Dr. Robert Manford
City Planner
Community Redevelopment Agency of the City of Los Angeles                  July 12, 2005
654 S. Spring St.
Suite 700
Los Angeles, CA 90013

Response to CIM Sunset & Vine Retail Addition and Signage Design Program, Hollywood

Initial Study Proposed Mitigated Negative Declaration

Prepared by Community Redevelopment Agency of Los Angeles (CRA), June 22, 2005

Hollywood Heritage opposes the Proposed Mitigated Negative Declaration (“Neg Dec”) for the described project. This is based on two principle concerns:

1)      The impacts, including cumulative, of the proposed signage and

2)      The removal of a historic building, as declared by the CRA in the 2003 Final EIR and adopted as such by the Los Angeles City Council, May 20, 2003

The Neg Dec somehow is not aware of the 2003 FEIR in that it states on page 19 that the site does not contain any historic buildings. The Sunset and Vine Tower was designated as historic in the 2003 FEIR for the Hollywood Redevelopment Plan Amendment (Plan). Section 511 of the Plan clearly states the conditions and terms under which this designation can be challenged, with the proceedings as described taking one year.

The Neg Dec has somehow ignored the status designated in 2003 to thereby avoid the conditions of the Plan as to how to deal with an historic structure. The report attached by Teresa Grimes to the Neg Dec has no standing in altering or amending the adopted 2003 FEIR or the 1986 Hollywood Redevelopment Plan. Only by meeting the conditions of Section 511, and this was used as evidence in the 1986 SHOT lawsuit versus the CRA, can any change in the historic status be made.

It should also be noted that while the Plan does refer to local, state, and federal standards, modification in the meaning of these standards cannot be retroactively applied to these assessments made prior to the changes. The CRA may require an update of their coding system to better reflect others, but at the time the “4s” designation was given the meaning was clear. Additionally, any designation (including level 5 and above at that time) provided for protection under Section 511 of the Plan. To make changes to the wording of the Plan as is proposed here, is illegal without an amendment to the Plan and is therefore subject to legal action. It should be further noted that “no permit filed with the city shall be considered to conform with this Redevelopment Plan unless and until requirements for this Section are met.” (Plan, Section 511, Page 44). Therefore no work can proceed on this site if Section 511 is not met.

The negative impact of the proposed project as defined under CEQA would be significant, with no mitigation possible. By demolishing the exterior skin of the building and replace it with a totally different design and by eliminating the open plaza space the base of the building, no architectural integrity of the building would remain. It would become for all intents and purposes, a new structure.

The Neg Dec, therefore, fails to recognize and thereby address the significant negative impacts to section “1. Aesthetics, 1b”. It is then severely compromised since this addresses the entire premise of the proposed project. For these reasons, as stated here, the Neg Dec is without merit and must be rejected.

The issue of “Supergraphic” signage is another major concern. Obviously this issue cannot occur without the concerns about historic demolition being allowed. Our rejection of the “1. Aesthetics” section would terminate the development of the proposed signage addition and variances. Some comments are included here anyway to hopefully avoid further Neg Dec problems.

Even though Hollywood has the most lenient and generous sign ordinance in the city, if not the country, CIM wants more. The proposed project plans for variances to get thousands of square feet of billboard signage that even the current code would not allow (page 14).

The Neg Dec dismisses these requests and overall proposed signage as practically good for the community and that they would “contribute to the visual uniqueness of the Hollywood area” (page 20). “Uniqueness” is true, but more as a form of high-rise blight, not an aesthetic improvement, hence significant negative impact would result from these signs in section “1. Aesthetics” (page 19).

The Neg Dec compares the proposed supergraphics with other nearby signs as being overall the same, but these four signs are 140 feet tall by 36 feet wide. There is only one other building in all of Hollywood that is taller than these signs, i.e. the signs become the 3rd, 4th, 5th, and 6th tallest structures (they are in a lighted frame, attached visually to the Sunset and Vine Tower) in Hollywood. The Neg Dec would have one believe that they are similar to other such signs, which is the same as comparing the size of a tuna fish to that of a whale because they both swim in the same ocean.

The Plan though is quite the opposite in its interpretation of signs such as this as stated in Section 516:

“Therefore, it is the intent of the Plan that the Agency may, after public hearing, adopt additional sign and billboard standards for a portion of the entire Project Area which may be more restrictive than City standards in order to further the goals of this Plan or the objectives of a special district as established by this Plan.”

This would rebuke the current expanded use of billboards, supergraphics, etc. as granted by the city and demonstrate the negative impacts from such signage, including that as proposed here, as not meeting the goals of the Plan.

Robert W. Nudelman
Director of Preservation Issues
Hollywood Heritage