THE IMPORTANCE OF PLANNING
The concept of planning for the preservation of historic resources is not new. As redevelopment of urban cores and transportation infrastructure projects became more common across the United States in postwar America, scholars and planners recognized the need for a conversation that would involve envisioning the kind of environments most useful to communities. In recent decades, divided constituencies have advocated for "clean slates," "smart growth," "freezing the picture in time,” and other catchphrases which do not reflect the complexity of creating a livable and sustainable land use planning strategy.
Hollywood Heritage was formed in 1980 at a time when a plan was being considered for revitalization. Several years later, a redevelopment area was proposed, and a plan adapted in 1984. A part of the redevelopment plan was devoted to the protection of historic resources.
At the time of the Redevelopment Plan's adoption, Hollywood Heritage nominated and successfully listed a thirteen-block stretch of Hollywood Boulevard in the National Register of Historic Places. Listed at the national level of significance, the Hollywood Boulevard Commercial and Entertainment District tells the story of Hollywood's built environment through its contributing structures and reflects the scale and development of Hollywood's most significant eras.
During the life of the Redevelopment Plan Area and its accompanying planning documents, efforts were made by Hollywood Heritage, neighborhood organizations, and others to protect all types of historic resources and to tell their stories through "context planning," an identification and evaluation tool that linked property types to their development history. Toward the end of the redevelopment era in Hollywood, several plans had been drafted and redrafted (urban design plans, specific plans, guidelines, etc.), but had not been adopted. The dissolution of the Agency has left these planning efforts undetermined.
Concurrently, the Planning Department was revising the Community Plan of 1988. Again the conversation began at the "macro" level: how to acknowledge and protect resources. Hollywood Heritage, familiar with the various threats that uncoordinated entitlement efforts could have, continued to advocate for precise measures to deal with each and every type of threatened resource, beginning with their identification and continuing through the entitlement process and the inclusion of incentives to assist property owners in crafting projects which included the physical preservation of resources.
2012 Community Plan
The current Community Plan was adopted in 2012, but is the subject of legal challenge. The Plan presents an updated picture of the community and its identified needs. There is reference to the protection of resources, but definitive programs proposed as mitigation remain to be implemented. Policies are outlined: however goals, timelines, and mitigations lack specificity. Hollywood Heritage acknowledges that the Community Plan is a general framework. However the organization advocates clarity and direction for anyone involved in land use decisions: City leaders and staff; developers and property owners; and community organizations and residents.
The 2012 Hollywood Community Plan clearly addresses the City of Los Angeles Department of Planning’s position on preservation and acknowledges Hollywood’s rich history:
“The Hollywood Community Plan area has a rich built history, with key buildings and places that have become significant for their notable architecture or association with the social and cultural history of the community. The preservation of historic resources protects this built legacy, ensuring continuity and the retention of the community’s collective memory. Historic preservation also offers economic benefits, as communities throughout the nation have used preservation as a successful tool to promote revitalization and economic development.
The Hollywood Community Plan Area boasts one of the highest concentrations of significant historic buildings in the City of Los Angeles. The Hollywood Boulevard Commercial and Entertainment District includes 63 contributing properties, and was listed in the National Register of Historic Places in 1984. The Plan area includes more than 140 City Historic-Cultural Monuments, representing nearly 15% of the total designated Monuments in the entire city.
Hollywood’s renaissance over the past decade has been spurred by the rehabilitation and adaptive reuse of its remarkable historic resources. From the revitalization of Hollywood’s historic theaters to the conversion of historic commercial buildings to new housing opportunities, historic preservation and rehabilitation has enhanced Hollywood’s authenticity and economic vitality.” (2012 Hollywood Community Plan, Pg.41)
Land Use Policies
The plan contains a number of the land use policies that pertain to individual resources, districts, and HPOZ’s. It begins to identify the significance of these resources, using the terms “eligible,” “altered,” and “non-eligible.” The policies in the document that are directly applicable to the preservation of Hollywood’s historic cultural resources are found primarily in the Land Use chapter. See also “Framework for Preservation in the Hollywood Community Plan.”
FRAMEWORK FOR PRESERVATION IN THE HOLLYWOOD COMMUNITY PLAN
Hollywood Heritage participated in the recent Community Plan update process by working with Planning staff and responding to drafts of the Plan and its accompanying environmental documents. As a stakeholder in the process, Hollywood Heritage was committed to incorporating the concept of planning for preservation into the Plan’s goals and objectives. This framework statement was developed during that period. It remains relevant today. Hollywood Heritage believes the Hollywood Community Plan should:
Provide a clear identification of historic resources and neighborhoods.
Historic resources, designated and identified, should be listed and mapped in the Plan. This includes individual buildings and neighborhoods.
Protect those historic resources and neighborhoods through regulation, incentives and technical assistance
Specific planning tools should be developed to protect historic resources. In many areas the plan fails (and in fact endangers) Hollywood’s historic resources, including the significant, nationally recognized Hollywood Boulevard Commercial and Entertainment District, listed on the National Register of Historic Places.
New zoning and height limits jeopardize the retention of existing historic resources. There is no need for developers to use incentives, such as TFAR, Mills Act, federal investment tax credits, easements and other mechanisms in their proposed projects if “by right” the building envelopes in the plan remain so generous. New development should be encouraged to recognize existing historic fabric, setting, and spatial relationships.
Maintain a consistent, integrated and responsible approach to existing and future plan studies and surveys.
Some of the plan goals suggest a concerted effort to encourage preservation, rehabilitation, and re-use of historic structures. It is imperative that plans and studies prepared by any agency for Hollywood are not in conflict and reflect community values towards preservation.
Use the Secretary of the Interior Standards and Guidelines for all rehabilitation projects involving historic resources, including the SOIS guidelines for additions and in-fill.
There is little need for new design guidelines to be prepared for the historic districts of Hollywood, particularly on Hollywood Boulevard all rehabilitation and new construction should conform to these standards. Conformance with these standards is the only way to avoid significant and negative impacts under CEQA.
Tie the demolition of any building 50 years old, or older, to approved plans.
Hollywood Heritage supports language included in the Vermont/Western Transit Oriented District Specific Plan (Station Neighborhood Area Plan) as a model for such language.
Current planning efforts lack:
A preservation alternative to the Hollywood Community Plan that would lessen the impact of the proposed plan on historic resources.
Mitigation measures to provide specificity. Currently many of these future studies constitute 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, without a substantial increase in funding.
The complete list of identified historic resources listed in the Cultural Resources Section of the DEIR do not match the historic resources listed in the Plan. These resources, and those identified as eligible in recent surveys, are not adequately mapped or described.
A technical report analyzing the real impacts of policies. The impact assessment in the Cultural Resources Section is weak. Several policies are stated in the Section that are laudable but do not contain implementation language. When there are significant adverse impacts as a result of individual projects, the plan should contain more incentives to avoid such impacts.
Hollywood Heritage’s letter regarding the Planning Department Assuming CRA responsibilities–
Hollywood Heritage took legal action regarding the lack of a design review component of the CRA plan for Hollywood as promised in the original Redevelopment Plan. As a result of that legal action, Hollywood Heritage had been working with the CRA representatives in an advisory capacity in regards to the application and granting of demolition permits and to resolve the status of plans and surveys.
As the CRA divests itself of its planning functions, its responsibilities are to be transferred to the Los Angeles Department of City Planning. During the public comment on the transfer, Hollywood Heritage submitted the following letter regarding our concerns:
HOLLYWOOD HERITAGE, INC.
P.O. Box 2586 Hollywood, CA 90078
(323) 874-4005 • FAX (323) 465-5993
Honorable City Council Member O’Farrell Department of City Planning Dir. Michael Lo Grande Attn: David OlivoCity HallLos Angeles, CA April 2, 2014
Re: Ordinance and Resolution to Transfer Land Use Authority from CRA/LA to the Department of City Planning (AB1484); CPC 2013-3169-CA; ENV-2013-3170-CE Council File: 11-0086
Dear Councilmember and Director:
Hollywood Heritage has a keen interest in the transfer of all land use-related plans and functions of the LA CRA to the LA Department of City Planning, and in seeing that the City Council provides adequate funding to do so at this critical time.
We are writing to emphasize that the elimination of the Community Redevelopment Agency land use functions can undo 25 years of progress for Los Angeles’ most famous, visible, important, and rapidly growing historic area.
During its tenure, CRA took on all of the localized and “fine grain” planning activities below the Community Plan level in Hollywood. Without pro-active, well-funded Planning Department actions now, unintended problems are inevitable.
With the re-opening of the Hollywood Community Plan, we understand that this transfer of CRA authority to City Planning “will incorporate the redevelopment plans’ land use controls into legislatively adopted Community Plan Implementation Overlays, or other land use regulations” and will take responsibility for EIRs where the current Plan identified eligible historic resources.
Hollywood Heritage offers our assistance in these endeavors. Although we unfortunately had to take an adversarial role in the courts with CRA, on a day-to-day basis we cooperated continuously with CRA. We developed and shared files, mapping, and data that can assist CityPlanning in its follow-through.
City Planning Prior to or Separate from CRA: Before the CRA Hollywood Project Area was adopted, Hollywood Heritage (HHI) and its founders were active in planning for a Hollywood Boulevard Specific Plan, defining the importance of Hollywood Boulevard and guiding its development. HHI authored the Hollywood Boulevard District research, and the nomination and successful listing of the District on the National Register of Historic Places. Hollywood Heritage has actively cooperated in HCM nominations; in post-earthquake surveying; in the survey update; and in actions involving districts and landmarks outside of Hollywood Boulevard proper, and outside of the Redevelopment Area.
Hollywood Heritage Cooperation with CRA Planning :
As the voice and conscience of historic preservation, we took an active and constant role in CRA activities. For example, we:
• Authored the Section 511 and other sections in the Redevelopment Plan for building the redeveloped future upon Hollywood’s illustrious past, and built the political consensus for inclusion of preservation procedures in the Plan• Served as elected representative to the CRA’s Citizens Advisory Committee;
• Participated in over 25 years of planning activities with CRA as they affected historic buildings.
• Participated actively in Historic Survey development
Preparing for the Transfer:
Hollywood Heritage encourages the City Council of LosAngeles to adequately fund the transition to City Planning, specifically for Hollywood :
1. Immediate mapping and data entry of “protect ed” historic buildings, and notification of planned demolitions:
There is a currently-adopted list of buildings, with Status Codes 1-4 protected by the Hollywood Redevelopment Plan, including recognition of these buildings in EIRs. These addresses must be transferred, mapped, and protected by City Planning. In addition there is an interim procedure set by judicial action wherein Hollywood Heritage is consulted on planned demolitions for Status Codes 1-6 within the Redevelopment Area. CRA and Planning have indicated their willingness to continue with these programs, and funding is needed to develop the procedures and databases prior to the actual transfer to City Planning, and to continue day-to-day after the transfer.
2. Transfer of CRA data and planning assets: CRA assembled databases,maps, draft plans, files, a draft update of the historic survey, etc. Funding should be provided specifically to City Planning to assure that all of this information in CRA’s hands is indexed properly and transferred to City Planning . There should be both hard copies and electronic files that are compatible with City Planning databases and software, or funding should be provided to be made compatible.
3. Retain “Notes” and Development Limitations:
The 1986 Hollywood Community Plan in the Redevelopment Area had extensive “Notes” which were specifically intended to deal with the conflicts of the AB 283 zoning conformance program before the “fine grain” urban design plans were completed by CRA. As CRA never completed those plans, the Department of City Planning must now ensure that those “D” limitations and “T” and “Q” conditions remain on properties while the Community Plan revision is worked out.
4. Interim Control Ordinance immediately: The Hollywood Boulevard National Register Commercial and Entertainment Historic District will need an ICO to give the Planning Department time to follow up on the court- mandated Urban Design Plan, and to work to conform the zoning categories with current protections.
Longer Term Strategies: Hollywood Heritage encourages adequate funding for longer- term planning:
5. Integrate Specific Plan or Overlay into re-opened Hollywood Community Plan:
Hollywood deserves its long-awaited Specific Plan, Hollywood Urban Design Plan, CPI Overlay, or whatever tool will serve the intended purpose for Hollywood.
6. Historic Survey Data/Mapping:
CRA for the last 25 years has been the“go to” agency for information. CRA became the repository of publicly available historic survey data; had almost completed survey revisions to provide an up-to-date, publicly available listing and mapping of historic resources; and had posted the data on their website. This effort needs to be “wrapped up”. It is a critical public information function needing funding. Prioritizing as a part of Survey LA’s implementation may be one answer.
7. Historic Cultural Monuments Program:
The Hollywood CommunityPlan in 1986 required that roughly 100 National Register and other listed historic buildings be forwarded to the Cultural Heritage Commission for listing as HCM’s at the City, and for notification in the event of proposed demolitions. The courts renewed that obligation in 2009. The City needs to make a proactive effort to integrate buildings, including the “contributors” and “non-contributors” to the National Register District, into City Planning’s system now if CRA cannot follow up on this obligation.
8. Historic Preservation Overlay Zone Program:
CRA surveys over the years identified specific historic residential districts. These CRA districts should become the basis for an HPOZ program in the future.
In the interim, for community planning purposes and for discretionary actions, these districts should be treated as if they are designated; mapped for contributing and non contributing resources; and boundaries defined. The multi-family area north of the Hollywood Blvd. National Register District was identified in 1986 as needing special urban design protections; this area is especially critical. This area should have an ICO placed on it until an appropriate preservation mechanism is identified.
9. Other CRA Settlement Agreement Obligations: Hollywood Heritage has recently indicated its willingness to reconsider one or more of the obligations for planning stipulated by the courts in the 2009 Settlement Agreement between Hollywood Heritage and CRA/City. The 2009 Agreement stipulates that urban design planning be completed by March 2013, but it was largely done but never completed. CRA opened up the discussion with a thorough analysis of CRA compliance to date. Hollywood Heritage is willing to “cut through” the issue in CRA cooperation; however, this must be conclusively negotiated prior to the transfer.
10. National Register District’s Updates: Due to changes in National Register and National Register-eligible districts, caused by restorations and demolitions in Hollywood and by the passage of 25 years, updates are critical in the coming years.
White Paper: Hollywood Heritage will prepare a White Paper for the CRA, the Council Offices, and City Planning to better understand each of these points.
President, Hollywood Heritage Inc.
Frequently Asked Questions:
Development of Historic Properties
What is Hollywood Heritage?
Hollywood Heritage is a non-profit organization dedicated to preservation of the historic built environment in Hollywood and to education about the early film industry and the role its pioneers played in shaping Hollywood's history.
How can I find out if my property is historic?
Buildings may be evaluated for historic significance if they are (generally) 50 years old or older, have retained physical integrity from their period of significance, and contribute to the understanding of a historic context or theme. Preliminary evaluations occur through historic resource surveys, CEQA historic resource assessments, area wide studies undertaken by government agencies, or other initiatives. The City of Los Angeles, State of California, and the federal government all have criteria for determining if a building or site is significant. Lists of identified buildings are kept by various agencies: Office of Historic Resources; Community Redevelopment Agency of the City of Los Angeles, a Designated Local Authority; Office of Historic Preservation; National Register of Historic Places. A building or property does not have to have an official designation to be considered historic.
What incentives are available to owners of historic properties?
The federal government offers tax incentives for rehabilitation of depreciable income producing structures who meet the requirements of the Investment Tax Credit program and conservation easement deductions for properties listed in the National Register. There currently is no state historic tax credit offered by California. However, California offers property owners the use of the State Historic Building Code (“SHBC”) with the permission of the local building official. On a local level, the City of Los Angeles offers property owners contracts for partial property tax abatement (Mills Act).
How does being historic affect the entitlement process?
If a building is considered to be a historic resource, then the impacts of a project on that resource must be considered. Los Angeles and its agencies conduct environmental review according to CEQA guidelines if this is the case. Demolition of a resource is considered a significant impact under CEQA, and may require a change in the project to mitigate impacts or a full environmental review (EIR) to inform the decision-making authority before it allows demolition to occur. In Hollywood, demolition of potentially historic buildings over 50 years of age must receive comment by Hollywood Heritage before a permit is granted.
What is an historic survey?
A survey is a preliminary analysis performed by a trained professional usually for a government agency like a planning department or redevelopment agency to assist in planning for a community's development. The survey identifies properties by architectural style, use, and historic association. Survey results are often expressed in a
numerical rating system called the California Historical Resource Status Codes (adopted by the Office of Historic Preservation in August 2003 and formerly known as the National Register Status Codes). Many properties in Hollywood have been evaluated through survey efforts by the Planning Department (Survey LA), the former Community Redevelopment Agency, or state and federal initiatives.
How can Hollywood Heritage help me as a property owner?
Hollywood Heritage can assist owners and developers in identifying historic buildings, provide technical assistance including consultants, contractors, architects and others. Hollywood Heritage maintains extensive photographic and documentary archives to assist in building history research.
Are there online resources available?
Interested persons can refer to OHP.PARKS.CA.GOV, preservation.lacity.org, laconservancy.org, preservationnation.org, and nps.gov.
Why is historic preservation the most sustainable type of development?
The Greenest Building is the one you don’t demolish. Building reuse almost always offers environmental savings over demolition and new construction. Reusing existing buildings can offer an important means of avoiding unnecessary carbon outlays and help communities achieve their carbon reduction goals in the near term.
Are there design guidelines for historic preservation projects?
The Secretary of the Interior is responsible for establishing standards for all national programs for the preservation of historic properties listed or eligible for listing in the National Register of Historic Places. State and local agencies use the same guidelines incorporated into ordinances. The Secretary of the Interior’s Standards and Guidelines can be found at NPS.gov.The Standards for Rehabilitation, a section of the Secretary's Standards for Historic Preservation Projects, address the most prevalent preservation treatment today: rehabilitation. Rehabilitation is defined as the process of returning a property to a state of utility, through repair or alteration, which makes possible an efficient contemporary use while preserving those portions and features of the property which are significant to its historic, architectural, and cultural values.The Standards pertain to historic buildings of all materials, construction types, sizes, and occupancy and encompass the exterior and the interior of historic buildings. The Standards also encompass related landscape features and the building's site and environment as well as attached, adjacent or related new construction. The Standards are to be applied to specific rehabilitation projects in a reasonable manner, taking into consideration economic and technical feasibility.
What is the meaning of the term "integrity" in historic preservation terminology?
Integrity is the ability of a property to convey its significance. It is grounded in the understanding of the property’s physical features. To retain historic integrity, a property will possess several and usually most of seven aspects identified by the National Park Service. Determining which of these aspects are most important to a particular property requires knowing why, where, and when the property is significant. These seven aspects of integrity are location, design, setting, materials, workmanship, feeling, and association.
HPOZ’s and the Preservation of Neighborhoods
One of the most important tools of preservation is the formation of Historic Districts, as they are referred to in National & State designation programs, or Historic Preservation Overlay Zones (HPOZ’s) as they are referred to at the local level here in Los Angeles.
The underlying premise of such designations is that even though a resource may not be significant enough individually, it can still convey significance and contribute to establishing a sense of place when situated in an area with other resources of a similar context. This is an effective way to preserve a number of a number of resources and implement design guidelines that effectively maintain an area’s historic context and sense of place. Existing HPOZ’s in CD 4 include Whitley Heights, Spaulding Square, and Hollywood Grove, some of the more significant and cohesive neighborhoods within the context of Hollywood.