacking in its presentation and by not meeting CEQA procedures for notification and subsequent response time. We must also oppose the MND for its blatant falsification of the historic status of the East-West Studios Building, 6000 Sunset Boulevard, by claiming that it is not historic, despite being documented as such in two FEIRs. This opposition is augmented by not providing further research as mandated by the Hollywood Redevelopment Plan as to any additional historical significance not covered in the FEIRs. Such inadequate preparation invalidates the legality of any conclusion of “no impacts” to historic resources in the MND.
Furthermore, it should be noted that Hollywood Heritage does support the building of the new Technicolor Building. But, it must be done in a manner that is not harmful to its historic neighbors. This can be done, and representations made by the project’s proponents at the June 30 hearing, appeared to be doing that. But by their inability to provide documentation to East-West Studios of these verbal proposals made on June 30, we must conclude, for now, that the original plan in the MND is the one in effect. That plan will have severe negative impacts on East-West Studios and must be comprehensively addressed as such in an EIR to meet the requirements of CEQA, not the convoluted MND discussed herein.
Sincerely,
Robert W.
Nudelman
Director of Preservation Issues
Hollywood Heritage
jc/RWN
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