Re: Response to CRA/LA Negative Declaration For The Proposed Demolition of Property at 1717 N. Bronson Avenue in Hollywood, Dated December 16, 2005

The Negative Declaration (Neg Dec) is both deficient and inaccurate. In addition, it continues a highly biased and prejudicial treatment of the Hollywood Redevelopment Project Area’s historic resources that have been approved and affirmed by the CRA, the Los Angeles City Council, and the California State Supreme Court on multiple occasions.

This particular concern is based on having developers prepare Neg Decs that are attempting to illegally override the 1986 Hollywood Redevelopment Plan and EIR (Plan) and a 2003 amended version. Both listed this property as significant, giving it the National Register designation of “3S,” or “appears eligible for the National Register as a separate listing through survey evaluation.” This “3S” designation was recorded again in 1991 by the State Office of Historic Preservation for CHRIS. Furthermore, historic surveys and reports in 1979, 1986, 1991, and 2003 all concluded this structure’s significance as “3S.” All of this information is in the Neg Dec, which also includes the oldest survey, from 1979. That survey’s information appears to match that of the Neg Dec’s information prepared in 2004, twenty-five years later. The Neg Dec makes no assumptions or assertions that the property’s appearance has changed in any way since 1979. Also, it should be noted that the 2003 EIR approved survey was done by the same firm, albeit with a different name, that prepared this Neg Dec a year later.

Yet nowhere in the Neg Dec is any information given or argument presented that demonstrates or even hints at the previous four approvals as being incorrect, never mind totally inaccurate as the Neg Dec now claims by reversing their findings of historic significance. The CRA and the City of Los Angeles have defended both the 1986 and 2003 Plans and EIRs in court as being accurate, making no mention that certain protective elements, which the historic designations are used for under CEQA, are inaccurate and unenforceable. The 1986 EIR was argued as such to the California State Supreme Court in the SHOT lawsuit and appeals. The CRA and the city have had more than ample opportunity to remove any “mistakes” from the Plan or EIR and the attached documents. Nothing regarding historic designations has been removed or modified during the CEQA process and subsequent legal actions, or under state redevelopment law.

Then what could ever be the basis for a Neg Dec to be issued for this site? Nothing has changed except the party who is paying to prepare the Neg Dec’s historic evaluation report. The Neg Dec version was paid for by the property owner who is proposing to demolish the structure, and the preparer, Jones and Stokes, is giving them the conclusion that they want, even if there is nothing to back it up. This might have some credence if they would now state that the survey they prepared for the 2003 EIR was fraudulent. But as they provide no evidence for that, it can only be presumed that their conclusion is political and not based on fact or CEQA law, and is therefore invalid and without merit. It is a biased assessment by its very nature and the CRA and the city must respect its findings as such. Or they can explain how four previous government paid-for surveys were inaccurate as, again, no such documentation is provided in the Neg Dec.

Historical Significance of 1717 N. Bronson Avenue

Upon reviewing the Neg Dec itself, it is clear that it is poorly prepared and does not meet the requirements of CEQA. It does not explain why everyone else’s, including their own a year earlier, historic surveys gave the structure a “3S” level of significance and why it is not so now. The description of the house is that it was built in 1904 and had a garage built behind it in 1920-23. The house had additions of a different style made to it in the 1930s and these appear to have left the 1904 house intact underneath with significant sections of it remaining visible as original. Despite the apparent exterior having had little or no modifications made to it for over 70 years, no description of the condition of the interior is given. The National Register does not simply look at a building to see if it is in a completely original condition. If so, very few buildings would be eligible. The condition refers to the “period or periods of significance,” which is almost always to be at least 50 years of age. Modifications or additions can be considered an important part of a structure’s history, especially if done for a purpose of historic significance, such as is the situation with those modifications made here in the 1930s.

When constructed in 1904, Hollywood Boulevard was a residential street with a few scattered homes (it wasn’t even Hollywood Boulevard until 1910), known then as Prospect Avenue. During the 1910s and 1920s commercial development moved onto Hollywood Boulevard, resulting in the demolition of existing homes or the building of retail strips in front of residential properties. Only two such homes survive from this era today, the Janes House (1905) which had a gas station built in its front yard and the home in the Neg Dec. Being the older of the two, this is the oldest known surviving structure built on Hollywood Boulevard (Prospect Avenue). This does give the house a significance of “3S” or better.

The modifications point to the change that made the house’s survival possible. By realigning its entry was from Hollywood Boulevard to Bronson Avenue it was able to survive. The retail in front that blocked the original entrance was built by famed Hollywood pioneer C.E. Toberman in March 1919, “the first of his de-centralized shopping centers, an idea he had apparently long before others.” “Accordingly, he built a group of shops and a brick garage at Hollywood and Bronson, at that time an outlying area.” (Free Enterprise, a Biography of Charles E. Toberman by Grace G. Koopal, 1970, page 217, 293 [“north-west corner of Hollywood and Bronson”]).

The modifications cited in the various surveys are all well over 50 years old, intact, and do not replace the 1904 house, only add to it and realign it 90° so that it could survive with the retail constructed in front. These modifications are evolutionary and show how this house survived when all but one other was demolished, and that house’s setting has been substantially altered unlike the subject property, where the evolution of Prospect Avenue to Hollywood Boulevard can still be seen.

It also should be noted that there is significant importance of the “new” 1919 addition having been built by Hollywood’s most prominent pioneer developer, C.E. Toberman.

The Neg Dec dismisses this significance by stating on page 14: “No historically important events are known to have occurred at this site.” This twists the federal regulations by looking at only one part of one section. The actual text includes the following:

How to Evaluate a Property Within Its Historic Context.

Historic contexts are historical patterns that can be identified through consideration of the history of the property and the history of the surrounding area. In accordance with the National Register criteria, the historic context may relate to one of the following:

• An event, a series of events or activities, or patterns of an area’s development (Criteria A).

(National Register Bulletin 15 rev. 1991, page 7)

For the reasons given in architectural evolution and for its sheer ability to survive for over 100 years as the sole remaining house in its original location from Hollywood’s origins on Prospect Avenue, the 1717 N. Bronson house meets these stated requirements for Criteria A of the National Register. Its modifications defined its context in Hollywood’s history as no other structure existing today does, demonstrating “a pattern of the area’s development.”