The West Hollywood Preservation Alliance (WHPA) urges that the staff recommendation presented in this item not be approved based on serious concerns related to issues of government transparency, widely-accepted historic preservation standards, and overall respect for West Hollywood’s cultural resources. Here is why WHPA is not supporting this flawed recommendation or Draft Resolution HPC 17-125.

Resolution No. HPC 13-105 which the HPC adopted on March 26, 2013, stated that it was “…recommending that the City Council designate the buildings located at 927 and 931 North Palm Avenue, West Hollywood, California as local resources as part of the Old Sherman Thematic Grouping. ” The resolution’s Section 6 further elaborated …”that the buildings and sites at 927 and 931 Palm Avenue be designated as local Cultural Resources as part of the Old Sherman Thematic Grouping.” [Emphasis added]

Then on July 15, 2013, the City Council adopted Resolution No. 13-4478 which only included “…designating the exteriors of the buildings located at 927 and 931 Palm Avenue, West Hollywood, California as local cultural resources as part of the Old Sherman Thematic Grouping.” The resolution which council adopted varied greatly from the resolution which the Historic Preservation Commission (HPC) had passed. Rather than considering the important Sherman-era “buildings and sites at 927 and 931 Palm Avenue,” which the HPC did, the City Council reduced the designation to just “designating the exteriors of the buildings,” leaving the possibility that the Council’s resolution does not cover the garages and additions at the rear of the historic sites.[Emphasis added]

What exactly transpired between your March 2013 meeting and that of the City Council in July 2013? The WHPA realizes that the HPC is an advisory body that makes recommendation. However, if the recommendations that you so diligently work on and then adopt are somehow magically changed with no further input from the commission or the public raises serious questions related to government transparency and ethical standards.

Adding further to this murky scenario is that the adopted Resolution No. 13-4478’s Section 6 states that “On May 20, 2013, the City Council reviewed the staff report and written evidence, the Historic Preservation Commission’s recommendation, and took testimony from interested parties.” [Emphasis added] The WHPA finds absolutely no record of any such meeting on May 20, 2013, which calls into question the accuracy of the resolution adopted by the City Council on July 15, 2013.

What we do surmise is that the resolution which city staff presented to council appeared to respond to the owner/developers concerns rather than to the more comprehensive view taken by the commission. When and how these comments were received and given the weight which they seem to have been given is not at all transparent. Furthermore, the City Council’s retreat from the HPC’s more comprehensive consideration of the buildings and their environs seems to suggest a move away from carefully evaluated preservation to a more narrow view which is focused more on development.

West Hollywood Municipal Code related to “Cultural Heritage Preservation” calls for compliance with the provisions of the National Historic Preservation Act of 1966 as amended. Furthermore, the city’s Municipal Code Section 19.58.040 (D) gives the city’s HPC review authority for:

“Preparing prescriptive standards and design guidelines in reviewing applications for permits to construct, alter, remodel, relocate, enlarge, remove or demolish any cultural resource , or structure within a historic district, or conservation zone. These guidelines shall be based upon the Secretary of Interior’s Standards for Rehabilitation.”

The U.S. Department of the Interior’s Technical Preservation Services has a section on “New Construction within the Boundaries of Historic Properties” HERE.

Please note this particular rehabilitation standard:

“It is possible to add new construction within the boundaries of historic properties if site conditions allow and if the design, density, and placement of the new construction respect the overall character of the site. According to the Secretary of the Interior’s Standards for Rehabilitation – Standard 9 in particular – and the Guidelines for Rehabilitating Historic Buildings, new construction needs to be built in a manner that protects the integrity of the historic building(s) and the property’s setting. As with new additions, the massing, size, scale, and architectural features of new construction on the site of a historic building must be compatible with those of the historic building. When visible and in close proximity to historic buildings, the new construction must be subordinate to these buildings.” [Emphasis added]

In describing the new development, the current staff report suggests that the proposed four-story building is a “backdrop” for the historic properties. However, the WHPA believes that this new development is not subordinate to the cultural resources and contradicts federal standards. It will loom over the historic sites like a massive wall. The buildings behind the development on the cul-de-sac Betty Way are given a “backdrop” of a row of trees. Why, we ask, do designated properties receive less consideration? Even though the proposed structure has ‘green’ walls, this does not diminish the massiveness of the four-story building.

Even if the rationale for the large structure is that other large buildings exist in the area, this does not mean that 927 and 931 N. Palm Avenue benefit in any way from having a four-story building in their backyards. Overall, the proposed development demonstrates little sensitivity to the value of West Hollywood’s designated cultural resources. Even if the new four-story building fulfills a need, it exacts a heavy price.

With only 4 of 7 HPC commissioners expected to deliberate on this vital matter at the July 24 hearing, and with many still unanswered questions and unresolved procedural discrepancies, the West Hollywood Preservation Alliance believes that consideration of Draft Resolution HPC 17-125 should tabled or continued to some future time. As it stands now, Draft Resolution HPC 17-125 should not be adopted. Doing so could result in potentially protracted legal action.