Ms. Pauline Lewicki
Senior Planner
Community Redevelopment Agency of the City of Los Angeles
354 S. Spring St. February 10, 1999
Suite 700
Los Angeles, California 90013

Hollywood Heritage, Inc. (HHI) is a non-profit, member based organization dedicated to protecting and encouraging Hollywood’s history, especially its structures which have architectural or cultural significance for Hollywood. This proposed project affects three such buildings:

1. The Doolittle Theater, originally the Vine Street Theater;
2. The TAV Studios, formerly the Merv Griffin Theater, ABC Studios, Tom Breneman’s Studios, etc;
3. The secondary or northern section of the TAV Studios, originally the Hollywood Roof Ballroom.

Potential indirect impacts may also affect neighboring historic landmarks and cultural resources.

Though HHI conceptually supports that idea of this project, fundamental and legally precedent setting issues remain to be dealt with in the Final EIR before our actual support. Previous discussions with the developer and in the DEIR have so far failed to resolve these issues.

The concerns here center on the expansion of the project to the Doolittle Theater and the city owned parking lot across Selma Avenue. Parking requirements have not been adequately addressed to meet the demands of the Doolittle Theater (approximately 1050 seats), 20,0000 square feet of new office space, 5,000 square feet of new retail, and 5,000 square feet of new restaurant space on the site, in conjunction with existing parking lot users. These include the Francis Howard Goldwyn Hollywood Public Library, the Ivar Theater (approximately 350 seats), the Taft Building, the Broadway Hollywood Building, and the Plaza Hotel (now senior housing).

The Broadway and Taft buildings contain over 350,000 square feet of office space, and along with the Plaza Hotel are National Register eligible buildings according to the Hollywood Redevelopment Plan and part of the Hollywood Boulevard Historic District. As such, the CRA is required to mitigate any negative impacts to these buildings and this would include the loss of, or the inaccessibility of, existing parking.

Accessibility for the Plaza Hotel must take into consideration that these are seniors, many with disabilities, which will require appropriate access to the parking structure and reserved parking located near that point of access. Although not of landmark status, the library also requires special disability access accommodations from the parking structure.

The structure itself, if it is indeed to be built 8 to 9 levels above ground, will require architectural design treatments and artwork so as not to create visual blight. This is especially important where the structure faces the Palm Court and other views from the Plaza Hotel and the library. Replacing the scenic view that seniors now enjoy with a concrete parking structure could be a stressful impact to them. The library’s façade is primarily of glass which is facing the location of the structure. These design and aesthetic issues were left out of the DEIR and need to be addressed.

HHI applauds the opportunity here to restore the vastly underused Doolittle Theater as a part of this project. There is concern though for what the proposed restoration will entail.

The DEIR does not discuss the restoration as it claims (p. 196) that the theater is no longer historic, having gone from a 3 in 1978 to a 6 in 1995 in historic status (note: all historic status reference numbers used herein refer to the evaluation codes of the California Office of Historic Preservation). This is somewhat confusing, as the only work done during this time was UCLA’s rehabilitation of the theater about 10 years ago. This work was approved by the CRA, which could only approve work that would not negatively impact the buildings' historic fabric or status, as per the Hollywood Redevelopment Plan. In addition, this rehabilitation actually uncovered the front windows, which had been covered since 1954. The theater suffered no earthquake damage in 1994.

If there are questions regarding the building’s historic status, they must be answered now so that no further harm can come to the theater. The theater’s façade and hopefully its interior must be restored as part of the project. The Final EIR needs to explain how the CRA violated the Redevelopment Plan in approving damaging work to the building’s historic integrity, or clarify the error in historic status. Part of this problem may be from the 1995 FEMA survey which only classified buildings as 1, 2 or 6 (on the National Register or not) with no grading in between, so the Doolittle 1985 grade of 3 would become automatically a 6 for that survey. The Theater should be left at 3 as previously documented with subsequent additional historic fabric uncovered, and because many of the Hollywood Boulevard Historic District buildings around Hollywood and Vine have been demolished since 1985 (Gilbert's Books, Ontra Cafeteria / Post Office, Brown Derby Restaurant, Hastings Hotel, West Coast Ensemble Theater Building, etc.) increasing the theater's historic value. This is also important so that the developer can take advantage of Federal tax credits on their restoration work, which would not be allowed on the project as described in the DEIR.

HHI also appreciates the developer, Doug Brown, stating at the February 4, 1999 public hearing that his company will "restore the Doolittle Theater to its original appearance." HHI also stresses that new construction adjacent to the theater must reflect on its restored appearance and proximity to the edge of the Hollywood Boulevard Historic District (none of these issues were covered in the DEIR). Restoration plans and new building designs should be included in the Final EIR and should be done in accordance with the Secretary of the Interior's standards for historic buildings.

HHI is not at all satisfied with the proposed plans to demolish these two connected landmark structures as part of this project, and strongly opposes any such actions. What HHI is willing to support is a compromise where the eastern and (potentially) northern facades are restored and incorporated into the new project as part of the exterior or as a, more or less, free standing façade in front of the new structure.

We do not make this compromise lightly. With only the rarest of exceptions would HHI support preservation of only a façade, but due to the conditions of the existing structure and the potential to architecturally meld the historic façade with the design of the new structure, we will accept a façade only restoration in this case. It should be noted that all of the perimeter walls are standing and the roof is partially intact. Only the eastern and northern walls, though, possess noteworthy architectural detail. It is especially important to maintain these street façades as so many of the surrounding historic buildings have been demolished since 1985 (see above) making this building's visual impact in maintaining the historic streetscape all the more important to Vine Street and the adjoining Hollywood Boulevard Historic District.

Unfortunately, the DEIR attempts to build a case against such an adaptive reuse of the historic façade, preferring a token preservation of one of the elements, a sign base, which would then be covered over with twice as much signage, making its reuse a farce (Technical Appendices Vol. II, p. 15) and the two relief panels which would lose their historic context and be lost on the new structure. This is not acceptable mitigation, nor does it meet the requirements to justify a Statement of Overriding Considerations as is required here for CEQA compliance. Additionally, the DEIR proposed mitigation meets neither the spirit, the intent, nor the law, of the 1986 Hollywood Redevelopment Plan. Restoration of the façade and its integration into the new structure would at least represent some mitigation under CEQA concerning historic preservation.

The case presented in the DEIR to downgrade the TAV Studios building from 3 to 5 has no standing and would not hold up to a challenge. The property received two historic evaluations as stated in the DEIR (Technical Appendices Vol. I, page 38 and page 42), but the second one, in 1985, was part of the requirements of the Hollywood Redevelopment Plan (approved may 7, 1986) and is a part of that legal document as such. The 1985 survey was not part of the Hollywood Revitalization Project as the DEIR claims, but the 1975 cited study was. Our interest therefore is in the 1985 survey.

The DEIR states that for a building to be eligible for listing in the National Register (the criteria used for inclusion in the 1985 CRA mandated survey) at least one of four criteria must be met. The DEIR correctly admits that the building meets two of the criteria today, as well as it did in 1985 (Technical Appendices Vol. I, page 38 and 42), while a third criteria is not applicable neither in 1985 nor today.

Yet, somehow the meeting of two criteria, when only one is required, is ignored. The fourth criteria, the only one the DEIR is apparently interested in, concerns (in this case) exterior design and architectural integrity. The EIR claims (Technical Appendices Vol. I pages 38 and 42) that "While design can still be perceived, it is seriously impaired by fire damage" (page 38) and "fire damage and subsequent deterioration . . . have impaired the structure's integrity to the point where it can no longer convey most of its architectural significance in the historic context" (page 42). This is not true when compared to the 1985 CRA survey.

To back up its claims, the DEIR shows photos of the building in the early 1940s, then compares them to the condition of the building in 1998. This is a complete misrepresentation of the facts involved here. The condition of comparison must be from 1985, which was the year of the legally approved historic evaluation of the structure, to 1998.

As the DEIR bases its downgrading only on the condition of the building's exterior, then, the degradation of that exterior (façade) must be proven in the DEIR to be substantial. Damage to the interior is not of concern to modify the 1985 historic survey, which did not include references to interior, and the DEIR does not cite any historic elements in the building's interior (there haven't been any since 1951) as reasons for downgrading.

Comparing the 1985 to 1998 (or 1999) condition of the building's exterior is then the actual reference standard to be used for any proposed downgrading. The principle damage caused by the two fires to the exterior includes the flaking of paint (non-original), the breaking of some second story windows and some of their metal frames, the loss of some of the second story glass blocks, and some minor stucco damage to the roof molding and around some of the windows. The first floor appears as it did in 1985 minus parts of the 1970s marquee and the boarding up of the front door. This minor damage is easily restored, and additional restoration by removal of exterior additions from the 1960s, 70s, and 80s would reveal even more historic fabric than was seen in 1985. The change from 1985 to 1999 is obviously not substantial, nor does it confirm the claims made in the DEIR for loss of significance, nor would it validate a Statement of Overriding Considerations under CEQA to demolish the building.

To attempt to downgrade the historic status of this building because of these minor and reversible issues would be to violate the protective safeguards of the 1986 Hollywood Redevelopment Plan and would be a false statement of the building's historic integrity and status. The recently restored Grauman's Egyptian Theater had less of its original exterior remaining, requiring extensive restoration, and structurally was in serious condition. To set a legal precedent as proposed here could have been used to prevent the restoration and rehabilitation of the Egyptian Theater, and would endanger other landmark buildings in Hollywood and elsewhere, now and in the future.

It should also be noted that numerous calls and letters were sent to the building's owners and the city of Los Angeles Building and Safety Department, as well as extensive media coverage, concerning the accessibility of the building and the potential, or later, continuing potential, for damage to the building. Nothing was done by the owners nor the city to adequately secure the building as is required by law. Condoning demolition by neglect of Hollywood's historic landmarks cannot be allowed as a policy of the CRA and the city as the adoption of this DEIR would allow.

Hollywood Heritage realizes that the building's interior has suffered significant damage and would have to be rebuilt as part of any rehabilitation project. As no historic fabric is left, we are willing to compromise by incorporating the historically significant façades only into the new structure. The new structure, as designed , mocks the historic one, so by incorporating the façade they would be representing the historic Streamline Moderne architecture and an element from Hollywood's entertainment past that would be a major selling point for shoppers and tourists, distinguishing this center from any other because of this inclusion of historic architecture and the cultural history of the building. It is adaptively reusing our heritage that makes the Egyptian Theater, the El Capitan Theater, and most recently the Cinerama Dome Theater and Entertainment Center stand out from the competition and be worthy of national media attention.

Another recent example of adaptively reusing an historic façade in a new building is the California Science Center, which restored the original 1923 brick façade into a 1997 structure. The DEIR states (Technical Appendices Vol. I, pg 17), the TAV Studios Building is "constructed of structural steel and reinforced concrete skeleton framework on a concrete foundation," and the concrete walls are 12 inches thick (Technical Appendices Vol. I, Engelkirk letter 10/13/98, page 1). Obviously the 1937 façade was built with an overkill of structural strength even by today's standards and definitely has more structural strength than the brick façade of the Science Center. As with the Science Center rehabilitation, the new building can be slightly set back at the top and modified in color and texture to differentiate it from the historic fabric, thereby eliminating the worry that the new building's height would be limited by the historic façade.

The TAV Studios first floor entryways were modified many times since 1937 and could be once again redesigned according to the Secretary of the Interior's Standards to fit any new entry requirements.

As noted in the DEIR (Technical Appendices Vol. I, pg. 16):

The project as proposed in the DEIR does not do this, rather it sets a dangerous precedent in violation of the Plan. What the developers are attempting to do with this project is to circumvent the Plan by illegally invalidating previous findings that were approved by the CRA and the LA City Council. Such modification can only be done by amendment to the Plan itself. Otherwise all buildings listed as protected in the 1985 CRA Hollywood Boulevard Historic Building Survey could be removed from protective status by appeals to the California Office of Historic Preservation (precedent if allowed here could similarly undermine all local historic protection ordinances in California).

What Hollywood Heritage has proposed here is a way to meet the requirements of the Plan and allow for the successful development of the site. It is not optimal for Hollywood Heritage, but it is a workable compromise to meet the legal requirements of the Plan, restore the building's historic fabric, and integrate it into a new structure.

HHI recognizes the damage to the building's interior but finds the cursory studies done to save the façade by Engelkirk Engineering (Technical Appendices Vol. I) to be lacking in an understanding of the issues and presenting, by far, a worst case scenario for rehabilitation. In any event, the facades can be saved successfully and adaptively reused as part of the new building. The value of tax credits and increased public and media attention from having this project incorporate historic and architecturally significant façades as part of it will offset any cost differences, if any would actually occur. Hollywood Heritage's main concern is the lowering of the building's historical status as a result of using inaccurate data and an illegal procedure. This would set a dangerous precedent to circumvent the Hollywood Redevelopment Plan's ability to protect historic resources in Hollywood.

Other previously outlined issues of parking and building design, rehabilitation of the Doolittle Theater and parking accessibility for existing users, need to be addressed in the Final EIR as defined here. All of these concerns need to be adequately addressed before Hollywood Heritage could approve of this project and support it before the CRA and City Council, where it will most likely be seeking public funds. Our support of the recent TrizecHahn and Cinerama Dome projects was based on the developers successfully addressing our concerns of historic preservation and design. We hope the same can be accomplished with the Hollywood Marketplace and Doolittle Theater complex.

Sincerely,

Robert W. Nudelman
Vice President, Hollywood Heritage, Inc.

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