Hollywood Heritage Response to the Draft EIR of the Hollywood Community Plan
May 5, 2011
Srimal Hewawitharana
Los Angeles City Planning Department
200 Spring Street, Room 750
Los Angeles, CA 90012
Dear Ms. Hewawitharana:
The Board of Directors of Hollywood Heritage, its Preservation Issues Committee and its members, thank you for the opportunity to review and comment on the Hollywood Community Plan, and the accompanying Draft Environmental Impact Report (DEIR).
For three decades Hollywood Heritage has been a staunch advocate of the preservation and protection of Hollywood’s historic resources and has long anticipated the update of the Community Plan. We support the goal of preserving what is most significant in Hollywood, while encouraging responsible new and infill development. Our organization has nominated many of the current Historic Cultural Monuments, listed the Hollywood Boulevard Commercial and Entertainment District in the National Register of Historic Places at the national level of significance, provided technical assistance to developers and owners of significant properties, and participated in public policy discussions through the formulation of the Community Redevelopment Plan of 1986 and subsequent urban design plans, specific plans in transportation zones and neighborhoods and in property entitlement discussion involving historic resources. These efforts have resulted in the rehabilitation of significant landmarks and districts in Hollywood. Today we find ourselves with the opportunity to codify preservation policy for the area in the Community Plan and to provide systematic implementation goals for resource protection in a planning document which should serve as the umbrella and the guide for all other plans, design guidelines, and entitlements.
Unfortunately, the Plan in its current form does not fulfill its stated policy goals to protect historic resources. In fact, many of the Plan’s implementation measures are detrimental to existing resources. Mitigation measures, while positive, lack specificity, defer implementation, and do not offer an appropriate monitoring program.
We find the current version of the Draft EIR to be deficient in the following areas:
1. The Plan does not contain sufficient information regarding the location, type and status of resources in Hollywood.
Earlier this year, Hollywood Heritage was encouraged to review the findings of the long-awaited Hollywood Historic Resources Survey Update for the CRA area and to participate in the Planning Department’s Survey LA program for Hollywood. These surveys were undertaken to assess the current number and relative significance of historic resources, including Hollywood’s historic core, its neighborhoods, the National Register of Historic Places Hollywood Boulevard Commercial and Entertainment Historic District (HBCEHD) and various entertainment-related sites. These surveys will ensure that the community, planners, developers, property owners and preservationists have reliable, updated, contextual information regarding Hollywood’s historic resources.
The current surveys build upon older surveys. Since 1986 there have been three geographically-based historic resources surveys of the Hollywood Redevelopment Project Area (1986, 2003 and 2009) and two site-specific surveys of damage connected to the civil unrest of 1992 and the Northridge Earthquake of 1994. In addition, there have been numerous site-specific assessments conducted for project review by CEQA and Section 106 activities. Both geographic and thematic contexts in which to evaluate resources have been prepared. Many of Hollywood’s significant structures have been recognized and their significance confirmed by multiple studies. Significant properties identified in studies, whether designated or not, are considered historic resources under CEQA and thus subject to environmental review.
Given the substantial amount of research done to identify historic properties in Hollywood over the years, we are disappointed by the Plan’s current state of resource identification and lack of specific protections for these resources.
The Plan has understandably focused on new development. However, even if that were its sole purpose, to make sense of the outcome, the Plan needs to include better information regarding existing conditions, most importantly the presence of historic buildings. To rectify this issue, the Plan should contain the following:
Existing Land Use Maps: A map of current land use and development intensities in the Plan areas is missing.
Comprehensive List of all designated and eligible resources in the Plan area. This “inventory” should include designated resources from the National Register, the California Register, City of Los Angeles Historic Cultural Monuments (HCM), and Historic Preservation Overlay Zone (HPOZ), those identified on the Historic Resources Inventory and those identified in categories 1 through 5 in current surveys (CRA 2009 update, SurveyLA Year 1). Furthermore, the historic resources listed in the Cultural Resources Section of the DEIR do not match the historic resources listed in the Plan. Nor are these resources, and those identified as eligible in recent surveys, adequately mapped or described.
Historic Resources Map: A comprehensive map of designated and eligible historic resources in all categories is missing. HCMs, HPOZs, historic districts, and identified historic resources is fundamental information for a Plan purporting to sensitively develop around them. There are several individual maps which address a portion of this map, however there is no complete map.
Proposed Land Use Maps: The current zoning and proposed Community Plan land use and development intensities should be mapped and included in the Plans.
Proposed Land Use Conflicts Map: An overlay map indicating conflicts of existing land uses with proposed land uses is missing. Without such a map, two basic issues of the Plan are left vague and may be misunderstood—on which sites should development take place, and on which sites would the existing or proposed development intensity threaten historic buildings?Decision makers and the public require simple, complete illustrations of existing conditions. The current maps and charts in the Plan do not present a holistic framework; there is no sense of which maps could combine to highlight the magnitude of impacts on resources.
Finally, several potential neighborhood historic districts have been identified in recent surveys. In order to protect these areas, basic land use mapping with historic resources identified must be added to this Plan. To mention the protection of and compatibility with historic resources and existing historic settings without clearly identifying all of them is a glaring inconsistency, especially when that information is readily available. In the absence of these basic maps, it is impossible to gauge whether the Plan as a whole is meeting its objectives, and legally complying with other Plan, including the CRA’s Hollywood Redevelopment Plan. There is no way to evaluate whether the proposals in this Plan are effective, desirable, or ineffectual, as they are inadequate as illustrated.
2. Most significantly, the plan does not provide explicit recognition of significance for the internationally recognized Hollywood Boulevard Commercial and Entertainment Historic District, nor does it provide adequately for the preservation of this resource.
The heart of Hollywood is listed in the National Register of Historic Places and functions as one of the City of Los Angeles major tourist destinations and economic engines. Each and every reviewer who has worked on this response with Hollywood Heritage returned with the same alarming conclusion: the Plan as conceived allows for the radical redevelopment of the National Register Hollywood Boulevard Commercial and Entertainment Historic District (HBCEHD) and has the potential to permanently damage the District. After resolving a lawsuit with the CRA which revolved around the appropriate procedures for preserving historic resources, Hollywood Heritage did not expect that this Plan, which functions as an umbrella to the Redevelopment Plan and other specific plans or urban design plans, would result in potential adverse affects to our most significant resources.
The HBCEHD contains 103 of the most important buildings in Hollywood, listed at the national level of significance in the National Register of Historic Places. While some stand alone as individual, internationally-recognized monuments including the Grauman’s Chinese, the El Capitan, and the Egyptian Theater, these landmarks are among 100 other structures on Hollywood Boulevard between Orange and Argyle that make up the most significant historic district in Hollywood and arguably in Los Angeles, surpassing even downtown Broadway in national and international significance.
The District was formally designated by the National Park Service on behalf of the Secretary of the Interior in 1985. At the time, there were over 60 contributors and approximately 40 non-contributors which all dated from the period of significance 1905-1935. Since its listing, the District has seen significant and positive restorations, now having the largest collection of restored historic theaters in use in the nation. The District can count the beneficial reuse of the Broadway and Equitable Buildings, the Hollywood Professional Building, and the Nash Building, and many restorations, spurring the renaissance of Hollywood.
But the District has suffered the loss of several contributors, and seen the addition of large developments such as Hollywood and Highland, the W Hotel and Madame Tussaud’s. Other buildings are currently non contributors due to bad remodeling. Hollywood Heritage continues to monitor the District and to identify potential contributors, which have significance, historic association and integrity and have attained the commonly accepted 50-year threshold of age.
In addition structures, constructed between 1935 and 1960, which were previously ineligible due to age, may now meet the criteria to be included in the district as contributors. The organization believes that a small collection of significant contributors in adjacent lots and side streets, including such landmarks as the Montalban Theater have clear association with the historic district.
For purposes of this Plan, all buildings and features built before 1964 within the boundaries of the HBCEHD should be treated as resources of the district regardless of their current individual evaluation, until the district has been formally amended to reflect the extended period of significance and the current level of integrity of the properties. Hollywood Heritage recommends that the properties within the district boundaries be treated as an HPOZ or Community Design Overlay district which preserves historic buildings and adjacent construction according to the Secretary of the Interiors Standards and Guidelines for Rehabilitation, as contained in the Secretary of the Interiors Standards for the Treatment of Historic Properties.
3. The plan acknowledges that historic resources an important component of planning policy. However, the Plan does not adequately protect those resources through overall land use policy or stated mitigations
The Plan states:
The Proposed Hollywood Community Plan also contains policies and programs to protect the character of low-scale residential neighborhoods and the rich built history of key buildings and places that are considered historically and culturally significant.
Long range implementation programs include proposed historic preservation studies and districts, a Neighborhood Character Front Yard Paving ordinance, an Alley Improvement Plan, an Alley Maintenance Plan, commercial design overlay districts, nexus studies, streetscape plans, and a hillside neighborhood study.
“To make the height districts in Hollywood’s commercial areas consistent with those in other community plans, the Proposed Plan proposes to remove the development limitations that were imposed by the 1988 Update.”
“They promote architectural compatibility and landscaping for new multiple family residential developments to protect the character and scale of existing residential neighborhoods, support historic preservation goals in neighborhoods of architectural merit and/or historic significance, and promote the preservation and rehabilitation of individual residential buildings of historic significance.”
The Plan contains:
A map of numbered subareas where the Proposed Plan recommends various changes in land use designations, zones, height districts, qualifying conditions (Qs) and development limitations (D), Draft Planning Land Use and Zone Change Map.
A matrix to be referenced when reading the Draft Matrix of Existing, Planned and Proposed Planned Land Use which contains detailed information regarding the Qualifying conditions and Development Limitations which are either removed, changed or added by the Proposed Plan, Draft “Q” Qualified Conditions and “D” Development Limitations. P3-6
The Proposed Plan includes the following:
A policy that reiterates the Cultural Heritage Ordinance policies regarding treatment and review of designated Historic-Cultural Monuments.
A policy (LU.1.6) aimed at recognizing building permit review of buildings listed on or eligible for the National Register (see also Mitigation Measure 2 below).
Programs (LU.1.5.1, LU.1.5.2, LU.1.5.3) that encourage additional study and HPOZ designation of areas (see also Mitigation Measure 3 below).
A policy and a program (LU.1.15, LU.1.5.4) encouraging generalized support for
SurveyLA and additional study of a particular area to be surveyed (see also Mitigation Measure 4 below).
A policy (LU.1.7) stressing conformance with the Secretary of the Interior’s Standards for high-density projects impacting historic resources and addressing potential impacts to projects located adjacent to historic districts (see also Mitigation Measure 5 below regarding project specific review).
A policy (LU.1.11) to protect historic resources in FAR Incentive areas (see also Mitigation Measure 6 below).
The Plan’s Goals and Objectives are well presented, however the Plan does not provide enough tools or proposals for the clear implementation of the Goals and Objectives. The Community Plan must be the primary tool for protection; compatible and sensitive new development should be appropriately regulated by this Plan to avoid significant impacts.
The following tools can be used to ensure protection of existing resources:
Use transfer of development rights to benefit historic buildings. In order for this tool to work, surrounding land use and density must be contained so that a developer wishing to increase entitlements can augment the existing land use and density through preservation incentives. If the plan already allows a substantial increase in height and density there is no incentive to retain historic buildings that are developed below the heights and density of the current plan. In order to support the financial viability of maintaining historic buildings, a TDR program could provide private compensation for property owners who have landmark buildings. Sale of development potential taken from these historic sites should not be used on other sites which demolish historic buildings.
Coordinate the demolition process of any building 50 years old, or older with approved plans for development. In addition, no empty lot shall be permitted to remain unimproved.
Use the Secretary of the Interior’s standards and guidelines for all rehabilitation projects involving historic resources, including the SOIS guidelines for additions and in-fill. The Community Plan and all other Specific or Urban Design Plans should not attempt to excerpt the Secretary of the Interior Standards, but should rather simply present them verbatim for use. Reinterpreting the Standards is a dangerous and unnecessary undertaking. Specific sources must be cited for analyzing the impact of new construction on historic districts. Users should be referred to an OHR staff member, preservation professional, the National Park Service, and other specific sources. The Standards must be the starting point for any review in an historic district, including analysis of the effect of an undertaking on the district as a whole.
Encourage the use of the 20% Federal Investment Tax Credit for use in the rehabilitation of National Register listed and eligible buildings.
Improve and streamline the building permit process to provide early technical assistance by the staffs of Planning, Building and Safety and/or Redevelopment to ensure compatible rehabilitation. Rehabilitation of commercial store fronts is a significant example in which Secretary of the Interior compliant rehabilitation would be of great benefit.
4. By permitting inappropriate heights and density, the Plan facilitates the destruction of historic buildings.
The Plan may have made a sincere attempt to control the design of buildings of greater height, but the permission of “by right” development to Plan standards, is incompatible with the goal of protecting historic structures.
In the past, the City Planning department imposed a “D” condition on properties fronting Hollywood Boulevard. This prevented the use of development rights without acknowledging the presence of historic buildings. Those “D” condition requirements remain today. However the Planning Department is proposing removing them in this document. Therefore if the plan in its current form is adopted, land use policies will endanger existing historic buildings.
Under the proposed plan a blanket height of 45 ft would be allowable in the center of the Boulevard, an area dominated by one and two story buildings. Of this area, all but two blocks are nationally significant. This 45’ height limit may have been proposed to protect the historic buildings, but it is abstract and doesn’t prevent demolitions. It doesn’t squarely address and solve the basic conflict that gave rise to this plan.
At the western end of the Boulevard height limits of 150 ft are permitted even though this portion of the District includes the most architecturally significant block, the southern side of Hollywood Boulevard between Highland and La Brea. In this stretch of the Boulevard, this is a particularly alarming and arbitrary scenario.
At the eastern end of the Boulevard certain parcels within the HBCEHD also fall in the unlimited height district area. Maps should be amended to clarify the status of vacant parcels outside the District boundaries.
Potential multifamily residential historic districts are threatened by a blanket height limit for new construction of 60ft. Height should be limited to existing for landmark buildings, and should be determined by individual neighbor sites to allow for sensitive additions rather than a monolithic 60ft height. The traditional patterns of development should be respected and enforced- respecting parcel lines, and forbidding the joining of no more than two parcels for a single project. Traditional lot coverage requirements and setbacks should be maintained.
Height proposals appear arbitrary and are not adequately explained in context.
The west and east sides of Highland Avenue have two different suggested heights, both overlain on important historic buildings. Sections of the HBCEHD are in areas allowing 150’.5. The mitigation measures as currently written are inadequate.
The Plan contains a number of mitigation measures which are designed to lessen the impact of the Plan on historic resources. However, the language of each of the eight measures does not permit the reader to evaluate the measures feasibility and the likelihood of appropriate implementation. The mitigation measures as stated in the Plan lack specificity and are potentially deferred mitigation. In the Plan, mitigation measures are to be conducted and monitored by the woefully understaffed Office of Historic Resources. While the staff is experienced and knowledgeable, it is not reasonable to expect that they can fulfill this task. The language of some mitigation measures is vague; in particular numbers 4 and 5. Hollywood Heritage supports the intent of these measures, but as written they are not implemented, merely discussed. How is one to monitor these good intentions? Can these measures comprise a “preservation plan” for Hollywood which is followed by all relevant agencies? Why restrict input from the Office of Historic Resources (mitigation #5) to projects where the Department of City Planning is the lead agency if this Plan is to govern all development in Hollywood? We would also like the Plan to explain how mitigation measure #6 will be utilized if the height and densities identified in the Plan are adopted. Why not combine portions of mitigation measures 1,2,5,7 and 8 into an overall specific preservation plan for the Hollywood Boulevard Commercial and Entertainment Historic District?
Hollywood Heritage suggests the following additional mitigation measures to protect historic resources and further mitigate the Plan’s acknowledged significant impacts:
Tie demolition permits on buildings 45 years or older to approved building plans (see the Station Neighborhood Area Plan or the CRA/Hollywood Heritage interim settlement agreement for models). This ensures early project review by appropriate parties and will lessen the impact for designated and eligible resources.
Create a rehabilitation plan for the Hollywood Boulevard Commercial and Entertainment Historic District using the Secretary of the Interior’s Standards.
Implement a technical assistance program for owners of historic properties using appropriate city agencies, qualified non-profits (Hollywood Heritage, Los Angeles Conservancy or the Hollywood Community Housing Corporation) and HPOZ board members. Use Neighborhood Councils, homeowner associations and electronic media to facilitate communication.6. Provide a preservation alternative to the Hollywood Community Plan which lessens the impact of the proposed plan on historic resources
CEQA requires that alternatives to the proposed project be prepared which would lessen the impact on historic resources. While the Plan correctly states that each and every demolition of a resource would in fact be a significant effect on the built environment, it has not addressed an alternative which would lessen any adverse affects on individual resources or the entire population of resources. Such an alternative should include, at a minimum, more precise language regarding the redevelopment of property with existing historic structures and a consideration of more precise height and bonus density tools to better integrate existing historic structures into the planning process.
7. The Plan lacks a technical report analyzing the impacts. It is not enough to state the potential impacts without careful examination.
The DEIR lacks a technical report which identifies the existing condition of historic resources and then analyzes the impacts of the Plan on those resources. The Cultural Resources Section of the DEIR globally identifies impacts, but does not present adequate information about the number and types of resources in sufficient detail. Further, the DEIR states potential impact but does not analyze the cumulative effect of the proposed land use height and density changes.
CONCLUSION
This Plan may have aimed to encourage the preservation, restoration, and re-use of historic structures. However, until historic buildings are specifically identified, and specific and directed planning tools developed to protect them, the Plan fails to meet this goal. In fact, the Plan seriously endangers Hollywood’s historic resources, including most significantly, the nationally renowned Hollywood Boulevard Commercial and Entertainment Historic District.
The final version of the Plan must be changed to protect historic buildings, not simply regulate the new buildings that replace them. The Plan does not eliminate the incentives to demolish historic buildings. Specifically, it does not give a clear picture of what is historic in Hollywood, nor does it highlight the potential benefits of rehabilitation. The Plan does not sufficiently represent the historic development of Hollywood, especially the Studios and Hollywood Boulevard – one of the city’s most important assets.
The current version of the Plan does not encourage the protection and preservation of resources within the nationally significant Hollywood Boulevard Commercial and Entertainment Historic District, sensitive adjacent neighborhoods, nor significant individual resources throughout the Plan area. Instead, it permits high densities and tall buildings on the sites of existing low-density historic buildings, and does not deal with the conflict of permitted zoning and existing buildings.
It is alarming and mysterious to us that documents currently being prepared by the Planning Department and other entities such as the Community Redevelopment Agency, though seeming to share similar goals, are not integrated in their approaches. The Hollywood Community Plan should provide a consistent, integrated and responsible approach to future planning, entitlements, and land use based upon the preservation of existing historic structures.
The City Council, the Planning Department and the Redevelopment Agency, as the permitting agencies of the City responsible for Hollywood, are the stewards of its historic resources. Decisions for development shall not impair the integrity (setting, location, design, materials, workmanship, association, and feeling) of Hollywood’s historic resources through attrition, demolition, or inappropriate alteration. The Plan should facilitate good preservation practice and stewardship of resources. This approach will ensure the healthy economic development of this popular tourist destination and provide a livable community for its residents.
The lack of a preservation alternative and incomplete, inadequate, potentially deferred and unenforceable mitigation measures are serious defects in the structure of the DEIR. Further, it is inappropriate to use the existing 1988 Community Plan as a base project. Planning for historic resources has evolved substantially in two decades. The goal should be to have a better plan with fewer impacts than the 1988 effort.
Hollywood Heritages remains appreciative of the Planning Departments efforts in this extremely important Plan. We value and respect the Plan’s inclusions. We will work diligently with you to ensure that the urgently missing pieces-- to preserve and protect the Hollywood Boulevard Commercial and Entertainment Historic District, its historic residential neighborhoods, and entertainment industry related sites --are included through regulation, incentives and technical assistance.
Sincerely,
Richard Adkins
President