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sr-012412-6a10_ City of City Council Report Santa Monica' City Council Meeting: January 24, 2012 Agenda Item: To: Mayor and City Council From: David Martin, Director, Planning and Community Development Subject: Appeal of the Des nation of the Turn -of- the - Century Cottage Residence Located at 2501 2" Street as a City Landmark Recommended Action Staff recommends that the City Council deny the appeal and uphold the decision of the Landmarks Commission to designate the subject building as a City Landmark. Executive Summary The appellant, Plaster Family Trust, requests that the City Council overturn the Landmarks Commission's ( "Commission ") February 14, 2011 decision to designate the Turn -of- the - Century residence at 2501 2nd Street as a City Landmark. The designation application was originally filed by the Landmarks Commission as a result of its earlier review of a demolition permit for the buildings on the subject property. In its findings in support of landmark designation, the Commission found that the building met three of the Landmark designation criteria ( #s 1, 4 and 6). The property itself was also included in the designation in order to safeguard the historic resource. The rear cottage and accessory garage were excluded from the designation. This report highlights the points of the appeal, the Landmarks Commission's action, and staff's recommendation based on required criteria for designation. While the initial report and recommendation to the Landmarks Commission did not support designation, in consideration of the full record to date, including additional information described further in this report, staff has concluded that designation should be approved. The recommendation on this matter does not have any budgetary or fiscal impact. Background The two detached cottage residences situated on the subject property were originally constructed between 1902 and 1907, and both retain their original residential uses. Front Cottage - The more prominent of the buildings, located at the front of the lot and addressed as 2501 2nd Street, is a good example of the Turn -of- the - Century Cottage with moderate to high integrity. The residence has many character - defining features of the style including hipped roof, asymmetrical front fagade, bay window and a recessed entrance. The residence is supported by a brick foundation and has clapboard and shingle siding divided by a narrow wood sill. Decoratively cut exposed rafters are visible beneath the open eaves. The property retains its original diagonal multi -light and double -hung windows. Alterations include the enclosure of the front porch and a rear addition located on the south east corner. Front Cottage — 2 "d Street (west) elevation Front Cottage - Mills Street (north) elevation Rear Cottage - The cottage at the rear of the subject site, addressed as 238 Mills Street, is a one -story wood -frame residence with board - and - batten siding. It is unclear if the residence has "single -wall' construction (no studs), which was common for southern California beach cottages constructed during the first three decades of the twentieth century, or whether the residence has traditional stud -wall framing. The rear residence has an asymmetrical front that faces the rear of the primary residence rather than the street. The single -story cottage has a hipped roof and several double hung single -light windows. The primary character - defining feature of the rear residence is its board and batten siding which has deteriorated over the years. The rear cottage has low integrity due primarily to its limited design quality. 2 Rear Cottage A wood frame garage located. between the two residences was constructed in 1927. The garage is a later addition and does not contribute to the significance of the primary residence at 2501 2nd Street. The Turn -of- the - Century Cottage or Victorian Vernacular Cottage style was a transitional architectural style popular in Los Angeles from the late 1800s to the early 1900s. The style is typically one story in height and has elements of the American Foursquare and Queen Anne style displayed on a smaller scale. The Turn- of -the- Century Cottage is highly significant as it was the last major housing type tied to the Victorian era of the nineteenth century. Historic Resources Inventory Status This property has been previously identified and assessed through the City's on -going survey process on four separate occasions. It was initially surveyed during Phase 1 (1982 -1983) of the Santa Monica Historic Resources Inventory Survey and was determined eligible for local listing as a contributor to the potential 2500 Block of 3rd Street District. The property was later reassessed during the City's 1994 Historic Resources Inventory Update following the 1994 Northridge earthquake, and again identified as a district contributor. Finally, the property was assessed in both 2004 and 2008 -11 Historic Resources Inventory Updates and both times the property was 3 determined eligible for listing as a contributor to a potential district, the 2500 Block of 3rd Street District/2400 -2500 block of 4t" Street. Discussion Landmarks Commission Action At its February 14, 2011 meeting, the Commission considered the staff report, accompanying consultant report, background information provided by the property owner on the building's condition, and public testimony regarding the building's value as an architectural resource in the neighborhood to assist in the Landmark discussion. The consultant's report concluded that the front cottage (2501 2 "d Street) has a high level of historic integrity and represents a good example of the Turn -of- the - Century style, which is becoming increasingly rare in the City, and recommended landmark designation. Staff, on the other hand, acknowledged the high integrity of the structure, but concluded neither building should be landmarked. Staff's recommendation took into consideration the Historic Resources Inventory evaluation which recognized the building's contribution to a potential historic district, but concluded that the building did not warrant individual landmark status. Further, staff noted that there are other more exceptional examples of the style represented in the City's current inventory of landmarked buildings and, therefore, Landmark designation did not appear to be warranted. In its review, the Commission reviewed the structures in terms of landmark criteria and did not base its determination on the cost of potential rehabilitation. The Commission further discussed that integrity and condition are independent of each other and poor condition does not necessarily equate to poor integrity. Here, notwithstanding the property's deferred maintenance, the Commission concluded that the front cottage has the highest level of architectural importance and historical value out of the three structures on -site, and that the detached accessory garage and rear cottage are not significant. The Commission discussed the distinguishing architectural features of the front cottage, including its windows with unique diamond -paned sashes, shaped rafter tails under the roof eaves, and the continuous sill around the house separating 0 horizontal wood siding from a wood shingle cladding. There was consensus that the limited maintenance proved to have positive results for preserving the building's historic integrity and keeping most of its character defining features intact. The Commission further noted that the building has a prominence in the neighborhood by virtue of its corner siting, and is also a contributor to a potential historic district representing the most intact hipped -roof cottage in the potential district. Furthermore, cottages of this style were once prevalent in Ocean Park, but are becoming increasingly rare. After considering the property owner's testimony and six speakers all in support of designation, the Commission unanimously determined that the main cottage meets three of the six designation criteria ( #1, #4 and #6): It exemplifies the early history of Ocean Park and manifests its cultural, economic and social development; it is a fine example of a Turn -of -the- Century Cottage with subtle but refined architectural detailing which is increasingly rare in the City; and, it is locally recognizable for its architectural detailing and its setting on a prominent corner in the neighborhood. The full text of the Landmarks Commission's Statement of Official Action is presented as Attachment C. The February 14, 2011 staff report and meeting minutes are presented as Attachments D and E, respectively. Appeal Summary The appellants filed a timely appeal on February 23, 2011. In their appeal statement, they describe the poor physical condition of the building, noting its structural deficiencies, and other impacts due to mold and other hazardous materials and conditions. They refer to a January 14, 2010 action of the Rent Control Board to issue a removal permit based on the uninhabitable condition of the structure and the economic infeasibility for rehabilitation. They further concur with City staff's recommendation to not designate and note that their historic consultant has identified 21 examples of similar cottages with higher integrity and better physical condition. 5 Designation Criteria The City Council, in its review of this appeal, must determine whether an improvement satisfies one or more of the following criteria set forth in SMMC Section 9.36.100 in order to be designated as a Landmark: (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. (2) It has aesthetic or artistic interest or value, or other noteworthy interest or value. (3) It is identified with historic personages or with important events in local, state or national history. (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. (5) It is a significant or a representative example of the work or product of a notable builder, designer or architect. (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. Under the provisions of the Landmarks Ordinance, the City Council may grant the appeal or uphold the decision of the Landmarks Commission, in whole or in part, based upon these criteria. The City Council's review of this application is de novo. Analysis Assessing a building's eligibility for City Landmark designation is based on the criteria established in the Landmarks Ordinance. Potential rehabilitation work or its cost is not germane to the discussion. Further, it is important to recognize the distinction between a building's "condition" and its "integrity" and keep these two concepts independent. "Condition" refers to the overall appearance and state of building repair, whereas "integrity" is the authenticity, of a property to its style as evidenced by the survival of physical characteristics that existed during its period of significance. Integrity is tl assessed based upon seven aspects: location, design, setting, materials, workmanship, feeling and association. The more that these aspects are determined to be intact, the higher a resource's overall integrity. The building may have cosmetic flaws and hidden structural deficiencies, including an unkempt appearance and poor maintenance. In reviewing its historic integrity, while the front porch has been enclosed, a replacement door installed, and its contextual setting altered over time due to new construction in the neighborhood, its overall historic integrity is high. The building remains an intact residential cottage whose design plan and architectural detailing are indicative of the Turn -of- the - Century style and whose overall location and feeling reflects the Ocean Park neighborhood at the beginning of the 20th Century. As detailed earlier in this report, staff's original recommendation to the Landmarks Commission concerning designation was to deny the request. Staff found that although the building has strong historic integrity, it was evaluated as a potential historic district contributor and not an individual landmark. Staff further recommended that, since this style is well- represented in the City's current list of landmarks, it was more appropriate for this building to be included in a future district than to be individually designated. As part of the analysis for this appeal, staff reassessed the Commission discussion and the information presented during the public testimony which stressed the importance of this building in terms of the historic neighborhood scale and character. This building was additionally described by speakers as a significant contributor to a potential historic district and how its loss would have negative consequences. The Commission addressed the increasing rarity of the Turn -of- the - Century style and emphasized the fragile architectural fabric that exists in Ocean Park. The importance of this style in defining the early history of Ocean Park was also expressed and the building serves as a representative example of this type of architectural style, given its current design integrity with limited alterations. The Commission further discussed that a limited number of examples of this style remain in Ocean Park and the local neighborhood specifically. This trend continues as is reflected in the recent remodel of a similar cottage at 2513 3`d Street where all of its exterior features and materials were removed. While the initial recommendation from staff did not support designation, based on the 7 full record to date, including testimony and the documentary evidence presented during the public hearing, staff now recommends that the Landmarks Commission action be upheld and the building be designated a City Landmark. The building has remained unoccupied since the appeal was filed last February and was secured to deter subsequent damage from unauthorized entry. Conclusion The cottage at 2501 2nd Street maintains sufficient historic integrity as an individual City Landmark and is a particularly important component of a potential historic district. Although the Historic Resource Inventory evaluated the building as a contributor to a potential historic district, staff believes the public record established at the Landmarks Commission hearing provides substantial evidence to support designation. Therefore, staff recommends that the City Council deny the appeal and uphold the decision of the Landmarks Commission to designate the front cottage and the parcel at 2501 2nd Street as a City Landmark, based on the criteria below: (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. The residence located on the corner of 2nd Street and Mills is a rare example of a Turn - of- the - Century Cottage, a housing type associated with the Victorian era. This style, which served to architecturally link the nineteenth and twentieth centuries, was the most prevalent when the first wave of development took place in the Ocean Park district and was largely replaced with the Craftsman style by 1910. Exhibiting a high degree of architectural integrity, the subject property is part of a cluster of historic structures in the immediate vicinity, but one of the few of its type that exemplify the early history of Ocean Park and manifest its cultural, economic and social development. (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or 10- craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. The residence located on the corner of 2nd Street and Mills is a fine example of a modest Turn -of- the - Century Cottage with subtle but refined architectural detailing including its windows with unique diamond -paned sashes, shaped rafter tails under the roof eaves, and continuous sill around the house separating horizontal wood siding from a wood shingle cladding. Based on a study of historic Sanborn Maps, it appears that there were once many examples of Turn -of- the - Century and Queen Anne style cottages in the Ocean Park area, but few remain. While it appears that the greatest number examples of the increasingly rare style are located in the Ocean Park neighborhood, the number remaining in the City as a whole is extremely low. Like nearly all examples of the over 100 -year old style, the residence located at the corner of 2nd Street and Mills has minor reversible alterations or additions, such as the front porch enclosure or room addition to the rear. However they do not deter from the significance of the architecture. (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. The subject property is situated on a highly visible corner location in the Ocean Park neighborhood containing other early 20th Century buildings. The property is improved with a Turn -of- the - Century cottage that is locally recognizable for its distinctive diamond -paned window design and for its setting on the lot with generous open space provided along 2nd Street and Mills Street. Alternative As an alternative to the staff recommendation, and if supported by the full evidentiary record, the Council may consider upholding the appeal and reversing the decision of the Landmarks Commission to designate the building /parcel at 25012 nd Street as a City Landmark. Wl Environmental Analysis The project is also exempt pursuant to CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) provides that CEQA only applies to those projects that have the potential for causing a significant effect on the environment. Since the proposed action would result in the retention of the existing structure and would not change the existing environmental baseline, there is no potential that the project would cause a significant effect on the environment. Public Outreach The public notice for this hearing was published at least 10 days prior to the hearing in the Santa Monica Daily Press and mailed to all property owners and occupants within 300 feet of the subject property. Financial Impacts & Budget Actions The recommendation presented in this report does not have any budgetary or fiscal impact. Prepared by: Scott Albright, AICP, Senior Planner Approved: Forwarded to Council: David Martin Rod Gould Director, Planning and Community City Manager Development 10 Attachments A. Appellants' Appeal Statement B. Draft City Council Statement of Official Action C. Landmarks Commission Statement of Official Action, February 14, 2011 D. Landmarks Commission Staff Report, February 14, 2011 E. Excerpt of Landmarks Commission Minutes, February 14,2011 F. City Landmark Assessment and Evaluation Report — July 27, 2010 G. Background documentation (from appellant) 11 ATTACHMENT A Appellants' Appeal Statement Electronic version of attachment is not available for review. Document is available for review at the City Clerk's office and the Libraries. `A City of Santa Monica Planning and Community Development Department City Planning Division City .f (310) 458 -8341 Santa iMoniel APPEAL FORM (Please Type or Print all Information) Application Number It A�?Od1 . APPELLANT NAME: Plaster Family Trust Filed: y �S33 APPELLANT ADDRESS: 801 S. Rancho #E -4, Las Vegas; NV 89106 CONTACT PERSON: Kevin V_Kozal -- 310 451 -4138 --- - - - - -- Phone: --- - - - - -- (all correspondence will be mailed to this address) Address: 1250 6TH Street, t Suite 200, Santa Monica CA 90401_ PROJECT CASE NUMBER(S) : 1 OLM002 PROJECT ADDRESS: 2501 Second Street APPLICANT: Santa Monica Landmarks C 4287 - 010 -011 ORIGINAL HEARING DATE: 02/14/2011 --------------------------- — ------- - ---- ACTION BEING APPEALED: Landmark designation by Landmarks Commission on February 14, 2011 - ------------------------- - - - - -- Please state the specific reason(s) for the appeal (use separate sheet if necessary): Is the appeal related to the discretionary action and findings issued for the proposed project? X —Yes ___ No If yes, explain: See attached cover letter. Is the appeal related to the conditions of approval? X_ Yes ___ No If yes, which conditions and why: See attached cover letter. Is the appeal related to design Issues? ___ Yes ___ No If yes, explain: NIA Is the appeal related to compatibility Issues such as building height, massing, pedestrian orientation, _ etc.? __ Yes ___ No If yes, explain: Is the appeal related to non - compliance with the Santa Monica Municipal Code? ___ Yes ___ No If yes, which Code section(s) does the project not comply with and why: N/A Is the appeal related to environmental impacts associated with the project? __ Yes ___ No If yes, explain: NIA Is the appeal related to other issues? X _ Yes _ _ No if yes, explain: See attached cover letter. APPELLANT SIGNATURE: v K��t^' NOTE: A hearing date on the appe wil not be scheduled until sufficient information regarding the basi for the appeal has been received to enable City Planning Division staff to prep a the required analysis for the staff report. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS 310 451 -2968 SANTA MONICA. CALIFORNIA 90401-1602 hard ing@hlkkiaw.com (310) 393 -1007 g @hlkklaw.com FACSIMILE (310) 392 -3537 February 23, 2011 VIA HAND DELIVERY Santa Monica City Council 1685 Main Street, Room 102 Santa Monica, CA 90401 Re: Appeal of Landmarks Commission Decision (10LM -002) Address: 2501 Second Street, Santa Monica Owner: Plaster Family Applicant: Santa Monica Landmarks Commission Date of Landmark Commission Designation: February 14, 2011 Our File No. 20251.001 Dear Councilmembers: This letter is attached to and made part of the appeal filed by the Plaster Family challenging the Landmarks Commission's decision to designate the cottage at 2501 Second Street as a landmark. The Plaster Family owns this property. In taking this action, the Commission did not follow City Staff's analysis and conclusion that this cottage does not merit a landmarks designation. We believe Staff's analysis is persuasive and should be followed by the City Council. I. BACKGROUND The cottage in question was constructed in or about 1902 -1907. It is a Turn -Of- The-Century/Victorian Vernacular -style cottage. It is one of many such cottages in Santa Monica.' ' At page 5 of its July 27, 2010 report, PCR Services lists a total of 17 other turn - of- the - century cottages. Most of these cottages are located in the Ocean Park neighborhood. Mary Jo Winder of Architectural Preservation Planning Services identifies four more examples, for a total of 21. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Santa Monica City Council February 23, 2011 Page 2 This cottage is in extremely poor physical condition. Nabih Youssef & Associates ( "Youssef'), an internationally recognized structural engineering firm specializing in structural and earthquake engineering, evaluated the structural systems of the cottage. Youssef found that the integrity of the structural systems.at the house are severely compromised and the building is not suitable for occupancy and poses serious safety hazards. The report concludes: "In our professional opinion, a majority of the structural components of the single - family home — including floor joists and framing, along with exterior components, including exterior walls and wall framing — are beyond repair and should be removed and replaced. In addition, the entire foundation of the single - family home must be replaced." Youssef Report, p. 3. The structural deficiencies identified in the Youssef report and the recommended remedies include the following: • The roof framing is sagging and damaged. Portions of the roof framing will need to be removed and replaced. The existing roof framing needs to be repaired and strengthened and diaphragm sheathing and connections to the exterior walls should be added. • The floor framing is sagging and has extensive damage. The floor framing in areas is beyond repair and must be replaced. Floor joists and beams need to be replaced and strengthened. In addition, adequate lateral bracing of the interior pier posts is required. Exterior walls are damaged and exposed to moisture. These components are beyond repair and should be removed and replaced. In addition, the exterior clapboards should be removed. The wall /cripple wall framing, sills, studs and plates must be removed and repaired or replaced in order to install needed sheer wall sheathing and hold downs. The existing foundation is inadequate, beyond repair and presents serious risks. The existing foundation must be removed. Reinforced concrete stem walls and footings at the perimeter and at interior pier footings must be provided. New foundation sill plates and adequate sill bolts are required. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Santa Monica City Council February 23, 2011 Page 3 Large cracks are evident throughout the interior lath and plaster, which . damage is consistent with the effects of floor and roof deflections, settlement of the structure and past earthquake damage. • There is rot and insect damage through the floor beam and joist framing. • The clay brick stem walls are deteriorating with bricks delaminating and mortar is eroded and missing from many joints. Youssef Report, pp.7 -8. Mark Levy, President of the Mold Guy, Inc. inspected the front house and tested for mold. Mr. Levy is a certified mold inspector and indoor environmentalist. This testing determined that there is a significant indoor mold problem in the front house that requires remediation. Mr. Plaster's contractor has indicated that, at a minimum, the mold remediation work will involve significant work in the kitchen and bathroom, including the removal of all kitchen cabinets, the removal of all bathroom fixtures and removal of significant portions of the floor, ceilings and walls. The remediation work will, also require the repair of all plaster in the kitchen, pantry, bathroom, closet and half the front bedroom, all new kitchen cabinets with new counter tops, new kitchen floor, new floor in the bathroom and new bathroom fixtures. Furthermore, the mold report recommends inspection inside the north wall of the bedroom /south wall of the bathroom during the abatement process. This is because it is likely the framing behind the plaster has mold growth as well. If that is the case, this framing will also need to be removed and replaced. Aardvark Property Hazard Analysis Company inspected the front house for asbestos. This inspection detected asbestos in numerous areas, including the congregated insulation sheets throughout the attic, roof patching materials, vinyl flooring and in certain exhaust flue pipes. On January 14, 2010, the Rent Control Board issued a removal permit for this cottage on the basis that it is uninhabitable and economically infeasible to rehabilitate. The cottage is vacant. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Santa Monica City Council February 23, 2011 Page 4 II. THE STAFF REPORT TO THE LANDMARKS COMMISSION IS PERSUASIVE AND SHOULD BE FOLLOWED ON APPEAL City Staff has reviewed this matter carefully and concluded that it does not merit landmarks designation. Specifically: There are better examples of Turn -Of- The- Century/Victorian Vernacular -style cottages throughout Santa Monica, including several that have been designated as landmarks and others located in the Third Street Historic District. (Page 6) To be designated, "a building from this period of the City's history should be an exemplary example; unique and rare in its overall character and detail, as the findings mandate." (Page 6) Given the cottage's "current state of disrepair and apparent need for structural and significant cosmetic rehabilitation, staff does not believe it would be prudent to designate a building as a landmark whose rehabilitation work will likely result in the loss of many of its original integrity of materials and the associated workmanship of the era, due to their deteriorated state." (Page 6) "While any future rehabilitation work is not relevant to the designation,...the designation of an additional building from this era that requires significant rehabilitation, would not be suitable." (Page 6) We submit Staff's analysis is convincing and should be followed by the City Council. III. THE COTTAGE AT 2501 SECOND STREET IS IN EXTREMELY POOR PHYSICAL CONDITION; ITS REHABILITATION WOULD SUBSTANTIALLY COMPROMISE ITS INTEGRITY In rendering its decision, the Landmarks Commission did not adequately consider either its extremely poor physical condition or the impact of its rehabilitation on its integrity. As Staff recognized in its report to the Landmarks Commission, rehabilitating this cottage will severely compromise its integrity by eliminating many of the materials and the associated workmanship that reflect the era of its design and construction. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Santa Monica City Council February 23, 2011 Page 5 We recognize that the cost of rehabilitating this cottage -- which is so extraordinary that the Rent Control Board determined it was not economically feasible -- is not relevant to the City Council's designation decision. But as City Staff has indicated, the extensive work required to rehabilitate this cottage would severely compromise its integrity and render it unworthy of designation. IV. THERE ARE MANY SUPERIOR TURN -OF- THE - CENTURY/ VICTORIAN VERNACULAR -STYLE COTTAGES IN SANTA MONICA, INCLUDING IN OCEAN PARK Consistent with the City's longstanding historic preservation practice, and the Landmarks Ordinance's designation criteria, City Staff assessed whether this cottage is a unique or rare example of its architectural type -- taking into account the inevitable result of the extensive refurbishment it requires. After reviewing surveys of such cottages in Santa Monica conducted by PCR (for the City) and Ms. Winder (for the property owner), City Staff concluded that the cottage at 2501 Second Street is insufficiently special to warrant designation. We believe the evidence strongly supports City Staff's position. Briefly: As Staff has pointed out, there are better examples of such cottages, three of which have been designated as City landmarks and others that are located in the Third Street Neighborhood Historic District. The consultants' survey work has identified 21 additional examples of such cottages which are in sound condition that have superior integrity. Moreover, some of these are designated landmarks or within an historic district. V. THE LANDMARKS COMMISSION ERRED IN CONCLUDING THAT THIS COTTAGE SATISFIES LANDMARKS ORDINANCE CRITERIA 1, 4 AND 6 The Landmarks Ordinance provides that the Commission (or City Council on appeal) "may" designate as a landmark a structure that satisfies one or more of the Ordinance's six criteria. Santa Monica Municipal Code Section 9.36.100(a) states in relevant part: "For purposes of this Chapter, the Landmarks Commission may approve the landmark designation of a structure, improvement, HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Santa Monica City Council February 23, 2011 Page 6 natural feature or an object if it finds that it meets one or more of the following criteria:..." (Emphasis added) Designation is a judgment call for the Commission and City Council; it is not mandatory even if a structure satisfies one or more of the Ordinance's criteria. Here, the Commission determined that the cottage satisfies Criteria 1, 4 and 6. We disagree. As the Staff has concluded, this cottage will not retain sufficient integrity after it is refurbished to satisfy either Criteria 1 or 4 as these criteria have historically been applied. And the Commission clearly stretched well beyond the City's historical practice in finding that the cottage's corner location is sufficient to satisfy Criteria 6. Regardless, ultimately the City Council must make a judgment call based on the evidence presented. We submit that City Staff's judgment, taking into account the extraordinary work required to refurbish the cottage and the impact of such work on the cottage's integrity, is correct. VI. CONCLUSION Accordingly, we urge the City Council to uphold this appeal and reverse the Landmarks Commission's decision. Respectfully Submitted, Christopher M. Harding KLK:snk cc: Rod Gould Eileen Fogarty Amanda Schachter Steve Traeger Scott Albright 20251 /Cor /CityCouncil.1001.CMH ATTACHMENT B Draft City Council Statement of Official Action 13 ity of PROJECT CASE NUMBER: Appeal 11 -001 LOCATION: 2501 2 "d Street CITY COUNCIL CITY OF SANTA MONICA STATEMENT OF OFFICIAL ACTION APPLICANT: City of Santa Monica Landmarks Commission APPELLANT: Plaster Family Trust PROPERTY OWNER: Plaster Family Trust CASE PLANNER: Scott Albright, AICP, Senior Planner REQUEST: Appeal 11 -001 of Landmarks Commission Approval of Landmark Designation Application 10 -002. CEQA STATUS: The project is exempt pursuant to CEQA Guidelines Section 15061(b)(3). Section 15061(b)(3) provides that CEQA only applies to those projects that have the potential for causing a significant effect on the environment. Since the proposed action would result in the retention of the existing structure and would not change the existing environmental baseline, there is no potential that the project would cause a significant effect on the environment. T CITY COUNCIL ACTION January 24, 2012 Date X Appeal upheld and Landmarks Commission approval reversed based upon the findings below: Appeal denied and Landmarks Commission decision to approve landmark designation is upheld based on the following findings: Other. EFFECTIVE DATE OF ACTION: January 24, 2012 The City Council, having held a public hearing on January 24, 2012, hereby denies Appeal 10 -001 and upholds the Landmarks Commission's decision to designate the building at 2501 2nd Street as a City Landmark based on the findings and determinations below. Each and all of the findings and determinations are based on the competent and substantial evidence, both oral and written, contained in the entire record relating to the Project. All summaries of information contained herein or in the findings are based on the substantial evidence in the record. The absence of any particular fact from any such summary is not an indication that a particular finding is not based in part on that fact. Findings and determinations for approval of Designation of the Landmark Building Per SMMC 9.36.100(a) (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. The residence located on the corner of 2nd Street and Mills is a rare example of a Turn -of- the - Century Cottage, a housing type associated with the Victorian era. This style, which served to architecturally link the nineteenth and twentieth centuries, was the most prevalent when the first wave of development took place in the Ocean Park district and was largely replaced with the Craftsman style by 1910. Exhibiting a high degree of architectural integrity, the subject property is part of a cluster of historic structures in the immediate vicinity, but one of the few of its type that exemplify the early history of Ocean Park and manifest its cultural, economic and social development. (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. 15 The residence located on the corner of 2nd Street and Mills is a fine example of a modest Turn -of- the - Century Cottage with subtle but refined architectural detailing including its windows with unique diamond -paned sashes, shaped rafter tails under the roof eaves, and continuous sill around the house separating horizontal wood siding from a wood shingle cladding. Based on a study of historic Sanborn Maps, it appears that there were once many examples of Turn -of- the - Century and Queen Anne style cottages in the Ocean Park area, but few remain. While it appears that the greatest number examples of the increasingly rare style are located in the Ocean Park neighborhood, the number remaining in the City as a whole is extremely low. Like nearly all examples of the over 100 -year old style, the residence located at the corner of 2nd Street and Mills has minor reversible alterations or additions, such as the front porch enclosure or room addition to the rear. However they do not deter from the significance of the architecture. (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. The subject property is situated on a highly visible corner location in the Ocean Park neighborhood containing other early 20th Century buildings. The property is improved with a Turn -of- the - Century cottage that is locally recognizable for its distinctive diamond -paned window design and for its setting on the lot with generous open space provided along 2nd Street and Mills Street. VOTE Ayes: Nays: Abstain: Absent: NOTICE If this is a final decision not subject to further appeal under Article 9 of the Santa Monica Municipal Code, the time within which judicial review of this decision must be sought is governed by Code of Civil Procedures Section 1094.6, which provision has been adopted by the City pursuant to Municipal Code Section 1.16.010. I hereby certify that this Statement of Official Action accurately reflects the final determination of the City Council of the City of Santa Monica. MARIA M. STEWART, City Clerk Date F: \CityPlanning\ Share \COUNCIL \STRPT\2011 \10APP -001 (2501 2nd Street).docx IN ATTACHMENT C Landmarks Commission Statement of Official Action February 14, 2011 17 FINDINGS AND DETERMINATION OF THE LANDMARKS COMMISSION OF THE CITY OF SANTA MONICA IN THE MATTER OF THE DESIGNATION OF A LANDMARK DESIGNATION OF A RESIDENTIAL STRUCTURE 10LM -002 LOCATED AT 2501 2ND STREET AS A CITY LANDMARK SECTION I. An application was filed by the City of Santa Monica Landmarks Commission on May 10, 2010 to designate the residential structure at 2501 2nd Street as a City Landmark. The Landmarks Commission, having held a Public Hearing on February 14, 2011, hereby designates the Turn -of- the - Century Cottage located at 2501 2nd Street as a City Landmark and the property commonly known as 2501 2 "d Street as a Landmark Parcel based on the following findings: (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. The residence located on the corner of 2nd Street and Mills is a rare example of a Turn -of- the - Century Cottage, a housing type associated with the Victorian era. This style, which served to architecturally link the nineteenth and twentieth centuries, was the most prevalent when the first wave of development took place in the Ocean Park district and was largely replaced with the Craftsman style by 1910. Exhibiting a high degree of architectural integrity, the subject property is part of a cluster of historic structures in the immediate vicinity, but one of the few of its type, that exemplify the early history of Ocean Park and manifest its cultural, economic and social development. (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. The residence located on the corner of 2nd Street and Mills is a fine example of a modest Turn -of -the- Century Cottage with subtle but refined architectural detailing including its windows with unique diamond -paned sashes, shaped rafter tails under the roof eaves, and continuous sill around the house separating horizontal wood siding from a wood shingle cladding. Based on a study of historic Sanborn Maps, it appears that there were once many examples of Turn- of -the- Century and Queen Anne style cottages in the Ocean Park area, but few remain. While it appears that the greatest number examples of the increasingly rare style are located in the Ocean Park neighborhood, the number remaining in the City as a whole is extremely low. Like nearly all examples of the over 100 -year old style, the residence located at the corner of 2nd Street and Mills has minor reversible in alterations or additions, such as the front porch enclosure or room addition to the rear. However they do not deter from the significance of the architecture. (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. The subject property is situated on a highly visible corner location in the Ocean Park neighborhood containing other early 20th Century buildings. The property is improved with a Turn -of- the - Century cottage that is locally recognizable for its distinctive diamond -paned window design and for its setting on the lot with generous open space provided along 2nd Street and Mills Street. SECTION II. The property commonly known as 2501 2nd Street (Assessor's Parcel Number 4287 - 010 -011) is designated as a Landmark Parcel in order to preserve, maintain, protect and safeguard the Landmark residential building. SECTION III. The accessory garage and the residential cottage, formally addressed as 238 Mills Street, both of which are located in the rear of the parcel, are excluded from the Landmark designation since they are not architecturally significant. SECTION IV. I hereby certify that the above Findings and Determination accurately reflect the final determination of the Landmarks Commission of the City of Santa Monica on February 14, 2011 as determined by the following vote: AYES: Bach, Fresco, Genser, Kaplan, Lehrer, Shari, Chair Berley ABSTAIN: None ABSENT: None NAYES: None Each and all of the findings and determinations are based on the competent and substantial evidence, both oral and written, contained in the entire record relating to the Project. All summaries of information contained herein or in the findings are based on the substantial evidence in the record. The absence of any particular fact from any such summary is not an indication that a particular finding is not based in part on that fact. Respectfully Submitted Attest: April 11, 2010 John Berley, Chairperson Scott Albright, AICP Landmarks. Commission Secretary 19 ATTACHMENT D Landmarks Commission Staff Report February 14, 2011 20 MEMORANDUM PLANNING AND COMMUNITY DEVELOPMENT DEPARTMENT CITY OF SANTA MONICA PLANNING DIVISION DATE: February 14, 2011 TO: The Honorable Landmarks Commission FROM: Planning Staff SUBJECT: 2501 2nd Street, 10LM -002 Public Hearing to Consider a Landmark Designation Application PROPERTY OWNER: Plaster Family Trust APPLICANT: Landmarks Commission INTRODUCTION & BACKGROUND The subject site at 2501 2nd Street is a corner lot in the City's Ocean Park neighborhood. It currently is improved with two residential cottages and a detached garage. The front structure, a cottage designed in the Turn -of- the- Century/Victorian Vernacular style was originally constructed between 1902 and 1907. The rear residence is a one -story wood -frame residence with board - and - batten siding. In March 2010, a request was received to demolish all on -site buildings. The request was made in order to allow the construction of new multi - family residential development. The Landmarks Commission first considered the demolition permit in April 2010. After receiving public testimony in support of preserving the existing primary structure, the Landmarks Commission requested additional information be provided, specifically identifying any examples of the style elsewhere within the City. In May 2010, after receiving a preliminary historic assessment, and after additional public testimony, the Commission voted to file a Landmark Designation application. A full landmark designation assessment report has been prepared and is attached. In addition, the subject property was subject to extensive remediation analysis in association with a request to remove the building from the City's Rent Control register. On January 14, 2010 the City's Rent Control Board issued a Notice of Decision granting the removal of the units from Rent Control based on certain findings of fact and conclusion of law including a statement that both units cannot be rehabilitated to render them habitable. 21 Historic Resources Inventory Status This property has been previously identified and assessed under the City's on -going survey process on three separate occasions. The subject property was initially surveyed during Phase 1 (1982 -1983) of the Santa Monica Historic Resources Inventory Survey and was determined eligible for local listing as a contributor to the potential 2500 Block of 3rd Street District and assigned a National Register Status Code of 5D1. The subject property was later reassessed during the City's 1994 Historic Resources Inventory Update following the 1994 Northridge earthquake, and again identified as a district contributor. Finally, the subject property was assessed again as part of the Historic Resources Inventory Update for the City of Santa Monica in 2004 as a 5D3. The property was determined eligible for listing as a contributor to a district, the 2500 Block of 3rd Street District, which appears eligible for local listing or designation through survey evaluation. PUBLIC NOTIFICATION Notice of the public hearing was provided as follows: Pursuant to SMMC Section 9.36.120, notice of the public hearing was mailed to all owners and residential and commercial tenants of property within a 300 -foot radius of the project and was published in the Santa Monica Daily Press at least ten consecutive calendar days prior to the hearing. A copy of the notice is included as Attachment B. ANALYSIS Property Information and Architectural Description The two detached cottage residences situated on the subject property were originally constructed between 1902 and 1907, and both retain their original residential use. Front Residence - The more pronounced of the buildings is a good example of the Turn - of- the - Century Cottage with moderate to high integrity. The residence has many character - defining features of the style including: • hipped roof; • asymmetrical front fagade; • bay window; and • recessed entrance. The residence is supported by brick foundation and has clapboard and shingle siding divided by a narrow wood watertable board. Decoratively cut exposed rafters are visible beneath the open eaves. The property appears to have high integrity and includes many of its original diagonal multi -light and doublehung windows. Alterations include the enclosed front porch and a lean -to rear addition located on the south east corner. Because the Turn -of- the - Century Cottage was largely replaced by the Craftsman -style cottage in Santa Monica during the first decade of the twentieth century, it is probable that the subject residence was either constructed between 1902 and 1905, or was moved to the site between 1902 and 1907. PA The rear cottage, 238 Mills, is a one -story wood -frame residence with board - and - batten siding. It is unclear if the residence has "single -wall' construction (no studs), which was a common construction method for beach cottages in Southern California constructed during the first three decades of the twentieth century, or whether the residence has traditional stud -wall framing. The rear residence has an asymmetrical front that faces the rear of the primary residence rather than the street. The single -story cottage has a hipped roof and several double hung single -light windows. It appears the primary character - defining feature of the rear residence, its board and batten siding, has deteriorated over the years and therefore, the rear residence has low integrity. A wood frame garage located between the two residences was constructed in 1927. The garage is a later addition and does not contribute to the significance of the primary residence at 2501 2nd Street. Turn -of- the - Century Cottage The Turn -of- the - Century Cottage or Victorian Vernacular Cottage style was a transitional architectural style popular in Los Angeles from the late 1800s to the early 1900s. The style is typically one story in height and has elements of the American Foursquare and Queen Anne style displayed on a smaller scale. Typical character defining features of this style include its box -like or rectangular shape, a pyramidal or hipped roof, a hipped or gabled dormer, a recessed front porch, and a bay window on the primary facade. The style developed as a utilitarian example of the Queen Anne cottage. Like the Queen Anne Cottage, the front fagade is asymmetrical and divided with a rounded bay and a recessed or covered entrance. The style was largely replaced by the Craftsman Cottage as the predominant wood -frame modest residence house type in Southern California, and is an increasingly rare local architectural style. With its asymmetrical fagade, bay window, and nearly square -plan, the primary house located on the corner of 2nd Street and Mills includes influences of both the Queen Anne and American Foursquare styles. The Turn -of- the - Century Cottage is highly significant as it was the last major housing type tied to the so- called Victorian era of the nineteenth century. Historic Associations Santa Monica In 1875, the original townsite of Santa Monica was surveyed, including all the land extending from Colorado Avenue on the south to Montana on the north, and from 26th Street on the east to the Pacific Ocean on the west. Between 1893 and the 1920s, the community operated as a tourist attraction that was visited primarily by wealthy patrons. Areas located just outside of the incorporated city limits were semi -rural in setting and populated with scattered residences. Following the widespread acceptance of the automobile in the 1920s, Santa Monica experienced a significant building boom, with numerous homes constructed in the tracts north of Montana and east of Seventh Street for year -round residents. 23 2501 2nd Street within the Ocean Park Neighborhood and the Vawter's Ocean Tract. The Ocean Park community developed somewhat independently of the rest of Santa Monica. Separated from the central and northern portions of the City by a deep natural gully today filled by the western terminus of the Santa Monica Freeway, Ocean Park was planned as a resort community oriented toward beachfront amusements by real - estate speculator and developer Abbott Kinney. The community adopted the name Ocean Park in 1895. Growth and development began in earnest in 1898, when Kinney was granted permission by the City of Santa Monica to build a 1,250 -foot pier at the end of Pier Avenue, on pilings already in place to carry the City's 200 -foot sewer outfall seaward. As early as 1901, Ocean Park was a community of 200 cottages, its growth promoted by the influx of newcomers from the mid - western states, and a boom in home construction. The town was incorporated in 1904, and later became part of the City of Santa Monica. Tourism remained Ocean Park's primary industry throughout the 20th century, but commercial and industrial enterprises began to play an increasingly prominent role by the 1920s. The Vawter's Ocean View Tract and the neighborhood surrounding the subject property was sparsely developed with residences during the early twentieth century. Based on the historic Sanborn maps, 2nd Street, originally called Lake Street, had few residences constructed by 1902. Block M, the site of the subject property, had 4 dwellings and 13 unimproved lots. By 1909, Block M included 12 dwellings with only 4 vacant lots. Based on the drawings included on the 1909 Sanborn map, it appears that at least 7 of the dwellings were Turn -of- the - Century Cottages, as indicated by their irregular footprints and projecting bays reflecting the earlier influence of late nineteenth century Victorian architecture. By 1918, Block M was subdivided into two blocks by the creation of Central Avenue, now Ocean Park Boulevard. In 1918, there were only two unimproved lots on the block. Landmarks Ordinance /Findings The Landmarks Ordinance requires the Commission to review the building's eligibility as a landmark based on the six criteria discussed below. The Commission may designate a property as a Landmark if it meets one or more of these criteria. Based on the research and evaluation of the one -story cottage residences at 2501 2 "d Street, the City's Historic Consultant has assessed that the front residence does meet the designation criteria established in SMMC 9.36.100 and believes it is eligible for City Landmark designation based upon the following draft findings: (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. The residence located on the corner of 2nd Street and Mills is a good example of a Turn -of -the- Century Cottage. The Turn -of- the - Century Cottage is highly significant as it was the last major housing type connected to the so- called Victorian era of the 24 nineteenth century and serves as an architectural transition from the nineteenth to the twentieth century. It was largely replaced by the Craftsman by the end of the first decade of the twentieth century. The residence located on the corner of 2nd Street and Mills retains sufficient architectural integrity to represent the residential development and architectural history of Santa Monica. The subject property manifests the cultural, economic, and social development of the Ocean Park neighborhood. Therefore, the residence located on the corner of 2nd Street and Mills appears to satisfy this criterion. (2) It has aesthetic or artistic interest or value, or other noteworthy interest or value. The resource does not appear to meet this criterion. The building lacks the sufficient aesthetic or artistic interest or value necessary for this designation. (3) It is identified with historic personages or with important events in local, state or national history. Historical background research did not reveal any information on the property's owners and /or occupants that indicates historical significance or notability. Therefore, the subject property does not appear to satisfy this criterion. (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. The residence located on the corner of 2nd Street and Mills is a good example of a Turn -of -the- Century Cottage. Similar to recent landmarked Turn -of- the - Century residences located at 2219 Ocean Avenue and at 1012 2nd Street, the corner residence at 2nd Street and Mills is a good example of a modest Turn -of- the - Century residence with subtle but refined architectural detailing. Based on a study of historic Sanborn Maps, it appears that there were once many examples of Turn -of -the- Century and Queen Anne style cottages in the Ocean Park area, but few remain. While it appears that the greatest number examples of the increasingly rare style are located in the Ocean Park neighborhood, the number remaining in the City as a whole is extremely low. Like nearly all examples of the over 100 -year old style, the residence located at the corner of 2nd Street and Mills has minor potentially reversible alterations or additions. However they do not deter from the significance of the architecture. Therefore, the property appears to satisfy this criterion. (5) It is a significant or a representative example of the work or product of a notable builder, designer or architect. It is unknown who designed and /or built the residence located on the corner of 2nd Street and Mills.Therefore the subject property does not appear to meet this criterion. (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. 25 The subject property does not appear to meet this criterion. STAFF RECOMMENDATION Staff's does not support the designation. Staff acknowledges the building's display of certain character defining features of the Turn -of- the - Century Victorian style; the use diamond paned windows on the upper sashes, particularly on the front facing bay window, and the decorative exposed rafter tails, as examples. The building also appears to have integrity, specific to its design, setting and location, and is appropriately scaled to the neighborhood in its current context. However, as discussed in the consultant's report and in the reports prepared by the property owner, although increasingly rare, staff asserts that there are other extant examples throughout the City that are representative of this style and would be able to convey the story of Santa Monica, specifically the Ocean Park neighborhood, at the Turn of the Century. The consultant's report describes the building as a good example of the Turn of the Century style. Staff believes that since there are similar better examples in the City, three of which have already been designated as City Landmarks (one of which is located in the Ocean Park neighborhood), and others located within the City's Third Street Neighborhood Historic District, also within Ocean Park, staff believes that a building from this period of the City's history should be an exemplary example; unique and rare in its overall character and detail, as the findings mandate. In addition, the property owner has consulted with several independent experts who have performed significant analysis of the building to assess its current state. This analysis concludes that the building is in an advanced state of structural and cosmetic disrepair. As noted earlier, the City's historic consultant acknowledges this current state, but concludes that the the building's condition may be poor, its historic integrity appears intact. While the existing condition of a building and integrity are independent of each other, and are not considerations in the findings for a landmark designation, however, given the residence's current state of disrepair and apparent need for structural and significant cosmetic rehabilitation, staff does not believe it would be prudent to designate a building as a landmark whose rehabilitation work will likely result in the loss of many of its original integrity of materials and the associated workmanship of the era, due to their deteriorated state. While any future rehabilitation work is not relevant to the designation, and will be addressed through a Certificate of Appropriateness, staff believes that given the extant examples that are currently intact and protected, the designation of an additional building from this era that requires significant rehabilitation, would not be suitable. Pursuant to SMMC 9.36.180, the Landmarks Commission's determination regarding this application may be appealed to the City Council if the appeal is filed with the City Planning Division within ten (10) consecutive days commencing from the date that the decision is made by the Landmarks Commission. M Attachments A. PCR Landmark Assessment Report (July 2010) B. Public Hearing Notice C. DPR Forms D. Aerial Photo E. Building Permits F. Correspondence from owners 27 ATTACHMENT E Excerpt of Landmarks Commission Minutes, February 14, 2011 m MINUTES REGULAR MEETING OF THE LANDMARKS COMMISSION Founded 1875 "Populus felix in urbe felicP Monday, February 14, 2011 City Council Chambers, Room 213 7:00 PM 1685 Main Street, Santa Monica CALL TO ORDER OF THE REGULAR MEETING OF THE LANDMARKS COMMISSION: The meeting was called to order at 7:02 pm. ROLL CALL: Present: Margaret Bach John Berley, Chair Nina Fresco Roger Genser Barbara Kaplan Ruthann Lehrer Ruth Shari, Chair Pro Tempore Also Present: Barry Rosenbaum, Senior Land Use Attorney Steve Traeger, Principal Urban Designer Scott Albright, AICP, Senior Planner Susan Umeda, Staff Assistant III 2. REPORT FROM STAFF: Mr. Albright reported that additional information was received about 2501 Second Street and 2219 Ocean Avenue. Mr. Albright reported that Item 10B was continued by staff. 9 -A. Landmark Designation Application 101-M -002, 2501 2nd Street, to determine whether the existing residential cottages, in whole or in part, should be designated as a City Landmark. (continued from December 14, 2010) The Commission made ex parte communication disclosures. ME Mr. Albright presented the staff report. Staff recommended denial of Landmark Designation Application 101-M -002, 2501 Second Street based upon the draft findings in the staff report. Chair Berley asked staff to explain why the application should be denied when the consultant's report stated that the structure meets two landmark criteria. Mr. Albright responded that it is staffs belief that there are other extant examples of this type of structure in Ocean Park that better portray this particular era in the City's history. Chair Berley noted that the consultant's report indicated that there is a dwindling number of comparables in the City but staff believes that there are a sufficient number of comparables. Mr. Albright stated that the extant comparables are protected by a.designation or in a historic district. Chair Berley stated that the owner's team has requested that they be given ten minutes to make their presentation. Commissioner Bach made a motion to approve this request. Commissioner Kaplan seconded the motion. The motion was approved by voice vote. The following members of the public addressed the Commission: Ken Kutcher, who represented the owner, Liz Lord, Dr. Anne Meyer, Steve Galloway, Mike Salazar (architect not associated with this project), Lou D'Elia, and Sylvia Gentile. Mr. Kutcher presented a rebuttal to public testimony. Mr. Kutcher stated that he supports staff's recommendation to deny landmark status to 2501 Second Street because there are other extant examples in the City and the proposed structures are in disrepair. Ms. Lord stated that the she supports the designation of the property and added that the house could be restored. Mr. Galloway stated that the house was neglected by the owner and supported designation. Mr. Salazar supported designation and described some of the significant features of the house; he added that the house could be rehabilitated to retain historic characteristics of the building. Mr. D'Elia stated that designation would preserve the character of the neighborhood and noted that the property owner is the owner of Signature Homes, a home builder based in Nevada. Ms. Gentile supported designation and described the character - defining features of the structure. Dr. Meyer supported designation of the property. Chair Berley noted that Mr. Kutcher stated that the property was never listed as individually eligible for landmark status. He stated that a continuation sheet, which was prepared by the Historic Resources Group in 2003, indicated that 2501 Second Street met Criteria 4. Mr. Kutcher stated that the evaluation conclusions that were presented had a status code of 5D1 or 5D3. Commissioner Kaplan stated that the reports submitted by the owner indicated that the process of rehabilitating the structure could endanger the lives of construction workers. Mr. Kutcher replied that the structural moving company and the engineering company indicated that there is a risk of personal injury if the 30 structure is lifted. Commissioner Kaplan asked Mr. Kutcher if there is a safe way the house could be lifted. Mr. Kutcher responded that there would be hazards in doing this type of work but does not know whether this would be in violation of the Occupation Safety and Health Act. Commissioner Kaplan asked Mr. Kutcher if it would be feasible to lift the structure in a safe way if costs are not factored into the project. Mr. Kutcher replied that it would be feasible to lift the structure in a safe manner at the right cost. Commissioner Fresco clarified that it is important for the Commission to review the quality of the structure in terms of landmark criteria and not base any judgment on the cost of rehabilitation; she noted that buildings that are subject to benign neglect are usually the structures with the most integrity. Commissioner Fresco stated that Ocean Park has the highest concentration of potentially historic buildings in the City. She stated that 2501 Second Street is in a potential historic district and there are only three hipped -roof cottages in this district; she stated that 2501 Second Street is the most intact hipped -roof cottage in the potential district. She stated that these cottages were prevalent in Ocean Park at one point in time and that these cottages should be preserved to retain the feeling and character of the Ocean Park neighborhood. She stated that determining what should be replaced is subjective because, as one of the speakers testified, a person who considers a new building as a desirable approach for the property would want to replace the old house with a newly - constructed one. However, she stated that there is always someone who wants to rehabilitate the existing structure to retain the historic character of the building. Commissioner Fresco stated that 2501 Second Street is an important structure in the neighborhood as a whole and as an example of this type of structure, which is becoming extremely rare. She stated that this structure is one of the original prevalent housing types in Santa Monica. Commissioner Lehrer stated that this building is part of a neighborhood complex and stated that she supported designation of the property. She stated that she was persuaded by the testimony of neighborhood residents who expressed interest in saving and restoring these types of structures because they are very important to the history of Santa Monica. She stated that turn -of- the - century cottages are a key component to neighborhood character and added that the building has distinguishing architectural features. She stated that it is not unusual to install internal shoring to lift the building and she stated that this operation does not pose any particular hazard to construction workers. She stated that demolition by neglect is tragic because this is how historic neighborhoods are decimated. She stated that this structure is a critical part of Ocean Park's historic fabric; the designation could be based on Criteria 1, as part of Ocean Park's historic built development and in terms of being a typical example of a turn -of- the - century Victorian cottage. She stated that the alterations are insignificant. Commissioner Kaplan expressed concern about the reports submitted by the owner because their criteria for demolition was primarily based on cost, which is 31 why the owner's representative was asked if workmen would be endangered during the lifting process; she stated that lifting houses is standard practice in restoring buildings. She stated that she did not notice as much damage to the house during her site visit, as described in the reports submitted by the owner; she noted that the photographs under the house showed beams that were split and piles that were deteriorated but stated that the problems with the house were not more extreme than other deteriorated structures that have been rehabilitated. She noted that the owner's representatives made statements such as "Restoration of old construction is more expensive per square foot than new construction." Commissioner Kaplan acknowledged that the statement made by the owner's representative regarding the cost of restoring historic buildings as being less than new construction is correct. However, she stated that she is not convinced that most of the historic features would need to be replaced. Commissioner Kaplan stated that there were a number of comparables which were built during the same period but the consultant's report stated that this building is a rare example of this type of structure; additionally, the neighbors have extensive knowledge about this property and affirmed that this structure is a rare example. Commissioner Kaplan stated that she was impressed with Commissioner Fresco's research regarding the number of comparables of each type, style and roof type in the area. Commissioner Kaplan also stated that she did an informal windshield survey of South Beach and noticed that the integrity of some areas was diminished. Commissioner Kaplan stated that she supports designation of the property. Commissioner Bach stated that she toured the property with the owner's representatives and observed the deteriorated condition of the building. She stated that the Commission generally would like to see a similar property restored. She stated that the neighbors clarified that the Commission may want to consider designating the property under Criterion 6 because the building is an anchor to the neighborhood. She stated that the Commission is dealing with a very fragile architectural fabric in Ocean Park. She stated that she supports designating the property with modifications to the findings. Commissioner Genser stated that Criterion 6 could apply to this property because it is in a unique location since it dominates the intersection of Mills and Second Streets. Commissioner Genser watched the building deteriorate; he stated that the structure is a wonderful example of the architecture in Ocean Park. He stated that the problems with the property are not insurmountable. He stated that the structure in the back of the property is less interesting than the front structure. He stated that there is a potential district in the area that still survives today and that the structure contributes to the historic fabric of the area. He stated that there is a cluster of landmarks which are close to 2501 Second Street such as the Shotgun House (which will be sited on Second Street), Merle Norman Building, Brown House, and Ocean Park Library. Therefore, he stated that he supports designation under Criteria 1, 4 and 6. He stated that the Commission must give a very clear direction to staff and have a very clear set of findings that are defensible. 32 Chair Berley thanked Commissioner Fresco for using the new inventory to help evaluate this property. He stated that this structure is a rare example of this type of building in an important area in the City; it also possesses a high degree of integrity. He added that the resource benefited from neglect because the structure is highly intact. He stated that the property is located in a unique and prominent location in the City, which is one of the reasons why this project is noticeable. Chair Berley stated that this structure has the potential to be a representative of this type of architectural style. He stated that he supports a landmark designation. Commissioner Bach emphasized the point made by Mr. Salazar regarding the double -hung, diamond -pane windows and the dual shingle and horizontal siding. Commissioner Kaplan pointed out Mr. Salazar's statement confirmed that the structure is the only one of that period with a continuous sill around the house. Commissioner Fresco made a motion to approve Landmark Designation Application 10LM -002, 2501 Second Street to designate the parcel and front structure of the property; the garage and rear building are excluded from the designation. She stated that the following should be added to the designation: [1] under Criterion 1, this was not just the housing type that connected the Victorian era as a transition into the twentieth century but it was also the most prevalent style of the original development in the Ocean Park and the architectural style is already quite rare and this building has a very high degree of integrity; [2] under Criterion 4, it is a fine example of this type of building and the continuous sill is a notable feature that should be included in the findings; and [3] under Criterion 6, the building is a recognizable feature in Ocean Park and is an anchor to the community since members of the community had knowledge of the location of the diamond -paned cottage. Commissioner Lehrer added that the shaped rafter tails under the eaves should be added under Criterion 4. Commissioner Genser seconded the motion. Commissioner Lehrer stated that Criterion 1 could be a generic discussion; however, the structure relates to the history of Ocean Park and the first wave of housing which occurred in this area since it is one of the early examples of residential development in Ocean Park. In regard to Criterion 1, Commissioner Genser added that the cluster of historic buildings in the area add to the context of the property. Chair Pro Tempore Shari stated that not all of the comparables cited in the Consultant's report are on Second Street and this fact should be factored into the language for designation. Additionally, she stated that the corner location and open space should be included in the designation since the fabric of the neighborhood would be altered if the corner or open space of the property is changed. 33 According to public testimony, Commissioner Bach noted that the diamond pane is part of a double -hung window, which is unique element to the structure. She added that identification of unique or rare features should be included in the designation. Commissioner Bach asked the Commission why the back house and the garage should not be included in the designation. Commissioner Lehrer responded that the garage and rear house are not significant; she stated that the front building has the highest level of architectural importance and historical value out of the three structures. Commissioner Lehrer added that it is advantageous to leave some flexibility in regard to the future of the site and how it might be managed by a new owner; however, the Commission would have the purview to review any new development that take place. A roll call was held for the motion and was approved by the following vote: AYES: Bach, Fresco, Genser, Kaplan, Lehrer, Shari, Chair Berley 3. ADJOURNMENT: Commissioner Bach made a motion to adjourn the meeting on February 15, 2011 at 12:06 am. Commissioner Lehrer seconded the motion. The motion was approved by voice vote. 34 ATTACHMENT F City Landmark Assessment and Evaluation Report July 27, 2010 Electronic version of attachment is not available for review. Document is available for review at the City Clerk's office and the Libraries. 35 2501 2nd Street Santa Monica, California City Landmark Assessment and Evaluation Report Evaluation Report Assessor's Parcel Map Sanborn Maps Photographs Prepared for: City of Santa Monica Planning Division July 27, 2010 2501 2nd Street Santa Monica, California City Landmark Assessment and Evaluation Report Environmental Setting Improvements on the subject property located at 2501 2nd Street include two detached cottage residences divided by a detached garage. Based on a site survey, available building permits, Los Angeles County Tax Assessor records, and Sanborn Maps, it appears that the original improvements to the subject property were made between 1902 and 1907. The subject property is bordered by a circa 1967 multi - family property to the south, 2 "d Street to the west, Mills Street to the north, and a wood -frame cottage to the east. The Pacific Ocean is approximately one - quarter mile to the west. The legal description of the subject property is Vawters Ocean View Tract Lot 11, Block M. Regulatory Setting This property has been previously identified and assessed under the City's on -going survey process on three separate occasions. The subject property was initially surveyed during Phase I (1982 -1983) of the Santa Monica Historic Resources Inventory Survey and was determined eligible for local listing as a contributor to the potential 2500 Block of 3` Street District and assigned a National Register Status Code of 5D1. The subject property was later reassessed during the City's 1994 Historic Resources Inventory Update following the 1994 Northridge earthquake, and again identified as a district contributor. Finally, the subject property was assessed again as part of the Historic Resources Inventory Update for the City of Santa Monica in 2004 as a 5D3. The property was determined eligible for listing as a contributor to a district, the 2500 Block of 3`d Street District, which appears eligible for local listing or designation through survey evaluation. Architectural Description Based on historic Sanborn maps, the two detached cottage residences situated on the subject property were originally constructed between 1902 and 1907. According to the survey forms created during the 1982 -1983 survey, a building permit from 1907 described the construction of the rear, secondary cottage located at 238 Mills Street as a "three room box dwelling" obtained by owner, Helen L. Clement. It appears the larger cottage fronting 2nd street was constructed earlier than 1907, as it is situated prominently on the corner of Mills and 2 "d while the rear cottage functions as the smaller secondary unit. It appears both cottages retain their original residential use. The primary residence, 2501 2nd Street, 'is a good example of the Turn -of -the- Century Cottage with moderate to high integrity. The residence has many character - defining features of the style including a hipped roof, asymmetrical front fagade with a bay window, and recessed entrance. The residence sits on a brick foundation and has clapboard and shingle siding divided by a narrow wood water - table board. Decoratively cut exposed rafters are visible beneath the open eaves. The property appears to have high integrity and includes many of its original diagonal multi -light and double - hung windows, Alterations include the enclosed front porch and a lean -to rear addition located on the south east corner. Because the Turn -of -the- Century Cottage was largely replaced by the Craftsman -style cottage in Santa Monica during the first decade of the twentieth century, it is 233 Wilshire Boulevard, Suite 130, Santa Monica, CA 90401 INTERNET www.pernet.com TEL 310.451.4488 rAx 310.451.5279 25012" Street Santa Monica, California City Landmark Assessment and Evaluation Report Page 2 probable that the subject residence was either constructed between 1902 and 1905, or was moved to the site between 1902 and 1907. The rear cottage, 238 Mills, is a one -story wood -frame residence with board - and -batten siding. It is unclear if the residence has "single- wall" construction (no studs), which was a common construction method for beach cottages in Southern California constructed during the first three decades of the twentieth century, or whether the residence has traditional stud -wall framing. The rear residence has an asymmetrical front that faces the rear of the primary residence rather than the street. The single - story cottage has a hipped roof and several double hung single -light windows. It appears the primary character - defining feature of the rear residence, its board and batten siding, has deteriorated over the years and therefore, the rear residence has low integrity. A wood frame garage located between the two residences was constructed in 1927. The garage is a later addition and does not contribute to the significance of the primary residence at 25012 "d Street. Historical Background Santa Monica In 1875, the original townsite of Santa Monica was surveyed, including all the land extending from Colorado Avenue on the south to Montana on the north, and from 26`h Street on the east to the Pacific Ocean on the west. Between 1893 and the 1920s, the community operated as a tourist attraction that was visited primarily by wealthy patrons. Areas located just outside of the incorporated city limits were semi -rural in setting and populated with scattered residences. Following the widespread acceptance of the automobile in the 1920s, Santa Monica experienced a significant building boom, with numerous homes constructed in the tracts north of Montana and east of Seventh Street for year -round residents. 25012 "d Street within the Ocean Park Neighborhood and the Vawter's Ocean Tract The Ocean Park community developed somewhat independently of the rest of Santa Monica. Separated from the central and northern portions of the City by a deep natural gully today filled by the western terminus of the Santa Monica Freeway, Ocean Park was planned as a resort community oriented toward beachfront amusements by real- estate speculator and developer Abbott Kinney. The community adopted the name Ocean Park in 1895. Growth and development began in earnest in 1898, when Kinney was granted permission by the City of Santa Monica to build a 1,250 -foot pier at the end of Pier Avenue, on pilings already in place to carry the City's 200 -foot sewer outfall seaward. As early as 1901, Ocean Park was a community of 200 cottages, its growth promoted by the influx of newcomers from the mid - western states, and a boom in home construction. The town was incorporated in 1904, and later became part of the City of Santa Monica. Tourism remained Ocean Park's primary industry throughout the 20`' century, but commercial and industrial enterprises began to play an increasingly prominent role by the 1920s. The Vawter's Ocean View Tract and the neighborhood surrounding the subject property was sparsely developed with residences during the early twentieth century. Based on the historic Sanborn maps, 2nd Street, originally called Lake Street, had few residences constructed by 1902. 25012"' Street Santa Monica, California City Landmark Assessment and Evaluation Report Page 3 Block M, the site of the subject property, had 4 dwellings and 13 unimproved lots. By 1909, Block M included 12 dwellings with only 4 vacant lots. Based on the drawings included on the 1909 Sanborn map, it appears that at least 7 of the dwellings were Turn -of -the- Century Cottages, as indicated by their irregular footprints and projecting bays reflecting the earlier influence of late - nineteenth century Victorian architecture. By 1918, Block M was subdivided into two blocks by the creation of Central Avenue, now Ocean Park Boulevard. In 1918, there were only two unimproved lots on the block. Turn -of- the - Century Cottage The Turn -of -the- Century Cottage or Victorian Vernacular Cottage style was a transitional architectural style popular in Los Angeles from the late 1800s to the early 1900s. The style is typically one story in height and has elements of the American Foursquare and Queen Anne style displayed on a smaller scale. Typical character- defining features of this style include its box -like or rectangular shape, a pyramidal or hipped roof, a hipped or gabled dormer, a recessed front porch, and a bay window on the primary facade. The style developed as a utilitarian example of the Queen Anne cottage. Like the Queen Anne Cottage, the front facade is asymmetrical and divided with a rounded bay and a recessed or covered entrance. The style was largely replaced by the Craftsman Cottage as the predominant wood -frame modest residence house type in Southern California, and is an increasingly rare local architectural style. With its asymmetrical facade, bay window, and nearly square -plan, the primary house located on the corner of 2 "a Street and Mills includes influences of both the Queen Anne and American Foursquare styles. The Turn -of -the- Century Cottage is highly significant as it was the last major housing type tied to the so- called Victorian era of the nineteenth century. Occupancy History Year Address Occupant 1913 -14 2501 2° Street A.M. Curtis 238 Mills J.S. Hunter 1915 -16 2501 2" Street J.H. Sams 238 Mills J.S. Hunter 1917 2501 2" Street Vacant 238 Mills E.A. Clark 1918 2501 2" Street C.G. Evans 238 Mills G.A. Redmond 1919 -20 2501 2° Street Elliot Yates 238 Mills W.N. Woodward 1921 -22 25012 n Street A.A. Hunter 238 Mills C.P. Turner 1923 -24 25012 " Street No Entry 238 Mills M.A. Woodhouse 25012 d Street Santa Monica, California City Landmark Assessment and Evaluation Report Page 4 Year Address Occupant 1925 2501 2° Street No Entry 238 Mills Herman Jochems 1927 2501 2n Street E.B. Swift 238 Mills Alvin Austen 1928 2501 2" Street W.E. Young 238 Mills J.D. Dowd 1930 -31 25012 n Street B.S. McConnell 238 Mills No Entry 1933 25012 n Street B.S. McConnell 238 Mills Charles Cox 1936 25012 n Street W.O. Hunter 238 Mills Edward Michelson 1938 2501 2° Street W.O. Hunter 238 Mills Edward Michelson 1940 2501 2" Street W.O. Hunter 238 Mills Edward Michelson 1947 -48 25012 n Street T.C. Estes 238 Mills Floyd Clothier 1952 -53 25012 n Street T.C. Estes 238 Mills No Entry 1954 2501 2" Street T.C. Estes 238 Mills No Entry 1958 -59 25012 n Street T.C. Estes 238 Mills No Entry 1960 -61 2501 2" Street T.C. Estes 238 Mills No Entry Evaluation of Significance Person(s) of Historical Importance Original property records are not available. The names of the original architect, builder, or owner associated with the subject property are unknown. City directory research over a 45 -year period indicates numerous tenants /owners have occupied both the primary residence at 2501 2nd Street and 238 Mills. (See City Directory Research table above for occupant listing). In concluding the background research, none of the occupants of the property appear to meet the level of significance necessary for City Landmark eligibility. In addition, a review of city directories to identify occupants of the subject property did not locate any persons of significant historical importance. Statement of other significance No evidence was discovered in current research of the property that indicates other significance. 2501 2nd Street Santa Monica, California City Landmark Assessment and Evaluation Report Page 5 Is the structure representative of a stvle in the Citv that is no loneer prevalent? Based on a study of historic Sanborn Maps in comparison with existing conditions, it appears that there were once many examples of Turn -of -the- Century and Queen Anne style cottages in the Ocean Park area, but few now remain. Furthermore, only a very small percentage of extant examples of the style in Ocean Park retain integrity. Some existing examples of the style include 212, 222, and 228 Bicknell, 2219 Ocean Avenue (City of Santa Monica Landmark), 145 Wadsworth, 120, 138, 139, and 143 Fraser, 147, 129, and 157 Hart, 237 Hill (Contributor to Designated 3`d Street District), and 2617 Hill (Contributor to Designated 3rd Street District), 2634 Hill (Contributor to Designated 3`d Street District), 2628 Hill (Contributor to Designated 3`d Street District) and 2547 3`d Street Hill (Contributor to Designated 3`d Street District), among others. While it appears that the greatest number examples of the increasingly rare style are located in the Ocean Park neighborhood, the number remaining in the City as a whole is extremely low. Furthermore, it appears existing examples of the type are threatened because they are typically modest in scale and in architectural detailing. The Turn -of -the- Century residence located on the corner of 2nd Street and Mills is comparable in architectural significance and integrity to recently landmarked examples of the style, at 2219 Ocean Avenue, and 1012 2 "d Street. Like most extant examples of the over 100 -year old style in the City of Santa Monica, the residence located at the corner of 2 "d Street has minor alterations or additions. The enclosure of the front porch and the rear addition are potentially reversible alterations. The rear cottage, 238 Mills, is a typical example of a Southern California beach cottage, which was a once ubiquitous type in beach resort towns in Southern California, including Santa Monica. The residence lacks sufficient significance and integrity for individual consideration as a City of Santa Monica Landmark, as its typical design does not individually add to the architectural culture of the City and its integrity has been compromised by years of neglect. However, 238 Mills does contribute to the potential 2500 Block of 3`d Street District. Does the structure contribute to a potential historic district? The Turn -of -the- Century residence located on the corner of 2 "d Street and Mills contributes to the potential 2500 Block of 3`d Street District, which is a highly intact potential district across Ocean Park Boulevard from the designated 3`d Street District. The rear cottage, 238 Mills, also contributes to the potential 2500 Block of 3`d Street District, as mentioned above. Loss of the Turn- of -the- Century residence located on the corner of 2nd Street and Mills would threaten the cohesion of the proposed district and could result in the removal of 2517 2 "d Street from the list of district contributors. Conclusion In applying the City's significance criteria for individual recognition as a proposed City of Santa Monica Landmark, the Tum -of -the- Century residence located on the corner of 2nd Street and Mills appears to rise to the threshold of significance for Landmark designation. As an individual resource, the 2501 2 "d Street residence possesses sufficient historical importance or architectural merit to 25012"' Street Santa Monica, California City Landmark Assessment and Evaluation Report Page 6 warrant designation. The garage and the rear residence at 238 Mills, do not warrant individual designation; however, the 238 Mills residence is eligible as a district contributor. Landmark Criteria 9.36 100(a) (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. The residence located on the corner of 2nd Street and Mills is a good example of a Turn- of -the- Century Cottage. The Turn-of -the- Century Cottage is highly significant as it was the last major housing type connected to the so- called Victorian era of the nineteenth century and serves as an architectural transition from the nineteenth, to the twentieth century. It was largely replaced by the Craftsman by the end of the first decade of the twentieth century. The residence located on the corner of 2 "d Street and Mills retains sufficient architectural integrity to represent the residential development and architectural history of Santa Monica. The subject property manifests the cultural, economic, and social development of the Ocean Park neighborhood. Therefore, the residence located on the corner of 2nd Street and Mills appears to satisfy this criterion. 9.36 100(a) (2) It has aesthetic or artistic interest or value, or other noteworthy interest or value. The resource does not appear to meet this criterion. The building lacks the sufficient aesthetic or artistic interest or value necessary for this designation. 9.36 100(a) (3) It is identified with historic personages or with important events in local, state or national history. Historical background research did not reveal any information on the property's owners and /or occupants that indicates historical significance or notability. Therefore, the subject property does not appear to satisfy this criterion 9.36.100(a) (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. The residence located on the corner of 2 "d Street and Mills is a good example of a Turn- of -the- Century Cottage. Similar to recent landmarked Turn -of -the- Century residences located at 2219 Ocean Avenue and at 1012 2nd Street, the corner residence at 2 "d Street and Mills is a good example of a modest Turn -of -the- Century residence with subtle but refined architectural detailing. Based on a study of historic Sanborn Maps, it appears that there were once many examples of Turn- of -the- Century and Queen Anne style cottages in the Ocean Park area, but few remain. While it appears that the greatest number examples of the increasingly rare style are located in the Ocean Park neighborhood, the number remaining in the City as a whole is extremely low. Like nearly all examples of the over 100 -year old style, the residence located at the corner of 2nd Street and Mills has minor potentially reversible alterations or additions. However they do not deter from the significance of the architecture. Therefore, the property appears to satisfy this criterion. 2501 2 "1 Street Santa Monica, California City Landmark Assessment and Evaluation Report Page 7 9.36 100(a) (5) It is a significant or a representative example of the work or product of a notable builder, designer or architect. It is unknown who designed and /or built the residence located on the corner of 2 "d Street and Mills. Therefore the subject property does not appear to meet this criterion. 9.36 100(a) (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. The subject property does not appear to meet this criterion. 25012 d Street Santa Monica, California City Landmark Assessment and Evaluation Report ATTACHMENTS Current Photographs Assessor's Map Sanborn Map 1918 Sanborn Map 1950 Ocean Park Turn -of -the- Century Cottages 25012" Street Santa Monica, California City Landmark Assessment and Evaluation Report Current Photographs Primary (West Elevation) of street - fronting dwelling, view east 25012"' Street Santa Monica, California City Landmark Assessment and Evaluation Report North Elevation, view southeast 2501 2 "d Street Santa Monica, California City Landmark Assessment and Evaluation Report South Elevation, view northeast 2501 2nd Street Santa Monica, California City Landmark Assessment and Evaluation Report Rear (East Elevation), view northwest 25012" Street Santa Monica, California City Landmark Assessment and Evaluation Report Rear Residence (West Elevation), view east 250!» _r Santa Monica, California . City Landmark Assessment and Evaluation Report /va t� � $\ �!p y \ � � w : w � � . ƒ j^ Assessor's Parcel Map } \/ \} §U. § ©� \ 2501 2 "d Street Santa Monica, California City Landmark Assessment and Evaluation Report Sanborn Map 1902 - 13- ��i�� DURf .. 1 -W ti K , 1 11 ` r� 1 " I BAND p ! °. 2t i' IYU BEAC1 % DEhCH 4y 1 1 1 1 1 � 9 88A x Y j 3 1 828 i? Hitt 20 � v} i - F-- _ i t I 1�I 11 i f �1 Iz l EI {1 , 1 , lLo k @FDk➢ y. ! 1 I! I j L u A 828 i? Hitt 20 � v} i - F-- _ 2501 2 °d Street Santa Monica, California City Landmark Assessment and Evaluation Report Sanborn Map 1909 01 I Ocean Park Turn -of -the- Century Cottages 212 Bicknell 222 Bicknell 228 Bicknell 2219 Ocean Ave 145 Wadsworth 120 Fraser 138 Fraser 139 Fraser 143 Fraser 147 Hart 129 Hart 157 Hart 237 Hill 2617 3rd Street 2634 3`d Street 2628 P Street 2547 P Street ATTACHMENT G Background Documentation (from appellant) Electronic version of attachment is not available for review. Document is available for review at the City Clerk's office and the Libraries. M; HARDING LAP,-MORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS SANTA MONICA, CALIFORNIA 90401-1602 (310)451 -3669 TELEPHONE (310) 393 -1007 kutcher @hlkklaw.com FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, )91)` Kenneth L. Kutcher .KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor /LandmarksComm,1001. KL K HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS SANTA MONICA, CALIFORNIA 90401 -1602 (310 }451 -3669 TELEPHONE (3(0) 393 -1007 kutChBr�QhIkkIBW.COm FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for .your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, Kenneth L. Kutcher .KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor /LandmarksComm.1001. KLK HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS SANTA MONICA, CALIFORNIA 90401 -1602 (310) 451-3669 TELEPHONE (310) 393 -1007 kutcher @hlkklaw.com FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for your customary Commissioner packets to be distributed shortly before the hearing. It also is.too large to send via email. Very truly yours, Kenneth L. Kutcher .KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor /LandmarksComm.1001. KLK HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS (310) 451 -3669 SANTA MONICA, CALIFORNIA 90401 -1602 kutcher @hikklaw.com TELEPHONE (310) 393 -1007 FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for ,your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, Kenneth L. Kutcher .KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 2025 1 /COr/LandmarksCOmm.1001. KLK HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS SANTA MONICA, CALIFORNIA 90401 -1602 (310) 451 -3669 TELEPHONE (310) 393 -1007 kutcher @hikklaw.com FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for .your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, Kenneth L. Kutcher .KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor(LandmarksComm:1001. KLK HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS SANTA MONICA, CALIFORNIA 90401 -1602 (310) 451 -3669 TELEPHONE (310) 393 -1007 kutcher@hlkklaw.com FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for ,your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, Kenneth L. Kutcher KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor /LandmarksComm.1001. KLK HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS SANTA MONICA, CALIFORNIA 90401-1602 (310) 451 -3669 TELEPHONE (310) 393 -1007 kutcher @hlkklaw.com FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, Kenneth L. Kutcher KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor/LandmarksComm.1001. KL K HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS (310) 451 -3669 SANTA MONICA, CALIFORNIA 90401 -1602 kutcher @hikklaw.com TELEPHONE (310) 393 -1007 FACSIMILE (310) 392 -3537 January 12, 2011 VIA MESSENGER DELIVERY Santa Monica Landmarks Commission 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Expert reports Site address: 2501 Second Street Our File No. 20251.001 Dear Commissioners: It is my understanding that the landmark application for the property at 2501 Second Street has been continued to February for your consideration. In anticipation of next month's hearing, I wanted to forward to you the booklet of expert reports we have Assembled and submitted to City Staff concerning the property on Second and Mills. The reports include expert analysis of historic resource criteria, foundation and structural systems, restoration /reconstruction scope and cost estimate, mold report and lab results, asbestos inspection, and architectural observations and suggestions. It was our goal to retain highly qualified and well regarded experts with preservation experience. Given the volume of information we have assembled, we did not want to wait for .your customary Commissioner packets to be distributed shortly before the hearing. It also is too large to send via email. Very truly yours, V Kenneth L. Kutcher .KLK:snk Enclosure cc: Scott Albright (w /o encl.) Steve Traeger (w /o encl.) 20251 /Cor /LandmarksComm.1001. KLK HARDING LARMORE KUTCHE]tf*gryW ATTORNEYS AT LAW CITY WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 1 ���r,l _. TI NJRITER'S E -MAIL ADDRESS (310) 461 -3669 SANTA MONICA, CALIFORNIA 90401-1602 kutcher @hikklaw.com TELEPHONE (310) 393 -1007 FACSIMILE (310) 392 -3537 January 4, 2011 VIA MESSENGER DELIVERY Scott Albright Senior Planner Planning Department City of Santa Monica 1685 Main Street,'Room 212 Santa Monica, CA 90401 Re: Landmark Designation Application No. 1 OLM -002 Address: 2501 Second Street Owner: Plaster Family Applicant: Santa Monica Landmarks Commission Our File No. 20251.001 Dear Mr. Albright: This letter is submitted on behalf of our client, the Plaster family, the owners of the property located at 2501 Second Street. The lot also includes a second dwelling at the rear bearing the address of 238 Mills Street (sometimes also referred to as 2501 -1/2 Second Street). The Landmarks Commission directed the filing of an application for landmark status for this property on May 10, 2010. The landmark application was filed during the 60 -day period for review of a demolition permit application. As a result of the application being filed, the hold on the pending demolition permit continues in effect. SMMC 9.04.10.16.010(d)(3). Since the filing of the landmarks application, we have requested time to retain a range of highly qualified experts to assist with evaluation of this property from the standpoint of structural integrity, health and safety, historic characteristics and integrity, rehabilitation, architecture and related issues. We have compiled a series of interrelated reports from these experts. They are enclosed. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 2 EXECUTIVE SUMMARY The expert reports show: • The property is not associated with historic persons or events; nor are the existing improvements the work of a master architect or builder. • The structures are structurally unsound, unsafe, dangerous and uninhabitable. • PCR and the owners' experts all agree that the rear house has lost its historic integrity. • The foundation of the front house is unsafe and must be replaced; in addition, the structural system of the house is severely compromised beyond repair. It is not safe to try to lift the house in order to replace the foundation. The structural engineers and historic house moving company recommend that the safest and most prudent course of action is to demolish the structure. Like the rear house, the front house also lacks integrity. The front house has been altered over the years, including an enclosure of the front porch, a poorly constructed addition at the rear, replacement of the historic roof, replacement of the original stoop, replacement of the original front and rear doors, and removal of the original chimney top. Most of the remaining character - defining features are damaged beyond repair and would require replacement in large part. Historic restoration of the front house is not recommended. This is because the work is so extensive and does not make economic sense given that the house is not the home of an historic personage or otherwise related to a significant architect, designer or builder. The Santa Monica Rent Control Board, a public entity with an interest in insuring that controlled rental units are maintained and not removed from the jurisdiction of the rent control law, concurs that the units are uninhabitable and cannot be made habitable in an economically feasible manner. The house is not the last, nor the best, example of its type. There are numerous much better examples of Turn of the Century Cottages in the nearby vicinity. Moreover, although the visual appearance of the house could be reconstructed, this would constitute an undesirable replication project, not a true preservation project. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 3 • The historic windows can be salvaged. There is dangerous and toxic mold present in the front house that will necessitate significant remediation, including the removal and replacement of major portions of the kitchen, bathroom and interior walls. Once the interior walls are opened the extent of the mold problem may be even more significant and problematic. • There is friable asbestos present in the dwellings. Our experts are as follows: Nabih Youssef & Associates: An internationally recognized structural engineering firm specializing in structural and earthquake engineering consultation. www.nvase.com Spectra Company: A very well regarded award winning company that engages in historic restoration whose restoration work includes properties on the National Register and well- recognized landmarks such as the Marion Davies Guest House in Santa Monica. www.spectracompany.com Quinn Evans Architects: A nationally recognized architectural firm whose practice focuses on preserving and renewing historically significant properties, including, for example, the Lincoln Home National Historic Site in Springfield Illinois. www.guinnevans.com CADForce: an architectural and engineering design and production services firm formed in 2001 and headquartered in Los Angeles that has completed more than 1,500 projects ranging from single family homes to high -rise office buildings and complexes, mixed -use developments and major university, municipal and hospitality projects. www.cadforce.net American Heavy Moving and Ripping, Inc.: A company with extensive experience in lifting and shoring historic structures, including cottages. www.americanheavVmoving.com Architectural Preservation Planning Services: A historic resource consulting firm formed by Mary Jo Winder, who holds a Master of Architecture (Historic Preservation) degree and has extensive experience in analyzing properties for potential landmark designation, including in Santa Monica. For 16 years (1990 to 2006) Ms. Winder served as Senior Planner in the Design & Historic Preservation Section of the Planning Division for the City of Pasadena. HARDING LAP-MORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 4 The Mold Guy, Inc: A company dedicated to the detection and prevention of mold in indoor environments, using professional and certified inspectors and remediators. www.themoldguy.org Aardvark Property Hazard Analysis Co.: Established in 1991 by Frank Najafi, who worked as an asbestos building inspector for the Long Beach Unified School District, this company has almost 20 years of experience with over 9,000 completed projects. NEXT STEPS We request that the City forward copies of these reports to the City's consultant, PCR Services. We also request that a site visit be arranged for PCR to tour the property with our experts so that a realtime exchange of professional information and observations can occur to ensure full and complete access to the structure(s) and observations by our experts. If more time is needed to arrange this site visit or to fully evaluate our expert reports, we will recommend that our client consent to delaying the hearing for another 30 days. Please ensure that the Landmarks Commission gets copies of each of our reports for their review prior to the hearing on whether to designate the house at 2501 Second Street as a local landmark. BACKGROUND It is important to note that the Landmarks Commission has filed an application for designation of 2501 Second Street as a landmark. No applications have been filed for creation of a historic district, and that issue is not before the Commission. For that reason, it is not addressed in these reports. Furthermore, no application has been filed for the rear structure at 238 Mills Street.' Also, to put this matter in context, it is important to note that the Rent Control Board has reviewed the property and has granted Category C Removal Permit # 432R -C for uninhabitability and infeasibility of repairing the units in an economically viable manner. City Charter art. XVIII, § 1803(t)(2)(i). ' PCR's Evaluation Report dated July 27, 2010, concludes that the rear cottage "lacks sufficient significance and integrity for individual consideration as a City of Santa Monica Landmark, as its typical design does not individually add to the architectural culture of the City and its integrity has been compromised by years of neglect." PCR Evaluation Report, p. 5.) As described herein, we believe the same can (and should) be said for the front residence as well. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 5 In granting the Category C Removal Permit, the Rent Control Board found: "5. The unreinforced masonry foundation of unit 2501 is deteriorated and poses a high seismic risk. There is no evidence of a connection between the foundation and the structure. Unit 2501's non - permitted porch which houses its water heater, refrigerator, and laundry hookups is substandard and should be removed. The improper conversion of the unit's bathtub to a shower caused water leakage and wood rot damage to the structure. "6. A mold inspection and laboratory analysis shows the presence of high levels of aspergillus /penicillium spores in unit 2501's kitchen, pantry, bathroom, front bedroom closet and front bedroom. Trace amounts of three other mold types were found in some of these areas. Higher levels of spores may indicate the presence of moisture sources and resultant fungal growth. Extensive mold remediation is recommended. 7. Unit 2501 -1/2 lacks foundation footings and shows severe sloping of its existing floors. The later -added bathroom has no foundation and rests directly on grade. Both the applicant's contractor and the Board's consultant conclude that unit 2501 -1/2 cannot be repaired to render it habitable. "8. Units 2501 and 2501 -1/2 are uninhabitable within the meaning of Rent Control Law section 1803(t)(2)(i)." 11. Units 2501 and 2501 -1/2 cannot be rehabilitated to render them habitable." (Emphasis added.) Thus, although this property was subject to the Santa Monica Rent Control Law, the Santa Monica Rent Control Board granted a removal permit. The Board has a vested interest in making sure that controlled rental units are not removed from the rental housing market and the jurisdiction of the Rent Control Law. The Board vigorously defends and asserts its jurisdiction in this regard. The Board does not easily or routinely grant removal permits and has over 30 years experience in analyzing repair costs and economic feasibility issues. The Board only grants removal permits after careful analysis by its staff and construction experts. HAP-DING LAWORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 6 The removal permit was granted on the basis that the units at the property are uninhabitable and cannot be made habitable in an economically feasible manner. The Rent Control Board's determination is relevant, if not binding, on the Landmarks Commission. See George v. California Unemployment Ins. Appeals Bd., 179 Cal. App. 4t' 1475, 1488, 102 Cal. Rptr. 3d 431 (2009). This Commission should carefully consider, and defer to, the expertise of the Board in analyzing the economic feasibility of repairing the structures at this property. STANDARD OF REVIEW Pursuant to Santa Monica Landmarks Ordinance Section 9.36.100(a), a structure qualifies as a local landmark if it meets any of the following six criteria: (1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. (2) It has aesthetic or artistic interest, or value, or other noteworthy interest or value. (3) It is identified with historic personages or with important events in local, state or national history. (4) It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. (5) It is a significant or a representative example of the work or product of a notable builder, designer or architect. (6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City. For this particular property, the PCR Services Corporation Evaluation Report dated July 27, 2010, suggests that the house at 2501 Second Street may qualify for local landmark designation under criteria (1) and (4). (PCR Evaluation Report, p. 6.) PCR's Evaluation Report acknowledges that "the primary character - defining feature of the rear residence, its board and batten siding, has deteriorated over the years and therefore, the rear residence has low integrity." (Id. at 2.) HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright .January 4, 2011 Page 7 Other than Staff Reports and Findings and Determinations for individual properties, there is little guidance on how to interpret these criteria. Experienced professionals often look for guidance to the National Park Service publications. National Register Bulletin #15 is entitled, "How to Apply the National Register Criteria for Evaluation." Within Bulletin #15, National Park Service Criterion C is entitled, "Design /Construction," and has a subcategory subtitled, "Distinctive Characteristics of Type, Period, and Method of Construction." This criterion is close to Santa Monica local Criterion 4 and the architectural component of local Criterion 1. The National Park Service writes: "To be eligible under this portion of the Criterion, a property must clearly illustrate, through 'distinctive characteristics,' the following: • "The pattern of features common to a particular class of resources, • "The individuality or variation of features that occurs within the class, • "The evolution of that class, or • "The transition between classes of resources." National Register Bulletin #15, "How to Apply the National Register Criteria for Evaluation" (U.S. Dep't of the Interior, rev. 1995) p. 18. Bulletin #15 goes on to explain: "'Distinctive characteristics' are the physical features or traits that commonly recur in individual types, periods, or methods of construction. To be eligible, a property must clearly contain enough of those characteristics to be considered a true representative of a particular type, period, or method of construction." Id. Chapter III of Bulletin #15 explains the importance of a property's "integrity" when evaluating the potential significance of a property: "Integrity is the ability of a property to convey its significance. To be listed ... a property must not only be shown to be significant under the ... criteria, but it also must have integrity." Id. at 44. There are seven aspects of Integrity: location; design, setting, materials, workmanship, feeling, and association. Id. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 8 With respect to Integrity, the Bulletin goes on to state, "A property significant under Criterion C must retain those physical features that characterize the type, period, or method of construction that the property represents. Retention of design, workmanship, and materials will usually be more important than location, setting, feeling, and association." Id. at 48. Finally, the Bulletin explains that reconstructed properties are only eligible when .no other building or structure with the same associations has survived (i.e., the last example of its kind): "A reconstructed property is eligible when it is accurately executed in a suitable environment and presented in a dignified manner as part of a restoration master plan and when no other building or structure with the same associations has survived. All three of these requirements must be met." Id. at 37 (emphasis in original). PRIOR HEARINGS The demolition permit application for this property was considered twice by the Landmarks Commission. At the first hearing on April 12, 2010, a neighbor contended that the house "doesn't appear to be, if you go there in person, as bad as the pictures indicate that it is." During questioning of the property owner, Commissioner Shari asked whether the owner had considered restoring the house and how long it had been since that had been considered. During deliberations, Commissioner Bach acknowledged, that, while the board -. and - batten siding in the rear was "intriguing," it was "admittedly very deteriorated, so I'm sort of struggling" and therefore she needed more information. Commissioner Bach requested also context about other existing examples of this type of home so she could assess whether either of these dwellings is the last of its type. The Commission voted to continue the hearing for further information. At the May 10, 2010 hearing, during questions of the owner, Chair Kaplan asked about the precedent for simultaneously designating and authorizing demolition to HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 9 proceed. Kevin Kozal mentioned the example at 1127 Sixth Street.2 Senior Land Use Attorney Barry Rosenbaum indicated that he wished to address that concept at a later hearing. Commissioner Genser indicated that although he felt the house reaches the threshold for filing the application, "I'm not sure in the end I would support a landmark." Commissioner Bach seemed more interested in the concept of a potential historic d istrict. Chair Kaplan was quite concerned about the mold problems. The Commission voted to file an application to preserve its jurisdiction over the property. Attorney Rosenbaum explained the preliminary nature of this vote: "This is a common reminder that I give, and I think actually the attorney for the owner said the same thing. Which is recognition that this is just a threshold determination, that you understand well. You're just deciding whether or not to file an application, certainly not deciding whether or not any part of this property should be landmarked. And so the issue before you, as it has been with all demolition applications, is whether there's some credible evidence that the property might meet the criteria for landmark. That's what's guiding you tonight." EXPERT REPORTS The Plaster family has retained a series of experts to perform detailed studies of the structures at the property. The resulting reports are enclosed with this letter and are summarized below. 2 In that matter, the Landmarks Commission designated the structure at 1127 Sixth Street a landmark (96LM002). This was appealed to the City Council, and on January 28, 1997, the City Council unanimously (6 -0) voted to uphold the landmark designation but to simultaneously authorize demolition. The minutes from that meeting confirm the motion approved was to "uphold the Landmarks Commission designation but authorize the demolition recognizing that this building was severely damaged in the earthquake and that any rehabilitation is not possible for the preservation of the original fabric of the building." HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 10 A. The Nabih Youssef & Associates Report Demonstrates That The Front House Is Structurally Unsound And Should Be Demolished. Nabih Youssef & Associates is an internationally recognized structural engineering firm providing specialized structural and earthquake engineering consulting services for new and existing buildings. Nabih Youssef & Associates has extensive experience completing structural and seismic studies of existing buildings, including several in the City of Santa Monica. Nabih Youssef & Associates was the structural engineering firm that provided a seismic analysis of the Henshey's department store following the 1994 earthquake. Currently, Nabih Youssef & Associates is performing structural and seismic work in relation to the landmark fagade of the Mayfair Theater in Santa Monica. The Plaster family retained Nabih Youssef & Associates to evaluate the structural systems of the front house. Nabih Youssef & Associates found that the integrity of the structural systems of the, house is severely compromised, the building is not suitable for occupancy and poses serious safety hazards, and that the most prudent course of action is to demolish the structure. The Nabih Youssef & Associates Report states: "In our professional opinion, a majority of the structural components of the single family home -- including floor joists and framing, along with exterior components including exterior walls and wall framing -- are beyond repair and should be removed and replaced. In addition, the entire foundation of the single family home must be replaced." Youssef Report, p. 3. "Given the overall condition of the house as discussed in this report, the best course of action would be to demolish the existing structure before replacing the foundation." Id. at D. 8. 10 As noted in the Nabih Youssef & Associates report, a major structural problem with this house is its foundation, which must be entirely replaced. Our firm contacted Ralph Clark of American Heavy Moving and Rigging, Inc., a company with extensive experience in lifting and shoring residential apartment buildings and large homes, to ascertain whether it would be physically possible and safe to lift the house in order to replace the foundation. Mr. Clark explains in his letter that in his professional opinion it HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 11 would be extremely difficult and very expensive to lift the house. He also concludes that this would impose a serious risk of collapse that could injure workers or others and damage or destroy the structure. C. The Spectra Company Report Concludes That Historic Restoration Of Expense Involved In That The House Is Not The Work Of A Master, No The Home Of An Important Historic Personage. Spectra Company is a very well regarded company that engages in historic restoration. They received the 2009 Preservation Design Award from the California Preservation Foundation for their work on the National Register Villa Riviera Luxury Cooperative apartment building in Long Beach. They have also worked on the National Register Pantages Theater, the National Register Old San Diego Gas and Electric Building, California Historic Landmark Frank Lloyd Wright Ennis House, and the National Historic Landmark Gamble House. They have also done work with the City of Pasadena, County of Orange, County of Los Angeles, and the City of Santa Monica. In Santa Monica, Spectra Company completed the historic wood restoration on the Marion Davies Guest House at the Annenberg Community Center. Spectra Company analyzed the cost of restoration and structural retrofit of the front house at 2501 Second Street in compliance with the Secretary of the Interior Standards for the Treatment of Historic Properties. Spectra Company concludes that the cost to renovate the front house at 2501 Second Street could easily reach $500,000 or more (a cost of over $450 per square foot). Spectra Company concludes that "given the cost we project to renovate this house, we would not expect such renovation to be undertaken unless there was an independent historic significance to the house, such as an original architect, builder, owner or event related to the house of historic significance." Spectra Company report at p. 3. Spectra Company further states "In our experience, the fact that the house may be an example of a particular style of architecture or design in itself is not enough to warrant incurring the renovation costs. In our opinion, incurring such renovation costs would not be economically prudent." Id. D. Quinn Evans Architects, A Nationally Recognized Architectural Firm The Plaster family has also retained Jeffrey Luker, AIA, LEED AP, a principal at Quinn Evans Architects to evaluate the property. Quinn Evans is a nationally HARDING LAWORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 12 recognized architectural firm whose practice focuses on preserving and renewing historically significant properties. For example, in 2006 Quinn Evans assisted in preparing a Historic Structure Report for the Lincoln Home National Historic Site in Springfield Illinois on behalf the United States Department of the Interior, National Park Service. Mr. Luker is a qualified preservation architect meeting the Secretary of the Interior's professional qualifications standards. Based on his study of the property, Mr. Luker found: "[Tjhe subject Residence presents only a marginal example of the subject 'Turn of the Century Cottage'. Briefly stated: "The Residence is in very poor condition. Character defining features have reached a deteriorated state making difficult the preservation of those features (i.e. rafter ends, wood siding, masonry chimney, front porch details). By and large, reconstructed properties are not eligible per the recommendations of the National Register Bulletin #15, p. 37. "The front porch has been enclosed as a non- historic alteration and the original stoop appears to have been replaced with a non- historic stair. • "The upper portion of the original chimney has been removed and capped. • "A poorly constructed infill/ addition been installed at the rear of the Residence. • "It appears that the original front and rear doors have been replaced based on their appearance and construction. • "The original roofing has been replaced with asphalt roofing. "In summary, the.overall scale/ mass of the building, the windows, and the deep roof overhang appear to be the only extant physical characteristics that foster initial consideration of whether the building merits preservation." HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2019 Page 13 Based on his study of the property, Mr. Luker concluded that the front house does not satisfy any of the City's six criteria for landmark designation: "Relevant to the City of Santa Monica Landmark or Historic District Designation Criteria: Section 9.36.100 of the City Ordinance listed below I offer the following assessment: "'(1) It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City.' "Although it is an example of a Turn -of -the Century Cottage, the Residence does not warrant designation because: a. "It is not rare as an example of its style in this area. We have been made aware of far better examples of Turn of the Century Cottages, including examples in Santa Monica. Specific examples of this architectural style have been listed in reports by PCR (City Landmark Assessment and Evaluation Report- 2501 2nd Street, Santa Monica CA PCR, July 27, 2010) and Mary Jo Winder (Historic/ Architectural Evaluation for 2501 2nd Street- Mary Jo Winder, April 19th, 2010 and Analysis of Architectural Integrity- 2501 2nd Street- Mary Jo Winder, August 28th, 2010). b. "The Residence lacks integrity because it has been altered in significant ways. Specifically as noted: the enclosure of the front porch, the removal of the historic chimney top, the replacement of the original front stoop, replacement of the front and back doors, the non -code complaint addition at the rear of the residence, and the removal and replacement of the wood shale shingles with asphalt shingles. Though the visual appearance of these items may be reversible, it is in fact moving toward a replication project with each repair and no longer a preservatior of the historic fabric. c. "The Residence is in significant disrepair and would require extensive reconstruction both aesthetically HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 14 and structurally. This fact has been noted in the structural engineer's report (Structural Evaluation of 2501 2nd Street- Nabih Youssef Associates September 27th, 2010) and the contractor's report (Cost evaluation from Spectra Company- historic preservation Construction Company). As noted in the Spectra report, because of the extent of the degradation, the cost of preserving the Residence is substantially higher than cost of what would be considered market value replacement. d. "The Residence has fundamental structural issues that would be extremely challenging to remedy without demolition or major engineering feats and expenditures out of scale with the functional size and significance of the Residence. The existing construction is no longer considered code compliant for reasons of risk to life and safety with instances of under - sized/ over - spanning members. Serious sagging is evident in the roof structure, and the structural system under the house has deteriorated beyond safe limits and in some cases is non - existent. (Structural Evaluation of 2501 2nd Street- Nabih Youssef Associates September 27th, 2010) and the contractor's report (Cost evaluation from Spectra Company- historic preservation construction company). e. "Of architectural significance, one of the character - defining features might be salvaged. Specifically, the windows may be removed and with significant work be made to be functional. Very little else of the existing structure has any great justification for being salvaged or saved due to its lack of significance or historic characteristics. " `(2) It has aesthetic or artistic interest or value, or other noteworthy interest or value.' "It is my opinion that as a stand -alone object, the building does not present noteworthy interest or value. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 15 "'(3) It is identified with historic personages or with important events in local, state or national history.' • "I have seen no evidence that the structure has any unique significance in its history pertaining to people or events; "'(4) It embodies distinguishing architectural characteristics valuable to a study of a period style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study.' • `Please see finding #1 above. " `(5) It is a significant or a representative example of the work or product of a notable builder, designer or architect.' "To my knowledge, the original builder, designer, or architect is unknown. " `(6) It has a unique location, a singular physical characteristic, or is an established and familiar visual feature of a neighborhood, community or the City.' "Other than its age, there is nothing uniquely significant about the location of this particular Residence. As the PCR Report confirms, there were once many examples of Turn -of- the - Century and Queen Anne style cottages in the Ocean Park area. They were typically modest in scale and in architectural detailing. The PCR and Mary Jo Winders reports show examples of these existing Turn of the Century residences in this area and in fact confirm they are not rare. (Historic/ Architectural Evaluation for 2501 2nd Street- Mary Jo Winder, April 19th, 2010 and Analysis of Architectural Integrity- 2501 2nd Street- Mary Jo Winder, August 28th, 2010)." Mr. Luker concludes that the front house at 2501 Second Street does not rise to the level of significance for purposes of individual designation. Mr. Luker expressly points out that those "working in the field of preservation must be ever mindful of the need for discernment in preserving meritorious structures without overreaching in ways that could harm future efforts for keeping buildings truly worth saving." HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 16 E. Which Would Not Legitimately Advance The Interests Of Historic Preservation. The Plaster family also retained Jefferson Schierbeek, AIA, LEED AP BD +C, to assess the feasibility of rehabilitating the front house. Mr. Schierbeek has been practicing architecture for 25 years and holds Master's Degrees from the University of Michigan in both Architecture and Urban Planning. Mr. Schierbeek has reviewed all of the experts' reports and has conducted several site visits to observe the condition of the buildings. Mr. Schierbeek has prepared a letter describing his work and providing his insights on the property. Among other things, Mr. Schierbeek finds: The areas listed as character - defining features in PCR's report (which include the wood siding, the decorative eave ends, the diamond window glazing patterning, the chimney and the front porch) are the areas that have the most significant deterioration and are the materials needing the most work to restore or, in several instances, requiring replacement entirely. The restoration of this house would likely result in the replacement of many character - defining features and would necessarily end up as a re- creation rather than a house with original materials preserved. This issue of preservation versus rebuilding is a much debated topic amongst preservation experts but it is generally accepted that a re- creation should only be considered as the last and final effort made to save something of major significant historical importance, which this residence is not. • As confirmed by the Spectra Company and Nabih Youssef & Associates reports, there is extensive structural damage to the structures and the cost of historic restoration would greatly exceed the cost of new construction. • In assessing the rear structure, PCR acknowledges that a deteriorated condition adversely affects the integrity of the building. PCR's integrity assessment of the front building is more "hopeful and perhaps wishful" rather than based upon the actual condition of the structure. In summary, Mr. Schierbeek concludes that given the poor condition of the house, any historic restoration would be extraordinarily expensive and would result in a HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 17 re- creation building and not a preserved building. While this may be an appropriate approach for a building that has great historic significance, it is not appropriate for a house that is simply old and an example of a fairly widespread architecture type, particularly where there are many better examples of this same architecture type in the nearby vicinity. F. Mary Jo Winder Of Architectural Preservation Planning Services Also The Plaster family retained Mary Jo Winder of Architectural Preservation Planning Services prior to the filing of the demolition permit application. Ms. Winder holds a Master of Architecture (Historic Preservation) degree and has extensive -experience in analyzing properties for potential landmark designation, including in Santa Monica. For 16 years (1990 to 2006) she served as Senior Planner in the Design & Historic Preservation Section of the Planning Division for the City of Pasadena. The Plaster family desired a professional opinion about the potential landmark status of the property before pursing any demolition or redevelopment plans. Based upon Ms. Winder's opinion that none of the structures on the property merit designation, the family proceeded with the demolition application. The report prepared by PCR, the City's expert, dated July 27, 2010, concedes that the property does not merit designation under four of the six possible criteria for individual designation set forth at Landmarks Ordinance Section 9.36.100(a)(1) -(6). PCR suggests that the property may qualify under only two of the criteria on the basis that the front house has integrity as an example of a turn of the century cottage. Ms. Winder disagrees with this assessment and concludes that in her professional opinion the buildings at the property do not merit landmark designation: "[T]he buildings on the property are not eligible for landmark designation because they fail to meet any of the six criteria in the Santa Monica Municipal Code." (Winder's April 2010 Report, p. 1.) With regard to whether the front house serves as a valuable example of Turn of the Century architecture, Ms. Winder concludes it exhibits only modest traits: "Although the house on the front of the lot has more character- defining features of residential vernacular architecture of the turn of the century as compared to the rear house, it is still a very modest example of a building type and style (massed plan bungalow) that represents that HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 18 period in the history of Santa Monica. Other massed plan bungalows in the Third Street Landmark District and the Ocean Park neighborhood are more architecturally intact than this house and, therefore, they better symbolize turn of the century residences in Ocean Park. (Id. at 2.) "The massed plan bungalow style of the front house is a common residential property type constructed in Santa Monica, California and across the U.S. between 1890 and 1910. The only features of the house that contribute to it being anything other than a modest example of the style and period are what appears to be hand - crafted rafter ends under the eaves and diamond- pattern upper sashes in most of its windows. These features, however, are not unique, as they are commonly found on numerous other turn- of -the- century residential structures in the City. The rear house and garage have vernacular features and no indication of craftsmanship, use of indigenous materials or unique method of construction. None of the buildings on the property at 2501 Second Street are valuable examples that would contribute to a study of the history of residential architecture in Santa Monica. The property clearly does not meet requirements for designation under this criterion." (Id. at 3.) In conclusion Ms. Winder states: "Although the residential buildings at 2501 Second Street are listed as contributing buildings to the Third Street Landmark District, neither of them qualifies as individually significant representative examples of architecture or architectural development in the City of Santa Monica. There is no known significant association with a person, group or event that are noted for any measurable contribution to the history of Santa Monica, or the history of the state or nation. In my professional opinion, based on the analysis set forth above, the property clearly does not meet any of the criteria in the Municipal Code for designation as an individual landmark." (Id. at 4.) HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 19 G. The Property Has Maior Mold Problems, Including Toxic Mold. The Plaster family hired Mark Levy, president of The Mold Guy, Inc., to inspect the front house and test for mold. Mr. Levy is a certified mold inspector and certified indoor environmentalist. He performed the inspection and prepared a report. He observed mold at the property and collected both air samples and surface samples. The air and surface samples were then forwarded to LA Testing for laboratory analysis. After the lab results were completed, The Mold Guy then prepared a report of their findings and supplied an expanded fungal lab report from LA Testing explaining the test results from the samples taken from the property. These reports demonstrate that there is a significant indoor mold problem in the front house that requires remediation. The mold report confirms that the front bedroom had "very high mold spore counts of Aspergillus /Penicillium and traces of Chaetomium type molds." (Report at p. 16.) The kitchen has "very high mold spore counts of Aspergillus /Penicillium and traces of Chaetomium and Stachybotrys type molds." (Id. at p. 15.) The report confirms that pantry has "very high mold spore counts of Aspergillus /Penicillium." (Id.) The bathroom had "very high mold spore counts of Aspergillus /Penicillium." (Id.) The front bedroom closet had "very high mold spore counts of Aspergillus /Penicillium and traces of Chaetomium and Stachybotrys type molds." (Id. at 15 -16.) The mold report confirms a mold problem exists at a structure if the indoor mold tests show (1) higher mold counts than the outdoor levels, (2) mold spores that are present indoors but are absent outdoors, or (3) indoor mold that is toxic. In this case all three situations are present. The lab report numerically and graphically demonstrates the results of the mold tests and indicates the raw count for total fungi outside is 146. The indoor samples were significantly higher (a minimum of quadruple and in some cases even higher) than the outdoor levels. The test results also demonstrate that indoor samples include mold not present outdoors. The kitchen sample included both Stachybotrys and Torula mold spores. The mold report warns: "Inhalation of fungal spores, fragments (parts), or metabolites (e.g. mycotoxins and volatile organic compounds) from a wide variety of fungi may lead to or exacerbate immunologic (allergic) reactions, cause toxic effects, or cause infections." (Report at p. 17.) HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 20 The mold report goes on to warn: "Illnesses can result from both high levels with short -term exposure and low levels, with long -term exposures ... Whether symptoms develop in people exposed to fungi depends on the nature of the fungal materials (e.g. allergenic, toxic or infectious), the amount of exposure and the susceptibility of exposed persons." (!d.) The lab report warns: "It is generally accepted in the industry that indoor fungal growth is undesirable and inappropriate, necessitating removal or other appropriate remedial actions." (Lab Report, P. 16.) The lab report states that the mold Stachybotrys, which was detected in several locations, "may play a role in the development of sick building syndrome." (Lab Report, p. 21.) It further states, "The presence of this fungus can be significant." (ld.) Mr. Plaster's contractor has indicated that, at a minimum, the mold remediation work will involve significant work in the kitchen and bathroom, including the removal of all kitchen cabinets, the removal of all bathroom fixtures and removal of significant portions of the floor, ceilings and walls. The remediation work will also require the repair of all plaster in the kitchen, pantry, bathroom, closet and half the front bedroom, all new kitchen cabinets with new counter tops, new kitchen floor, new floor in the bathroom and new bathroom fixtures. Furthermore, the mold report recommends inspection inside the north wall of the bedroom /south wall of the bathroom during the abatement process. This is because it is likely the framing behind the plaster has mold growth as well. If that is the case, this framing will also need to be removed and replaced. H. Asbestos Is Also Present At The Property. The Plaster family retained Aardvark Property Hazard Analysis Company to inspect the front house for asbestos. Not surprisingly, this inspection detected asbestos in numerous areas, including the congregated insulation sheets throughout the attic, roof patching materials, vinyl flooring and in certain exhaust flue pipes. HARDING LAWORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 21 THESE HOUSES SHOULD NOT BE DESIGNATED AS LOCALLANDMARKS We acknowledge that based upon a superficial review, this property does have some curb appeal from a historic resource standpoint. The front house appears to be over 100 years old and is an example (although altered and deteriorated) of a turn -of- the- century cottage .3 But upon a more careful and thorough review and study, it is obvious that the front house lacks the integrity to be designated a landmark. In this regard: • The historic consultants retained by the property owner assert the front house does not merit landmark designation and PCR, the City's expert, concurs that the front structural fails to meet four of the six criteria set forth in the City's landmarks ordinance for designation. • PCR concludes that the front house may meet only two of the six criteria, both criteria of which relate to the structure being an example of a turn - of- the - century cottage. But PCR acknowledges that there are multiple better examples of this style of architecture in the nearby vicinity. • The front house is structurally unsound and dangerous. • The cost to renovate this structure are exorbitant. • Upon completion of the contemplated reconstruction, very few -- if any -- of the character - defining features would be original. Because of the deteriorated and unsafe and unsound condition of the property, these features would need to be reconstructed to mimic the original characteristics, which would result in a pretend version of a historic house. This approach to preservation is not recommended unless it is the last of its type, which is not the case. 3 Throughout this letter and the reports, the focus of study is upon the front house. This is because no consultant asserts that the garage structure or rear house should be designated. According to the report prepared by the City's consultant PCR dated July 27, 2010, the rear house "lacks sufficient significance and integrity for individual consideration as a City of Santa Monica landmark." (PCR Report at p. 5). HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 22 IM Designation. PCR acknowledges that the front house fails to meet four of the six criteria. PCR states as follows with regard to the front structure: The building lacks the sufficient aesthetic or artistic interest or value necessary for this designation. [Criterion 2] Historic background research did not reveal any information on the property's owners and /or occupants that indicates historic significance or notability. [Criterion 3] It is unknown who designed and /or built the residence located on the corner of Second Street and Mills. [Criterion 5] The experts hired by the Plaster family agree. B. There Are Much Better Examples Of Turn -Of- The - Century Cottages. PCR report concludes that the front house may merit designation under two criteria on the basis that it is a good example of a turn -of- the - century cottage. As noted .above, the experts retained by the property owner dispute this contention on the basis that the house has been altered and on the further basis that the extant character - defining features suffer from severe deterioration and would need to be replicated rather than preserved. This is the same basis for PCR to recommend against designation of the rear house. Furthermore, all experts agree that there are multiple examples of this style of architecture in the area and elsewhere in the City. At page 5 of their report, PCR lists a total of 17 other turn -of- the - century cottages in the near vicinity. In addition to those, Ms. Winder identifies four more examples, for a total of 21. Good historic preservation practice recommends against reconstructing historic structures when other similar examples also exist. (See National Register Bulletin #15, "How to Apply the National Register Criteria for Evaluation" (U.S. Dep't of the Interior, rev. 1995) p. 37.) HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright January 4, 2011 Page 23 C. Even If The City Were To Designate The Subject House, It Should Furthermore, even if this property is deemed to meet the criteria for designation (which our experts refute), we request that the pending demolition be allowed to proceed on the basis of the property's poor physical condition and dangers presented to public safety and health. part: Santa Monica Landmarks Ordinance Section 9.36.120(f) provides in pertinent Q "The [Landmarks] Commission shall have the power, after a public hearing, whether at the time it renders such decision to designate a Landmark or at any time thereafter, to specify the nature of any alteration, restoration, construction, removal, relocation or demolition of or to a Landmark or Landmark Parcel which may be performed without the prior issuance of a certificate of appropriateness." (Emphasis added.) Rear According to the report prepared by the City's consultant PCR dated July 27, 2010, the rear house "lacks sufficient significance and integrity for individual consideration as a City of Santa Monica landmark." (PCR Report at p. 5). The experts hired by the Plaster family concur with this assessment and, based on PCR's report, have not been asked to document their analysis of the rear house nor of the garages. Very truly yours, Kenneth L. Kutcher Enclosures cc: Steve Traeger (w/ encls.) Barry Rosenbaum (w/ encls Richard Plaster (w/ encls.) Brian Plaster (w/ encls.) 20251 /Cor /Albrig ht.1008. KLK HARDING LAPWORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW WRITER'S DIRECT DIAL 1250 SIXTH STREET, SUITE 200 WRITER'S E -MAIL ADDRESS (310) 451 -4138 SANTA MONICA. CALIFORNIA 90401 -1602 . TELEPHONE (310) 393 -1007 - FACSIMILE (310) 392 -3537 April 20, 2010 VIA MESSENGER DELIVERY Scott Albright Senior Planner Planning Department City of Santa Monica 1685 Main Street, Room 212 Santa Monica, CA 90401 Re: Demolition Application No. 10PCO303 Property Address: 2501 Second Street kozal @hlkklaw.com t,i Y O}' (ia;h:!h CITY 10 APR 20 P3'06 Expiration of 60 -Day Review Period: May 22, 2010 Our File No. 20251.001 Dear Mr. Albright: This letter follows -up on our recent telephone conversation in which I explained we would be submitting reports relating to the historical /architectural significance of the two units at 2501 Second Street, and their physical condition. Please forward this letter and the attached reports to the City's consultant who is reviewing this property to report to the Landmarks Commission at its May 10th hearing. Thank you for your assistance in this regard. A. The Structures Do Not Meet Any Of The Criteria For Landmark Designation Nor Do They Qualify As Contributors To The Third Street District. Enclosed is a report prepared by Mary Jo Winder of Architectural Preservation Planning Services evaluating the historical /architectural significance of the two units at 2501 Second Street. Also enclosed is a summary of Ms. Winder's professional credentials and background. Based on her inspection and analysis, Ms. Winder concludes that in her professional opinion, the buildings at the property do not merit landmark designation: "The [following] report concludes that the buildings on the property are not eligible for landmark designation because they fail to meet any of the six criteria in the Santa Monica Municipal Code." Ms. Winder examined each of the six criteria in reaching this opinion. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright April 20, 2010 Page 2 Furthermore, this property is not located within the Third Street Historic District, so it clearly does not qualify as a contributor to the District. Moreover, Ms. Winder concludes that even if a property outside the district were nonetheless considered as a potential contributor to a district, these particular buildings would not be contributors to the Third Street Neighborhood Historic District: "In this case there is no reason to consider this property as significant to the district." (Winder report at p. 4.) At the Landmark Commission's April 12, 2010 hearing, a member of the public spoke and claimed that the buildings are in generally original condition. However, Ms. Winder's report confirms that is not the case; many material alterations have occurred: "Major alterations include the infill of its recessed corner porch with fixed, multi -light windows and a newer front door with sidelights; removal of original front steps and replacement with non - original concrete steps with concrete cheek walls; and removal of the original fireplace box/chimney on the north elevation and replacement with a poorly designed brick chimney. Another major alteration is a large rear addition that includes a rear porch." (Id. at P. 1.) Ms. Winder also points out that there are other superior examples of turn- of -the- century massed plan vernacular bungalows in the area. Ms. Winder is in the process of documenting other such examples. We will provide this documentation to you shortly. B. The Structures On This Property Are In Poor Condition And Would Not Be Economically Feasible To Repair. At the Landmarks Commission's April 12, 2010 hearing, comments were made suggesting that the structures appear to be in good condition. But these statements were conjecture and are not consistent with the findings of multiple experts who have investigated the property. The experts who have performed detailed onsite inspections of the property, including the expert retained by the Santa Monica Rent Control Board, clearly refute the lay testimony and document that the structures are in extremely poor condition, as summarized below. Thus, even if the Commission determines there is some merit to the structures -- which we dispute -- the Commission should not proceed with a landmarks application because it simply is not economically feasible to repair the structures. This is confirmed by the Santa Monica Rent Control Board's decision to grant Removal Case No. 432R -C. Such decisions are difficult to obtain from the Rent Control Board because they result in the Board's loss of jurisdiction over the property. In order to obtain a Category C HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright April 20, 2010 Page 3 Removal Permit, the property owner must demonstrate the property is uninhabitable and cannot be made habitable in an economically feasible manner. (Rent Control Law Section 1805(t)(2)(i)). This determination has been made by an agency of the City and is binding upon the City. The evidence supporting this decision is overwhelming and uncontridicted. Enclosed with this letter are copies of the following: • June 30, 2009 report prepared by Simmonds Builders, an expert retained by the property owner. • An August 31, 2009 report prepared by ASAP Home Inspection Service, a company retained by the Santa Monica Rent Control Board. • A follow -up report prepared by ASAP Home Inspection Service dated September 22, 2009. • A letter dated October 8, 2009 from our firm to the Rent Control Board enclosing additional information about the deteriorated condition of the foundation of the front unit. • A letter dated November 24, 2009 from our firm to the Rent Control Board enclosing a mold inspection report dated November 9, 2009. • The Santa Monica Rent Control Board's Staff Report and Notice of Decision in Removal Case No. 432R -C. In reviewing the reports, please note the following: Both the owner's expert and the Board's expert agreed that the rear structure is not habitable and that it is not economically feasible to repair this structure. Among other things: ➢ The Board's expert stated with respect to the rear unit: "This unit is not sitting on foundation footings and excessive settlement is readily apparent. This unit also has a 95 sq. ft. lean -to bathroom addition of substandard construction with no apparent foundation and is in extensively deteriorated and unsafe condition." (August 31 ASAP Report at p. 1) HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright April 20, 2010 Page 4 ➢ The Board's expert concluded it is not economically feasible to repair this unit. In his conclusion the Board's expert stated: "The unit is unsafe and should be razed." (Id. at p. 4) ➢ The owner's expert concluded that "Because of the severely dilapidated condition of this structure, I do not believe it is possible to rehabilitate the unit." (June 30 Simmonds Report at p. 7) • Both the property owner's expert and the Board's expert agreed that the foundation in the front structure is significantly deteriorated and must be replaced. The Board's expert further stated that the unit is unsafe to occupy: "It is common knowledge that this type of foundation is a high seismic risk and has been recognized by the real estate and building industry as being unsafe for twenty or more years." (August 31 ASAP Report at p. 2.) • The Board's expert further stated: "Other repairs needed to bring the front unit to tenantable condition include removing the non - permitted, substandard, covered porch, installing a new foundation skirt wall to match house siding, a new furnace, relocating the water heater, new roof covering, plaster repair, painting inside and out, and miscellaneous repairs." (Id.) The experts have also expressed concern that the front structure could collapse when being raised to complete foundation work. Subsequent additional analysis of the foundation was also conducted, which showed that, due to soils conditions, even more extensive foundation work than initially anticipated would be required. Moreover, the property owner obtained a mold report because of concerns about moisture and possible mold in the units. The mold report confirms that there is a significant and potentially dangerous mold infestation at the property. Page 27 of the lab report indicates that the mold "Stachybotrys" is present and may produce toxins. As a result, extensive mold abatement work would be necessary, and given the scope of abatement needed, this would result in significant rebuilding of the kitchen, bathroom and plaster walls. In rendering its decision, the Santa Monica Rent Control Board reviewed all the data and reports and determined that the two structures are uninhabitable and cannot be economically rehabilitated to render them habitable. HARDING LARMORE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Scott Albright April 20, 2010 Page 5 C. Finally Even If The Landmarks Commission Were To Believe That The Structures Qualify For Landmark Designation, The Commission Should As Allowed By The Landmarks Ordinance, Concurrently Approve Immediate Demolition Due To Their Poor Condition. The Commission has the authority to approve demolition simultaneously with designation of a structure. Landmarks Ordinance Section 9.36.120(f) states in relevant part: "The Commission shall have the power, after a public hearing, whether at the time it renders such decision to designate a Landmark or at any time thereafter, to specify the nature of any alteration, restoration, construction, removal, relocation or demolition of or to a Landmark or Landmark Parcel which may be performed without the prior issuance of a certificate of appropriateness pursuant to this Chapter." (Emphasis added). There is precedent for this approach. We believe that the City took this approach with the property at 1127 Sixth Street. Therefore, even if the Commission ultimately decides these structures have historical significance, given their extremely poor condition, the Board should simultaneously authorize demolition. The failure to allow demolition of structures that cannot be economically rehabilitated (as already determined by another City agency) would result in a denial of all economic use of the property and arguably constitute an unconstitutional taking of the property. Please call me if you have any questions regardin this letter or the enclosed documents. /� a KVK:ojb Enclosures cc: Steve Traeger (w/ encls.) Barry Rosenbaum (w/ encls.) 20251 /Cor /AI bright.1001. KV K HISTORIC /ARCHITECTURAL EVALUATION FOR 2501 SECOND STREET, SANTA MONICA, CALIFORNIA Introduction This report presents an evaluation of the historical /architectural significance of two residential buildings and a garage at 2501 Second Street, Santa Monica, California. The report concludes that the buildings on the property are not eligible for landmark designation because they fail to meet any of the six criteria in the Santa Monica Municipal Code. The methodology employed in this evaluation is in accordance with professional standards of the National Park Service, National Register of Historic Places, the California Register of Historical Places and Chapter 9.36 of Article 9 of the City of Santa Monica Municipal Code. Background The property has been included in previous historic resources surveys; most recently, an updated inventory form (completed by Historic Resources Group in 2003) identified the residential building at the front of the lot and the rear residential unit (238 Mills St.) as potential contributors to the Third Street Landmark District (5D2); however, no amendment to the district has been completed to include the property. A garage on the rear of the property is not identified in any of the previous surveys and is not a contributor. The property is not located within the boundaries of the Third Street District. As such it cannot currently be considered a contributor, regardless of its condition. Description All the buildings on the 50 -by -130 foot lot at 2501 Second Street are one - story, wood - frame structures. The house on the front of the lot possesses characteristics of a tam -of- the- century massed plan vernacular bungalow. It has an irregular plan, hipped roof with shaped exposed rafters, wood siding (horizontal clapboard below window sills and wood shingles above), wide double hung windows with diamond -paned upper sashes, and a projecting slant -sided front bay. Major alterations include the infill of its recessed corner porch with fixed, multi -light windows and a newer front door with sidelights; removal of original front steps and replacement with non - original concrete steps with concrete cheek walls; and removal of the original fireplace box /chimney on the north elevation and replacement with a poorly designed brick chimney. Another major alteration is a large rear addition that includes a rear porch. Although the addition was likely constructed early in the building's history, there is no building permit to document its construction. A second residential unit at the rear of the property (a.k.a. 238 Mills) is an unremarkable one - story, irregular -plan structure with a hipped roof and board and batten siding. It has double -hung windows and a recessed corner porch with simple wood supports and enclosed vertical wood -slat rail. A second porch on the south elevation has a shed roof that is supported by a plain wood post. The detached double garage is sited between the two residential buildings accessed at the north elevation by a wide, concrete driveway. It has a flat roof, stucco cladding and four wood - paneled doors. History of Property City of Santa Monica building permit files give minimal documentation of the development of 2501 Second Street. The only major construction is documented in a 1927 permit for a garage. Sanborn maps, however, document that both of the residential buildings on the lot were constructed between 1902 and 1909. In 1902, the lot, at the corner of what was then called Lake (Second) and Surf (Mills) was shown as vacant. The 1909 Sanborn map shows the front house with its corner porch and what appears to be a rear addition. The smaller rear house (labeled 236 Mill (sic)) was also depicted with a corner porch. The 1918 Sanborn map shows that a room had been added to the south elevation of the rear house. The garage that was permitted in 1927 appears on the 1918- 1950 Sanborn map. The history of the occupancy of the property is found in Santa Monica City Directories. The first occupant is listed in the 1913 -14 directory as A.M. Curtis. In 1915 -16 J. H. Sams was occupant. There is no indication of occupancy in the 1917 and 1918 directory, but in 1919 -20 the property is listed as 2501 Washington Boulevard with Elliot W. Yates, an electrician, in residence. In 1923 -24, Mrs. Christina Hansen and J. A. Lynch were residents, in. 1927, E.H. Swift and Mrs. E. B. Swift occupied the front house. The J. S. Hunter Trust is documented as owner of the property on the 1927 garage permit. From the early 1930s to the early 60s, 2501 Second Street (still known as Washington Boulevard) was the residence of Thomas Estes. Evaluation of Significance The following comments are the result of my professional evaluation of the buildings at 2501 Second Street according to the criteria for landmark designation in the Santa Monica Municipal Code. Criterion 1. It exemplifies, symbolizes, or manifests elements of the cultural, social, economic, political or architectural history of the City. Although the house on the front of the lot has more character- defining features of residential vernacular architecture of the turn of the century as compared to the rear house, it is still a very modest example of a building type and style (massed plan bungalow) that represents that period in the history of Santa Monica. Other massed plan bungalows in the Third Street Landmark District and the Ocean Park neighborhood are more architecturally intact than this house and, therefore, they better symbolize turn of the century residences in Ocean Park. The 1927 garage is a utilitarian structure that is not architecturally significant. The property is not eligible under criterion 1 because none of the buildings are individually exemplary examples of a style or period. Criterion 2. It has aesthetic or artistic interest or value, or other noteworthy interest or value. The buildings are all vernacular examples of turn-of -the- century and early twentieth - century residential development and there are no elements that are aesthetically or artistically noteworthy. The property is ineligible for designation as a landmark under this criterion. Criterion 3. It is identified with historic personages or with important events in local, state or national history. Archival research of building permits and City directories did not reveal any significant person associated with 2501 Second Street. It appears that it was a rental property during the first three decades of its history. The resident with the longest association with the property (and probably an owner /resident) was Thomas Estes, an electrician, who lived at the address for at least thirty years. The property is not eligible for designation as a landmark under this criterion. Criterion 4. It embodies distinguishing architectural characteristics valuable to a study of a period, style, method of construction, or the use of indigenous materials or craftsmanship, or is a unique or rare example of an architectural design, detail or historical type valuable to such a study. The massed plan bungalow style of the front house is a common residential property type constructed in Santa Monica, California and across the U.S. between 1890 and 1910. The only features of the house that contribute to it being anything other than a modest example of the style and period are what appears to be hand - crafted rafter ends under the eaves and diamond - pattern upper sashes in most of its windows. These features, however, are not unique, as they are commonly found on numerous other turn- of -the- century residential structures in the City. The rear house and garage have vernacular features and no indication of craftsmanship, use of indigenous materials or unique method of construction. None of the buildings on the property at 2501 Second Street are valuable examples that would contribute to a study of the history of residential architecture in Santa Monica. The property clearly does not meet requirements for designation under this criterion. Criterion 5. It is a significant or a representative example of the work or product of a notable builder, designer or architect. A building permit of original construction of the two residential structures is unavailable; therefore, the architect /designer or builder is unlrnown. The contractor listed on the garage is not known to be significant. The property does not meet requirements of this landmark criterion. Criterion 6. It has a unique location, a singular physical characteristic, or is all established and familiar visual feature of a neighborhood, community or the City. None of the buildings at 2501 Second Street have unique characteristics. Their location on the corner of Second Street and Mills does not render the property unique or a standout within the neighborhood. Therefore, neither the group of buildings nor any of them individually qualify as landmarks under this criterion. Evaluation as a Contributor to the Third Street District Although a previous evaluation concluded that the property at 2501 Second Street is eligible for inclusion in the existing Third Street Historic District, I believe that both the houses on the property lack sufficient architectural integrity to qualify as contributing buildings. There is no justification under City of Santa Monica criteria for expanding the district boundaries to include a property such as this one, which possesses marginal architectural integrity. Clearly, a property not within an existing district's boundaries cannot be deemed a contributor to that district. In this case there is no reason to consider this property as significant to the district. Conclusion Although the residential buildings at 2501 Second Street are listed as contributing buildings to the Third Street Landmark District, neither of them qualifies as individually significant representative examples of architecture or architectural development in the City of Santa Monica. There is no known significant association with a person, group or event that are noted for any measurable contribution to the history of Santa Monica, or the history of the state or nation. In my professional opinion, based on the analysis set forth above, the property clearly does not meet any of the criteria in the Municipal Code for designation as an individual landmark. Report Prepared By: Date: April 19, 2010 Mary Jo Winder Architectural Preservation Planning Services rd License Number: 519687 Jerry Schmitz Simmonds Builders 7916 Woodley Ave. Van Nuys, CA 91406 June 30, 2009 Kevin V. Kozal Hardin Larmore Mullen Jakle Kutcher & Kozal, LLP 1250 6` Street; Suite 300 Santa Monica, CA 90401 Re: Removal Permit Application 2501 2°d Street Santa Monica, CA Dear Mr. Kozal: I have inspected and photographed the property at 25012 nd Street in Santa Monica. All three structures on the property are currently unsafe and uninhabitable. The purpose of this report is to assess the potential costs required to return the property to a safe and livable condition. Due to the scale of the project and the inefficiency inherent in smaller construction projects, all costs of work referenced in this report assumes all three structures would be repaired or replaced at the same time. Repairs suggested in this report are made with regards to Santa Monica Municipal Code 8.84.040 which states in part as follows: Alterations, repairs or rehabilitation to an existing building may be of the same type of construction as the existing building or structure, provided the aggregate value of such work in any one year does not exceed ten percent of the replacement cost of the building, and provided further, that no hazardous conditions or substandard residential buildings are continued or created. These provisions shall be retroactive when specifically required by this Code. Alterations, repairs or rehabilitation in excess of ten percent of the replacement cost of the building or structure may be made provided all of the work conforms to this Code for a new building of like area, height and occupancy in the same location and that no hazardous conditions or substandard residential buildings are continued or created in the remainder of the building as a- result of such work. Mary Jo Winder . 1609 Fair Oaks Avenue #2 South Pasadena, CA 91030 626- 403 -0088 or 626- 664 -9464 EDUCATION Master of Architecture (Historic Preservation), Kansas State University (1984). B.A., Art History, University of Alabama in Huntsville (1982). Supplemental Training Introduction to Federal Projects and Historic Preservation Law, Advisory Council on Historic Preservation, (1984). Advanced Seminar on Preparing Agreement Documents Under Section 106 of the National Historic Preservation Act, University of Nevada (1991). PROFESSIONAL EXPERIENCE 2002 to present: Principal, Architectural Preservation Planning Services. Consultant for historic preservation in land -use planning and development. 1990 to 2006: Senior Planner, Design & Historic Preservation Section, Planning Division, City of Pasadena. Staff to Historic Preservation Commission (staff reports, meeting presentations); coordinator for Certified Local Government Program (grant writing, supervision of grant projects including historic resources surveys, historic contexts, National Register nominations, ordinance revision, preservation plan); administration of Section 106 review process; coordination and supervision of city -wide reconnaissance survey, city -wide historic context report, ethnic history study, preservation plan, ordinance revisions, and preservation element in Land -Use Element of General Plan; management of preparation of Design Guidelines for Historic Districts in the City of Pasadena; administration of design review of projects affecting historic resources; preparation of California Environmental Quality Act documents; preparation of educational brochures/ informational materials; presentations to neighborhood groups. 1989 to 1990: Preservation Planner, Metropolitan Area Planning Department, City of Wichita. Staff to Wichita Historic Preservation Board; administration of design review of landmarks and landmark districts; administration of Section 106; administration of Certified Local Government program (grant writing, coordination and supervision of grant projects); preparation of City preservation plan; revision of preservation ordinance; administration of designation and revolving loan programs; presentations to neighborhood and business groups. 1983 to 1988: Preservation Consultant, Cities of Leavenworth, KS, Kansas City, MO, St. Joseph, MO, and private property owners. Preparation of historic resources surveys, National Register nominations, historic contexts, Certified Local Government grant applications, public education materials, brochure for marketing historic properties, certifications for Tax Act projects; consultation on rehabilitation projects. 25012 nd Street June 30, 2009 Page 3 The walkways and driveway (Pic 07) are original and are in a state of crumbling. The front step has settled into the front yard causing it to pull away from the house and slope the stair treads in an unsafe manner. The .exterior siding (Pic ®S) consists of half painted wood shingles and half wood lap siding which are both in deteriorated condition and rotted in several areas. This siding system would allow for substantial moisture and air infiltration. The windows (Pic 09) are 50% fixed and 50% double hung. They are quite old and outdated lacking proper weather stripping. Most are non - functioning due to being painted closed. Several show significant signs of water damage and rot. The windows which were originally intended to open should either be restored or replaced to facilitate egress in case of fire. The chimney for the living room fireplace (Pic 10) has collapsed at the roofline and has been capped. It will need to be demolished down to the smoke shelf and rebuilt per code. The roof on this structure (Pic 11) consists of one layer of composite shingles installed over an older cedar shingle roof. The eves are approximately 3 feet deep and consist of exposed rafter tails with T &G sheeting. There is substantial evidence of water penetration (Pic 12) through the roofing having stained, buckled and rotted the eve sheeting. The structural members of the roof show evidence of substantial sagging giving the roof a "swaybacked" appearance. The roof on this structure would need to be removed and framing members replaced or supported with proper elywood sheeting installed in order to meet current code requirements. Interior: The interior of the home is generally in a dilapidated condition. The interior walls consist of plaster on wood lath construction. The plastef has failed throughout the home as evidenced by significant.cracking and the delaminating (Pic 13) of the plaster from the lath. The extent of the damage makes repair inadequate and insufficient. Therefore, the removal and replacement of all plaster with drywall is required. The wall between the front bedroom and bathroom has sunk, along with the floor, due to long term water exposure from the shower area and termite damage. Visible termite damage in the hardwood floors indicates the extent to which termite infiltration has penetrated from below compromising the structural integrity of the framing members beneath. The flooring consists of hardwood floors which have been sanded past their limits causing splintering and preventing further refinishing. Areas of the flooring sink 25012 n1 Street June 30, 2009 Page 5 is in this advanced "state of disrepair. Once repair costs exceed 50% of replacement value requiring the entire home to be brought up to current code, it is actually more expensive to restore rather than replace with new construction. We believe it would not be prudent to attempt to repair this home. Not only is it unsafe to inhabit but it is also unsafe to work on.. Due to the extensive structural damage and the need to replace the footings, there is a significant possibility that the home would simply collapse under its own weight while attempting to lift it off of the existing footings. The structure itself creates a worksite hazard. It is far more economical, efficient and safe to remove the entire structure and rebuild it from the ground up. Below is a list of costs associated with the repair work referenced above. It Should be expected that upon start of work additional hidden damage will be detected and the costs will increase beyond these estimates. 1. Demolition of plaster, floors, and finishes $ 9,675 2. Lift home off foundation and construct temporary shoring $23,220 3. Excavate and replace foundation $27,090 4. Remove and restore fireplace chimney $10,965 5. Remove and replace buckled concrete walks and driveway $7,095 6. Repair and replace cripple wall structure $8,385 7. Repair and replace siding $15,125 8. Repair damaged and undersized framing $9,385 9. Finish carpentry, baseboard, casing & picture rail $9,804 10. Kitchen & dining room cabinetry $9,675 11. Insulation to meet Title 24 requirements $5,805 12. Bathroom & kitchen plumbing fixtures $5,805 13. Replace rough plumbing & water heater $7,998 14. Gas lines for FAU, relocate water heater & stove $2,322 15. Replace eve T &G and rafter tails as needed $7,224 16. Re -sheet and replace roofing with composition shingle $18,060 17. Gutters and downspouts $2,838 18. Wood doors and windows $10,062 19. Gypsum wallboard $21,285 20. Ceramic file & installation $5,418 21. Linoleum in kitchen and bath $1,935 22. Replace wood flooring $16,700 23. Prep and exterior paint $12,255 24. Interior paint $10,062 25. Replace forced air unit (heat only) $5,805 26. Electrical expanded and brought up to code $11,223 Subtotal: $275,286 Contractor fee and general conditions - 15 %: $41.292 Total: $316,578 25012 nd Street June 30, 2009 Page 7 The interior of the home is generally in a dilapidated condition. There is a severe flea infestation and substantial evidence of rodent or possum inhabitants. The flooring consists of hardwood floors which have been sanded past their limits causing splintering and preventing further refinishing. The floors are noticeably out of level indicating foundation and/or structural problems below. The electrical service to the home has been updated at the panel. However, service inside the home has not been extended to include adequate lighting or receptacles. Where the electrical system has been extended, such as to the rear yard, (Pic 29) it was not done to code and creates an unsafe condition. The plumbing system consists of galvanized pipe which has been installed on the . outside of the home (Pic 30) and is in a dilapidated condition. Conclusion: The rear studio guest unit would cost approximately $175,000 to build new today using typical Type V construction techniques. Because of the severely dilapidated condition of this structure, I do not believe it is possible to rehabilitate the unit. Following removal of rotted and termite destroyed portions of the structure there simply would not be enough of the unit remaining to allow restoration. Therefore, I would estimate the repair cost to exceed 100% of the replacement cost making the owner unable to legally repair the building per Santa Monica Municipal Code 8.84.040 as follows: Whenever an existing building or structure has been damaged, or is in need of repairs, or the owner desires to make repairs, alterations or rehabilitation in an amount exceeding fifty percent of the replacement cost of the building or structure, the entire building or structure shall be made to conform to all of the requirements of the Technical Codes or shall be demolished. Unit #3: Garage The garage (Pic 31) consists of a wood framed structure consisting of two divided parking stalls. The doors on the unit are water damaged, warped and sagging: The garage has a stucco exterior which appears to be in relatively good condition. This is a flat roofed structure which drains to the rear. The underside of the roof is visible from the southern stall of the garage. (Pic 32) There is evidence of historic water infiltration. The support structure of the roof is undersized by modem standards and is sagging. The cave at the rear of the unit (Pic 33) shows signs of severe water damage. This roof structure would require reinforcement and repair followed by the installation of a new water proof membrane. Conclusion: The garage would cost approximately $25,000 to build new today using typical Type V construction techniques. Repair costs would exceed 68% of the replacement cost making the owner unable to legally repair the building without d city 0' 5m,'Dabk PrrDrs_0cc° Rend Conero9 Board 1635 Main S'lice'd PO Pox 22911 sayltjl Monica, €'aii�or:74y994.97 - ?2a19 ' weplernber 2, 2009 +IG;rQIi-F ��{, ,_at n-. n �r�.iUL.IVu j'siI,e h= U'iGFlc'Y-al ;OX.aatn 1250 v" ,1 'Eireet, Suite 300 °Sania Monica, CA 90401 e. Rernoval Permil Applicadon A32g -0 Plaster i arn& l rush -2501 ?nd �.i1.� .i Dee.( Kevin: \t ached i$ a copy oS the f1 AP 6'lorne Inspection Service revnr prepared. tcrr the 3oard in the above mailer. ,s -�?dvised, the mailer is still ientatively scheduled 'ko be considered by the Board at irs October 8, ?009 rneeiing. l�lo'i9ce of consideradon and the sia,I-I repoft will be mailed ai: least ten days prior io the date of consldera ion. if you (lave any quesiicins concerning the above, ? can be reached ai (310} 4113 -87W. /Uiachrnenis Sincerely, i) Keith J. i resgl- Staff Attorney cc: =:32 R -lam File 2CL 310 :!59 -13751 ASAP Horne Inspection. Service 310 399 -11999 WVjW.as_pinspectia".a,corn August 31, 2009 Keith Kresge City of Santa Monica Rent Control Board 1685 fain Street Santa Monica, CA 90407-2200 RE: Removal Permit Application 4328 -C 2501 2nd Street, Santa Monica, CA 90405 Plaster Family Trust, Applicant Dear Mr. Kresge, i L your request 1 inspected the above property on July 30`t' and August 5"' 2009, to document the curaent condition of the subject structures and gather data to estimate the cost to restore the units to tenantable condition, DESCW T ION There are two units and a detached two -car garage on the corner lot property. According to the County Assessor records there are two units with three bedrooms and one bathroom totaling 1573 sq. -ft. built in 1895. The front unit is a two bedroom, one bath, single story, single family house of approximately 1,040 sq. IL. that sits on an unreinforced red brick masonry foundation with deteriorated mortar ioints. dither than the foundation,, the house is in fairly-good condition for its age with the exception of the bathroom, which has structural water damage, but is repairable. The rear unit is an approximately 514 sq. ft. studio unit with a small kitchen. This unit is not sitting on foundation footings and excessive settlement is readily apparent. This unit also has a 95 sq. ft. lean -to bathroom addition of substandard construction with no apparent foundation and is in extensively deteriorated and unsafe condition. 2 219 G i ant /en ❑9, R, dundo Be. 9 c h, ^ R 90278 August 31, 2009 Removal Permit Application 432R -C METHODOLOGY I visually inspected the readily accessible portions of the structures and their systems and components and took photographs and measurements to estimate the cost to -restore the structures to tenantable condition. I took measurements and estimated time and materials based on my experience and utilizing two man crew of various skill levels to do some of the work. 1 used specialty contractors where appropriate and cost effective, including foundation replacement, roof covering, razing the rear unit, and painting. For correlation I compared any estimated costs with the 2009 National Estimator Cost Spooks. My estimate is to restore the structures to tenantable condition as per last occupancy. No aesthetic improvements or updating are included. SCOPE E flip' WOW4_ At the front unit the main issue that makes this unit not tenantable is its deteriorated, unreiuforced reel brick masonry foundation, which is unsafe. The foundation is not adequate for supporting the structure either by today's standards or from general age related deterioration. The foundation cannot be repaired and will need to, be. replaced. Cost to replace the foundation will exceed 10% of the replacement cost of the structure and therefore must be done to current Technical Codes, which will include upgrading the interior pier and post floor supports and girders. It is common knowledge that this type of foundation is a high seismic risk and has been recognized by the real estate and building industry as being unsafe £or twenty or more years. It should have been replaced years ago due to the deteriorated mortar and general condition. The cost estimate to install a new.foundation and floor support system would be $43,115. Structural water related damage (wood rot) at the bathroom noted earlier, in my opinion began shortly after improperly converting the bathtub for use as a shower without adequate waterproofing. Based on method and materials used I estimate this was likely to have been done maybe 40 -50 years ago with subsequent improper repairs. I believe this condition was apparent to the occupants for years and proper repairs were deferred allowing the deterioration to worsen. This damage is repairable however, and it should be noted that when the foundation is replaced, most of the structural damage at the bathroom and surrounding area will be corrected as part of the foundation replacement package. Other repairs needed to bring the front unit to tenantable condition include removing the non - permitted, substandard, covered porch, installing a new foundation skirt wall to match house siding, a new furnace, relocating the water heater, new roof covering, piaster repair, painting inside and out, and miscellaneous repairs. There was no evidence that the plumbing drain and waste pipes were not in working order nor that the electrical system was significantly damaged or unsafe; no cost to replace either was included in my estimate. August 31, 2009 Removal Permit Application 432R -C The interior of the house was not in severely deteriorated condition (see attached photos) and the house can be restored to tenantable condition with general repairs and painting at an estimated cost of $58,352. I estimate the cost to repair and re -roof the garage and paint the exterior at $3,100, which is not included in the $58,352 above. No Io estimate is given for restoring tl?e mv'a -r Thli t. The stra�cture ca��not be repaired due to the cost of repairs exceeding 50% of the building's replaccarent cost, thus requiring it to comply with current 1 eelmical Codes, which is not possible. Replacing the foundation and related repairs and needed improvements to restore the structural integrity io the unit, including removing the substandard non - permitted bathroom, would cost $72,000, which exceeds 50% of the $120,800 unit replacement cost and should be demolished. The non - permitted bathroom cannot be replaced as per current Technical Codes. Since the unit does not have a bathroom it would not be tenantable. ADDITIONAL INFORMATION I reviewed an inspection report and estimate of repairs from Simmonds Builders dated June 30, 2009, furnished by Applicant. This detailed report is a fair assessment of the property condition as I found it during my inspection. Plovvever, this estimate includes repairs and improvements that are not necessary to bring the structures to, tenantable condition as pel California. Civil Code Section 1941.1, and 1 have excluded those items in in estimate. Simmonds Builders estimates the cost to replace the structures at $350,000 for the front house and $175,000 for the rear studio. I estimate the cost to replace the front house to be $244,300 and the rear studio unit to be $120,800. Simmonds Builders estimates "the potential cost required to return the property to a safe and livable condition" to be $316,578, and further concludes "repair costs would exceed 90% of the replacement cost making the owner unable to repair the building to comply with Santa Monica Municipal Code 8.84.040 ". Simmonds Builders estimate includes repairs and improvements that are desirable but not necessary to bring the front unit to tenantable condition as per California Civil Code Section 1941.1. 'These inclusions add significantly to Simmonds Builders cost estimate. It should be noted that there is deferred maintenance in kitchen and bathroom of the front unit and at the detached garages. My estimated cost to restore the house to its last tenantable state and replace the foundation, including garage roof repair, re- roofing and painting is $104,567. August 31, 2009 Removal Permit Application 432R -C CONCLUSION The front unit (house) can be restored to tenantable condition for an estimated cost of $104,567. The rear unit (studio) cannot be restored for reasons stated; the foremost is the cost to repair will require compliance with current Technical Codes, which would not allow the unit to be restored. The unit is lmsafe and should be razed. Cost to raze this structure would be $3,900. Very truly yours, . �� rr_ Duane McCutcheon General Building Contractor #272224 ICC Combination Dwelling Inspector #5130345 -56 Enclosures: Photos, 11 pages 2501 ? "a Sired., S @ni.c) Monic.a Froi -A unii, north (; vVest, olevlzions West elevation vlfasi writ and Couch elevebom 2501 21,11 Street, Santa Monica Front unit, South and east elevations. Mon - ermitied parch addition. East elevation, south portion East elegy e)Uen, novii7 porlioll NCIldh elevation 2501 ?"a Street Santa Vvlonica d'osandaHon grouit detariorciiion mead bF!cl( Co unciation UNiring has been u,pc3eo-:ad ( deer covered porch ineeeicov 2501 2"d S'ffeot, &anta Monica Parch anclosure Kitchen ire serviceaWe, E.; bineet rep — vable Patch neeclad under sink 250121111 Street, Santa Monica 6-anbs f is in rair c®n�dMon, no�r13 vinyl carc.souay U9idh are isa c3oacl coeaditi ®ss uidl -in h xh is in fair condi 'On U1.As and ceilings are in overall good d wncdidon 2501 2nd Sar _at, SaiBia Mon a;a Living room Dining roorra beyond bask bedroorra _ °e i�S =air�� rra `S 25012110 Skree�, Santa Monica Vljesi beclenoo n, south wall °s ss� bedroom, vves,. viciIl Wesk bedroom, nowh w ll rAasia, cl acra��u,�ri \r�pese W��ehondro, o�s'd vr�6@ 25012-1 Street, Santa Monica G ,0 2501 na &6.reet, Sant Monica L-Vaio-y dnk Is sebvlceable Tollee Is serviceable 4aar °ae�es 's Vc:,@V r.rral4, 4lq -Xlh ele -va on Fear° Lill, i, s�ordl and svesd elev adore 2501 211[1 Sheet, Santa Monica Rear unit, west elev ation !illes elevation S ea¢i� e9euaPo ara (rac��i p�rrr itC�c1 f�acFaraa sea ) Typical e,terbr uual& setilemerat 2501 211 Skreet, Saint& Monica Baihrioom (nose ieogr & Ptch�sa WRITER'S DIRECT DIAL (31 o) 'Pi -I en .1 &-I HA RD 1 ill G LA U a 11.,3 � li � M . L n� JJ C -3HE P. S> Iii O ZZA !I , L !L P ATTORNEYS AT LAVA! 1250 SIXTH STREET, SUITE 300 S.AHTA MOHIC.A. CALIFORNIA. 90101-1602 TELEPHONE (310) 393 -1007 FACSIMILE (3 10) d5� -1959 VIP', MESSENGER DELIVERY Keith "Kresge Staff Attorney Santa Monica Rent Control Bogard WRITER'S E -MAIL ADDRESS e 4➢�a tli{ FJ`1 ,y2;d `u �,., p., e e "'' i Saint@ Monica, CA 90401-32295 Ede: Propep.yAddress: ` 501 Sic and atrest, S arat a Monica n a'te r?f C Removal Parmi't ;'gyp, alication ?32 R -C- Our File plod 202519 001 Dear Mr. Kresge: Thank you' for' forwarding to me Duane lVdi;Cratoho on's, September 22, 2009 le'.ier. that was prepared in response 's0 our rer. uesis for frsrihc,r information as se -t fourth in racy Sep'tea fiber 16, 2009 letter to you. �N T RODUC T I om I understand that you will be leaving for vacation at the end of- this w8ek, I do nat anticipate a response to this letter before you leave for vacation. However, I respectfully request that you forward as copy of this letter tai Duane MCCLs'toheon 80 he can consider the points raised herein while you are On vacation. T hia, letter also provides a'tirrae extension. We question soma of Mr, €v1cCulchfeoua reparia° E stirraa'tes and also= request that lie reconsider sortie of the expenses identified by the property owner's e,(pert, Sirtlnraondd Builders. However, overall ws are nO't gMSd'lUling or CdiSpriting Mr. k1cCua'eoheon's expertise or oredan dals. But we hefeve shat lrtr_ iUcCua r -heoai may have foa -i2sd on shoric=terni minimal repairs with low estimates instead of the more comprehensive repairs that are likely needed as a praaotaeaal reality. We ass r's'tha,'t ihere pare eve -val reason,,a why ivIr. iUIcCutdhec n sh,,ould incraas ;Ii's repair as-drnao(9, EvrCm a o h[3ht, Osi incia'EC t.i,lll, tl9_Bng 6 -,3 MFf HARDING LARMORE MULLEN JAKLE KUTCHER 8z, I OZAL, LLP ATTORNEYS AT LAW Keith Kresge October 8, 2009 Page 2 McCutcheon's estimate and analysis, support demolition and replacement of the front house. As a practical matter, it is unlikely that a rational property owner would only engage in cosmetic repairs to the front house. The more reasonable and practical option is to demolish and rebuild, or at a minimum to engage in signi'fican't remodeling and upgrade work. The Board's Category C analysis should reflect this real world situation. TIME EXTENSION This letter confirms that the property owner grants an extension of time for the Board to render a decision on the above - referenced pending Category "C" Removal Permit Application through and including December 31, 2009 DISCUSSION A. Fifty Percent 50 %) Standard Even using Mr. McCutcheon's current cost estimates, he is very close to the 50% threshold. This threshold supports replacement of the entire front house, similar to what Mr. McCutcheon recommends for the rear structure. Mr. MCCUtcheon confirms that if the repair cost exceeds 50% of the replacement value of a structure, then the s'truc'ture should be demolished and replaced. Mr. McCutcheon estimates that the total cost to replace the front house is $244,300. Therefore if the repair costs exceed $122,150 (i.e. 50% of the replacement cost), then demolition is warranted. Mr. McCutcheon estimates the cost to repair the front house at $104,567. This is less than $15,000 below the 50% cut -off figure. - Given the age of this structure (which may be nearing 100 years old), we believe it is reasonable to assume that during repairs additional unforeseen problems and defects will be discovered that will cause additional repair costs. For example, given the age of this structure it is most likely the case that there is termite damage that is not visible. Furthermore, Michael Foionis, Mr. Plaster's architect, believes there is extensive water and mold damage in the bathroom and kitchen, the full extent of which will not be known until some exploratory demolition work is completed. These and other unknown factors very easily could increase Mr. McCutcheon's repair estimate by more -than $15,000. HARDING LARMORE MULLEN JAKLE KUTCHER &z KOZAL, LLl ATTORNEYS AT LAW Keith Kresge October 8, 2009 Page 3 We believe that there is precedent 'for the Board to consider the repair costs of the property as d whole, not lust on a structure by structure basis. Mr. McCutcheon estimates the replacement value of the rear structure to be $120,600. When added to the replacement cost of the front house the 50% threshold for the entire property is $142,550 (i.e., $244,300 plus $120,600 = $365,100, divided by 2 = $1 52,550). Mr. McCutcheon estimates the repair cost of the rear structure to be $72,000. When added to his repair estimate of the front house ($104,5567) the sum of $176,567 is less than $6,000 (which is less than 4% of the total repair estimate) from the 50% threshold for the entire property. Under these circumstances with such a razor thin margin it is fair to anticipate actual costs incurred during construction would easily exceed the 50% threshold. B. Foundation Reaair Both Mr. McCutcheon and Simmonds Builders confirm that extensive foundation repair work is necessary. Originally, Simmonds Builders estimated the foundation repair cost at $50,310. Mr. McCutcheon estimated the repair cost at $43,115, without a contingency, overhead or profit percentages. After the initial inspection, Jerry Schmitz of Simmonds Builders reinspected the property and analyzed the foundation more carefully. Attached are two photographs that Mr. Schmitz recently took of the crawl space under the front house at the property. These photographs show evidence of significant termite damage. In fact, Mr. Schmitz points out that the center floor beam has completely failed. Mr. Schmitz obtained a bid from his concrete contractor, ® &® Construction Specialties, Inc., for replacement of the foundation. A copy of this bid is attached. This bid estimates the total foundation cost at $75,900. Mr. Schmitz has explained to me that due to the sandy nature of the soil in this area of this City, and the need to support the house, the work would have to be done in a section -by- section basis. This adds to the overall cost. Also due to the sandy soil, a soils report and structural engineer's report will be required. It is likely a foundation of a greater depth (possibly up to 5 feet) and greater width will be required to securely. support the home. All of this will increase the foundation cost. In Mr. McCutcheon's September 22nd letter, he outlines his repair cost 'for the front house, foundation and garages. For the front house and garages, Mr. McCutcheon includes an overhead percentage, a contingency percentage and a profit percentage. However, these are not set forth in his estimate for the foundation at $43,115. If these are included, his estimate could increase by approximately $15,000 and bring his total estimate to nearly $60,000. This factor alone is enough to push Mr. McCutcheon's repair estimate above the 50% threshold. HARDING LARMORE MULLEN JAKLE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Keith Kresge October 8, 2009 Page 4 C. Items Missing Or Which May Be Under- Estimated In Mr. McCutcheon's Estimate In his September 22nd letter, Mr. McCutcheon lists the 26 repair categories estimated by Simmonds Builders and provides responses to some of these. There are twelve categories Mr. McCutcheon does not comment upon. The cost of these 12 items total $149,937, without a contractor tee or general conditions. We appreciate that this may not necessarily mean that Mr. McCutcheon does not question any of these numbers. But if he is not questioning these figures, then Simmonds Builders repair estimate on items Mr. McCutcheon does not dispute exceeds 50% of Mr. McCutcheon's estimated cost to replace the front house. But even it Mr. McCutcheon disputes Simmonds Builders' estimate there are items that may be missing or underestimated in Mr. McCutcheon's estimate. 1. Termite Damage The enclosed photographs taken by Mr. Schmitz demonstrate evidence of significant termite damage. Mr. Schmitz believes this has caused certain structural failure of the home as evidence throughout by failed plaster and settling of the roof structure. He believes given this it would necessarily be the case that additional damage inside the wall cavities of the home will be discovered. In his repair estimate as set forth in his September 22nd letter, Mr. MCCutcheon confirms that his structural pest control figure is an "estimated allowance, deter to pest control." Given this acknowledgement, we believe it is reasonable to assume that the repair cost related to termite damage could increase significantly. 2. Wood Flooring Mr. McCutcheon states that the wood flooring is in a serviceable condition. However Mr. Schmitz indicates the wood flooring is splintering and that wood floors have a limited number of sandings possible due to the thickness of the wood. Attached is a drawing of the profile of two boards as they are connected in the hardwood floor. As the floors are sanded again and again, the 'tab at the top of the joint becomes too thin and the wood splits at that point. Mr. Schmitz believes that the floor in the property shows clear signs that the tabs are already too thin. Mr. Schmitz believes that if the floors are sanded the wood will split further and the floors will be useless. Mr. Schmitz believes the only reasonable remedy is to remove and replace the hardwood floors completely. This is an added cost of $16,700. 14-ARDING LARMORE MULLEN JAKLE 1C{JTCHER & ICOZAL, LLP ATTORNEYS AT LAW Keith Kresge October 8, 2009 Page 5 3. Mold Michael Polonis, Mr. Plaster's architect, believes that the extensive water damage in the bathroom and kitchen has resulted in the presence of mold. This means exploratory demolition work of the plaster walls will have to be completed. Depending upon the extent of the damage, structural repair work may be necessary. And if mold is present then additional remediation work will be necessary. 4. Plaster Repairs Mr. McCutcheon indicates that the interior plaster wails are repairable and do not need to be removed and replaced with drywall. He estimates repairing the interior walls at $3,100. However, Mr. Schmitz points out that the plaster is cracked throughout the house and there are areas where the plaster has (alien off the walls. Originally when the plaster is put on the walls it pushes between the wood slates and dries and binds. This is not something that can be patched because it does not properly bind. Plaster falling from the ceiling can be a health hazard. In these circumstances, removal of the plaster and replacement with drywall is more appropriate. Mr. Schmitz estimates the cost of this work at $21,285. 5. Miscellaneous Items There are areas of work in the Simmonds Builders bid that Mr. McCutcheon does not question and yet are not included in Mr. McCutcheon's estimate. These include for example: Mr. McCutcheon indicates that the fireplace and chimney can be rendered unusable and left in place. However he does not appear to include the cost for this work in his estimate. Mr. McCutcheon acknowledges that potential trip hazards in the concrete walks and driveways can be repaired. However he does not appear to include the cost for this work in his estimate. 6. Additional Low Estimate Items We appreciate that in conducting the Category "C" analysis certain judgment r,alls have to be made about whether a component of a building can be repaired or must HARDING LARMORE MULLEN JAKLE KUTCHER fz KOZAL, LIP ATTORNEYS AT LAW Keith Kresge October 8, 2009 Rage 6 be replaced. Further, judgments have to be made about whether cosmetic or more substantive repairs must be made. However, we are concerned that in some instances Mr. McCutcheon's repair estimates are both too low and do not adequately reflect the need for replacement. For example: Mr. McCutcheon recommends replacement of the roof and certain repair work at a total of $5,960. Mr. Schmitz believes that this will result in an ineffective repair. Enclosed are two photographs of the roof showing that the roof structure is sagging. Mr. Schmitz estimates the cost of an appropriate roof repair, including rebuilding the rafters and installing a new root at approximately $18,000. Mr. McCutcheon recommends one coat of roller paint on the garage doors at a cost of $95.00. Although this is a small item, it is another example of the cosmetic nature of some recommended repairs. Mr. Schmitz indicates the garage doors are rotted and sagging to the point of resting on the ground. These doors should be replaced rather than simply painted. Mr. McCutcheon points out that the addition to the rear of the front house is illegal and must be removed. Mr. McCutcheon estimates $329 for this work. Yet this work involves removal of the illegal addition, removal of the foundation component and patching and repairing the exterior of the house. We question whether $329 is sufficient for this work. Enclosed are photographs of the kitchen showing the extensive deterioration and damage. Mr. McCutcheon's estimate for repairing the kitchen is approximately $900. This includes repairing the floor and cabinets. This seems very low. And Mr. McCutcheon includes no amount for repairing the kitchen counter even thought the photographs show damage to the counters. Overall, we are concerned that many of repairs being recommended by Mr. McCutcheon are insufficient repairs that would not last long after which more extensive repairs and replacements would be needed. We respectfully request that Mr. McCutcheon consider these points and assess what repairs would be needed to maintain the property for a longer period of time. - - -- - ,i ; r f I `I 7 � ::�.:: r � :- r , . .�:���. i�$ i �_ Construction Specialties, Inc. 1 1043 ®linda St., Sun Valley, CA. 91352 License 4681416 Ph. 818.767.8364 Fax 813.767.3874 Date: 9.24.2009 To: Jerry Company: Sirnmonds Guilders E-mail: terrys@simmcon.corrl From: Jeff Kilgrow Re: Rid for 2501 2nd St., Santa Monica tr of Pages: (1) Scope of work: 1. Shore existing house as needed for new foundation $ 9,500 2. Demo existing foundation and haul away. $16,000 :. Form, place steel and concrete for 112 I. f. of` spread footings $42,900 4. Level and attach existing framing to new foundation $ 6,500 Total Price $75,900± Due to the typical nature of the soil in this area and the need to support the home, the work would be performed using A -B slot cutting methods. It should also be assumed a spread footing will be required to properly support the home. Note: This is onlya 'ball park number based on our conversations about this property. For an exact number, a complete set ofArchitectural and Structural drawing are needed.. Also l will need a copy of the soils report. Thank you, Jeff Kilgrow Protect Manager o i nT' O,.r Tal u rp I 1 e t3� S5 IFS I+ F tx a t N ,S v Til MI fi``'r gn s '�I a„ VGI �� ..� ._, ...,. __ ' "'r u ASAP Home Inspection Service 310 379 -1999 www. as a pin spe cti on. corn September 22, 2009 Keith Kresge City of Santa Monica Rent Control Board 1685 Main Street Santa Monica, CA 90407 -2200 RE: Request for Additional Information by Kevin Kozal Removal Permit Application 432R -C 25012 nd Street, Santa Monica, CA 90405 Dear Mr. Kresge, Herewith is my response to Mr. Kozal's request for a breakdown of my repair estimate regarding the subject property, and a summary of repairs and improvements in the cost estimate from Simmonds Builders, which in my opinion includes repairs and /or improvements not necessary to restore the' dwelling to tenantable condition. The items in the breakdown of costs associated with repair work from Simmonds Builders do not clearly state the method or quantity of work. However, cost estimates of many of the items in the list suggest that work exceeds the basic repairs needed to correct conditions that may endanger the life, limb, health, property, safety, or welfare of the public or the occupants as per California Civil Code Section 1941.1 and Section 17920.3. Because of the lack of details in the list of costs from Simmonds Builders below, my comments (italicized) are based upon my inference from their line item estimates and descriptions. List of costs associated with repair work from Simmonds Builders 1. Demolition of plaster, floors and finish, $9,675 This line does not state the quantity ofplaster, floors and finish to be demolished. However, the cost estimated here implies that the scope of this work includes demolition not required to meet tenantable standards. 2. Lift home off foundation and construct temporary shoring, $23,220 3. Excavate and replace foundation, $27,090 4. Remove and restore chimney, $10,965 . The fireplace and chimney have been in a state of disrepair for an undetermined length of time. Afireplace is not an essential appliance. Rendering it unusable and leaving it in place will comply with the health and safety code. 2218 Grant Avenuo, Redonda Beach, CA 90278 September 22, 2009 Removal Permit Application 432R -C 5. Remove and replace buckled concrete walks and driveway, $7,095 The condition of the walks and driveway do not affect the safe use of the property, with the exception ofpotential trip hazards, which can be corrected without replacing the walks and driveway. 6. Repair and replace cripple wall structure, $8,385 Cripple walls will be replaced with a concrete blockfoundation 7. Repair and replace siding, $15,125 8. Repair damaged and undersized framing, $9,385 9. Finish carpentry, baseboard, casing and picture rail, $9,804 10. Kitchen and dining room cabinetry, $9,675 Cabinetry condition is acceptable with some repair needed. They.do not need to be replaced. 11. Insulation to meet Title 24 requirements $5,805 12. Bathroom and kitchen plumbing fixtures, $5,805 Fixtures are in usable condition with some repair needed 13. Replace rough plumbing and water heater, $7,998 Rough plumbing appears to be in serviceable condition 14. Gas line for FAU, relocate water heater and stove, $2,322 Stove does not need to be relocated 15. Replace cave T &G and rafter tails as needed, $7,224 16. Re -sheet and replace roofing with composition shingle, $18,060 17. Gutters and downspouts, $2,838 Not required by building code or health and safety code 18. Wood door and windows, $10,062 19. Gypsum wall board, $21, 285 Plaster walls are repairable and need not be removed and replaced with drywall 20. Ceramic tile & installation, $5,418 Kitchen counters are serviceable (no other ceramic the present) 21. Linoleum in kitchen and bath, $1,935 22. Replace wood flooring, $16,700 Wood flooring is in serviceable condition 23. Prep and exterior paint, $12,255 24. Interior paint, $10,062 25. Replace forces air unit (heat only), $5,805 Existing heat is two floor furnaces. Like kind would include non - mechanical gravity type unit such as a floor or wall furnace. A forced air heat system is an upgrade 26. Electrical expanded and brought up to code, $11,223 Expanding the electrical system is an upgrade and is not necessary Page 2 of 6 September 22, 2009 Removal Permit Application 432R -C My breakdown of the scope of work and estimated cost to restore the dwelling to comply with Health and Safety Codes in a like condition as of its last occupancy is as follows. No allowance was given for replacing dated fixtures and /or appliances or for improving desirability by a prospective tenant. FRONT HOUSE STRUCTURAL PEST CONTROL Remove rotted/damaged wood at and around bathroom as per structural pest control operator's direction and replace as needed. Estimated allowance, defer to pest control. $4,906 PLUMBING Miscellaneous T & M to repair plumbing drain and waste lines disturbed to replace foundation. Repairs viewed at existing lines suggest plumbing has been maintained in working order. $528.00 Reinstall /relocate existing water heater (install in exterior enclosure, Shorten pipes) HEATING Remove floor furnaces and seal opening below grate. Install Gas wall furnace 50,000 Btu, spark ignition. $650 $210 $1,124 ELECTRICAL Electrical wiring system and service have been updated in the past and appear to be reasonably maintained. No significant cost is needed to the electrical system. No allowance. EXTERIOR Remove unpermitted, substandard enclosed rear porch. Repair windows as needed. Restore front door to operation as needed. Siding repair and new foundation skirt wall siding. Prep and paint exterior walls and trim. Page 3 of 6 $329 $900 $195 $2,253 $4,700 September 22, 2009 Removal Permit Application 432R -C ROOF, House Removal of wood shingles & asphalt shingles. Repair rafters and cave boards. OSB sheathing, rough, power nailed, including normal waste. 1/2" 3 -tab fiberglass asphalt shingles, GAF Royal Sovereign ®, 25 year $1,517 $801 $1,245 $2,397 INTERIOR Repair walls (existing and anticipated damage) $3,100 Paint interior $3,300 KITCHEN Repair plaster below sink. Repair cabinets. Repair kitchen floor with pantry tile, new vinyl tiles at pantry. $200 $390 $310 BATHROOM Structural framing components are water damaged due to substandard shower conversion over a bathtub. Floor framing will be restored to level in conjunction with the foundation work. Shower enclosure is not code compliant and walls will be restored. An option is to install a fiberglass tub /shower combo for about the same cost as to restore. $2,000 Bathroom wall repair $480 REARPORCH Restore modifications from bootleg covered porch to original condition, close off wall end, repair window. $2,500 WASTE DISPOSAL Roll -off for public dump Wood shingles Rotted roof framing and eaves boards Cripple walls, Rotted floor framing members Bootleg rear porch Page 4 of 6 September 22, 2009 Removal Permit Application 4328 -C Asbestos attic insulation and asphalt shingles disposal . Dumpster, 40 CY solid waste bin (for lumber, drywall, roofing) Low -boy, 14 CY solid waste container (asphalt, dirt, masonry, concrete) Hauling cost $1,828 TEMPORARY FACILITIES Toilet and fence $750 MISCELLANEOUS PERMITS $1,000 ON -SITE SUPERVISION $2,500 Subtotal: $40,112 15% Overhead: $6,017 15% Contingency: $6,918 10% Profit: $5,305 Estimate, Front house: $58,352 FOUNDATION Remove and replace; includes permits and OH &P Estimate, Replace foundation: GARAGES Demolition of 5 -ply built -up membrane roofing Board roof sheathing, Demolition Board roof sheathing, Installation, 150 sq. ft. Page 5 of 6 $43,1-13 $392 $109 $291 September 22, 2009 Removal Permit Application 432R -C Nail one 15# felt ply, mop 90# mineral surface ply with asphalt $570 Galvanized steel flashing, Parapet coping $258 Exterior flat latex on stucco, one coat Spray $526 Exterior flat latex on doors, one coat Roller Very truly yours, $95 Subtotal: $2,241 15% Overhead: $336 10% Contingency: $240 10% Profit: $283 Estimate Garages: $3,100 Estimate, Front house: $58,352 Estimate, Replace foundation: $43,115 Estimate Garages: $3,100 GRAND TOTAL $104,567 Duane McCutcheon General Building Contractor #272224 ICC Combination Dwelling Inspector #5130345 -56 Page 6 of 6 WRITER'S DIRECT DIAL (310) 451 -4138 November 24, 2009 HARDING LARMORE MULLEN JAKLE KUTC EK & KOZAL, LLP ATTORNEYS AT LAW 1250 SIXTH STREET, SUITE 300 SANTA MONICA, CALIFORNIA 90401 -1602 TELEPHONE (310) 393 -1007 FACSIMILE (310) 458 -1959 VIA E -MAIL keith.kresgg@,ap2gov.net Keith Kresge Staff Attorney Santa Monica Rent Control Board 1685 Main Street, Room 202 Santa Monica, CA. 90401 -3295 Re: Property Address: 2501 Second Street, Santa Monica Our File No. 20251.001 Dear Mr. Kresge: WRITER'S E -MAIL ADDRESS kozal@hlmlaw.com himlaw.com As I explained in our most recent telephone conversation, we retained a mold testing company to analyze the front house. The property owner and his experts expressed concern that mold and water damage has occurred at the property. The attached mold inspection report prepared by the Mold Guy confirms this. Also attached is the expanded fungal report from LA Testing explaining the test results from the samples taken by the Mold Guy at the property. In summary, these attached documents demonstrate that there is a significant mold problem at the property that requires remediation. This will entail additional work and expenses to remedy this problem. At page '14 the mold report confirms a mold problem exists if the indoor mold tests show (1) higher mold counts then the outdoor levels, (2) mold spores that are present indoors but are absent outdoors, or (3) indoor mold is toxic. In this case all three situations are present. Pages 5 -14 of the lab report numerically and graphically demonstrate the results of the mold tests. Page 5 indicates the raw count for total fungi outside is 146. Pages 5 and 6 confirm that all of the indoor samples were significantly higher (a minimum of quadruple and in other samples even higher) than the outdoor levels. These figures also demonstrate that indoor samples detected mold not present outdoors. For example, the kitchen sample included both Stachybotrys and Torula mold spores. Page 27 of the lab report indicates the mold Stachybotrys may produce toxins. HARDING LARMORE MULLEN JAKLE KUTCHER & KOZAL, LLP ATTORNEYS AT LAW Keith Kresge November 24, 2009 Page 2 Given the foregoing, all three of the factors for a mold problem are present at this property. The Mold Guy does not perform remediation work and therefore did not provide an estimate of the remediation costs. However, we have discussed the necessary work with the owner's expert, Jerry Schmitz of Simmonds Builders. Mr. Schmitz confirms that the repair work necessary for the remediation, excluding the mold abatement, is essentially included in his prior estimates. This Is because he recommends significant repair work to the kitchen, bathroom and plaster walls. However, the mold abatement work would be an additional cost to his repair estimate. Mr. Schmitz estimates that this will involve a higher level of precaution because the abatement crew must take steps to protect themselves and the environment from airborne mold spores which are stirred up during the demolition. He believes the abatement costs, which exclude repair cost, will be at least $5,000. As we have previously discussed, the report prepared by Duane McCutcheon, Board's expert, confirms that his estimated repair costs are very close 'tothe 50% Burn that triggers a complete rebuild. The gap is only $15,000. It appears that Mr. McCutcheon did not consider significant repair work in the kitchen, bathroom or front bedroom. (For example it appears that his estimated repair costs for the kitchen and bathroom are $890 and $2,480.) The remediation work will involve significant work in these areas including the removal of all kitchen cabinets, the removal of all bathroom fixtures and removal of significant portions of the floor, ceilings and walls. The remediation work will also require the repair of all plaster in the kitchen, pantry, bathroom, closet and half the front bedroom, all new kitchen cabinets with new counter tops, new kitchen floor, new floor in the bathroom and new bathroom fixtures. It appears that very little if any of this work was included in Mr. McCutcheon's estimate. I believe it should be self evident that this repair work alone, not including any abatement costs, will easily be more than $15,000. Furthermore, the mold report recommends inspection inside the north wall of the bedroom /south wall of the bathroom during the abatement process. This is because it is likely the framing behind the plaster has mold growth as well. If that is the case, this framing will also need to be replaced. Mr. Schmitz points out that this will not be an easy repair because the ceilings and roof will need to be shored during this work. Mr. Schmitz points out that this is the wall identified in his report that has significantly dropped due to termite /water damage below the floor. k I , ,K T T CEI-E a" ATTORNEYS AT LAW Keith Kresge 11avember 24, 2009 Page 3 Mr. ivicG:uicheon's report indical s he only consir_eved items nace.ssary Tor heaMi and saie.ty and ncA co-si3tetic ft<ern& All of the ra- me,dBadon ti>oirh ide.gffied in th nrold roport rs lai?es_,'to a health and sa ielly and therGe "iora carmii be discounted 0r ignored. " With the cidr;'idon of the a tached imorma "lion we respeciiLilly reques't'thai Mr, McCut heon review his estirYake. and confirm that replacernerit of 'ihe "front house_: is warralT' d on "the basis that "the repair costs will exceed 50% of e replacement cost of the structure. _ i�rspjeccs�llt :�ruk,rui'sa�c�ci, Kevin V. Kfj,y,s[l lst'ti lI-I;r?jb fi.'ttac..hmem 202511Cor /Kra sge.1008. r<vi; .doc I I` The scope of a4,rJ1f,a5 iJ3dt,1d,@fl a d}>'.<l1F"d w7.3u d sunray t74 3 3 - propa'n.y. TA'a, burgay'j'riY'l as on le de; ?, ch'a) o UAvj7) elvid-anc' -a of mt)dd :3 and J702�cudbid gm`x#1 J`1VMO PIS s�3 dZ3y���''c) 9f3��'t,�137�� ud'Nlaa,'J' 371 dd9'�i'.•]SinJd1,, "N'd:.' i3�3!43Kz t)r ahirD aun),ay )aa"3 47m Yball in th kA)o°i'ing 1ndC7oi").Ad -30 )1Zc.,daar:ed in 'kh 1 ?Cl¢7`9+_'19'.l oN7�7�N� "4i!s'1f35 a? lmagiaki`f', 1fa'1't Pa;anti- d)J radurQ tha Ir75JDfdbi)i,(y 01 i.ubiTa ✓'d717k) )1°1 pwkld'f9u7n �fo d:6 d( vl33u 1) l.'lrvay, to 997 o r sijb,,,m -in c a -.) 13nipIva � ;I ra t�l n tJ --x d ifalit d"qu 6, 612 vaf One o7m}Jd le'd 1I1?)S;yt7�a`] )'cS� dlJ�l l'7tJf?j °11'3•'sld'),A) I hd1 �Y ep� b'J -_Y _ I'll; Fu gip: ? smI PSI 4a �,'�.iB+r1 l'.i _.i 1 + +i ":dGii� �.�:,1 .i ,S�71Jr .]+_i_t� +3 <c. t.r-lun m, Me mu,", a°) daunagW aHd th.', 313 il(Ad I ? C+i3'ThO x.:10: V- 16"1,1 baf;{'Pimi9 Is a3 ::.aiflpje was <`3kan in 'Una it3ECf, fr' to tia an7 jna' U ai% "ti5141'D3, §a1 mold caYSdf$on Ask Air Jlovj vvao'kakav at 15 Kam F�9° � ��airoa,s "t� . a lt9 °s'si s��d9�, C;Ovllpr)ata skuyfar^"fa�` aa;flpia s we're taken on +:h � an Qa1a @h and im the panalz and bad, "pail hi Nis L,i:t!.,Jfrn ltU. Mass samphs ON be s damoad on kha VOPOA by mW _ab Code: 1 5517M3 Lab "A a: <i' dk &00z) _�b °r-a: V2 r4-ko ?3" O a?9°m (vmfl9;J af? 33)l 91alhis 1-1s,16aaWity: 67% T empara'hina: 655 gow 1 Az 4,.- 1 Vynhen f'ablrlq�.F, uv�lfl 7,�Id 6S1 41 b om ) wa-.s 5),- , pail S. )"J'aH M 3Ma KR'tchar had mad's 'e-Ind (7 in, pr':),An",j and mold Al X6 WhAyll An Ito, - ) - -� i,J � 1 -.; 11 �? -f'�. . ;.:. el ipv.,3l.1b,;h,,I::?: ,Si I P�e sma Adva-lltiI2m �id:,i`g:':'d�Pan,,iyv`9 `rill d.la`311zS411] 4ir1 :)ice) COMM S.�sSO. Ai d,Jowa,Yclz ! la ?' d' `_ir. 1 ✓ 13�� ^d5 t,)9 ] ffiiai'i`a3�d�. ,`1?:i {Jj ?i +d' dly, .l e,' 1q)f)aR.q ;'n' dnce s mpl -J d}f'i y qkol`i on. &I -a Nl .' al A <lq- sm°1hs I1ii3ar +11,9 J`f3'ON & ` OZ COMM Muso :.w`lmp% imp y .1r, �j�l`J'dlxlJj$3'e) �iaa',YJ:ttifi l3d� �u l;�.d1: %'�V' Lab Codo: 13517341 1<af .p,, aa'a'na: 84 3 � s WhAyll An Ito, - ) - -� i,J � 1 -.; 11 �? -f'�. . ;.:. el ipv.,3l.1b,;h,,I::?: ,Si I P�e sma Adva-lltiI2m �id:,i`g:':'d�Pan,,iyv`9 `rill d.la`311zS411] 4ir1 :)ice) COMM S.�sSO. Ai d,Jowa,Yclz ! la ?' d' `_ir. 1 ✓ 13�� ^d5 t,)9 ] ffiiai'i`a3�d�. ,`1?:i {Jj ?i +d' dly, .l e,' 1q)f)aR.q ;'n' dnce s mpl -J d}f'i y qkol`i on. &I -a Nl .' al A <lq- sm°1hs I1ii3ar +11,9 J`f3'ON & ` OZ COMM Muso :.w`lmp% imp y .1r, �j�l`J'dlxlJj$3'e) �iaa',YJ:ttifi l3d� �u l;�.d1: %'�V' Lab Codo: 13517341 1<af .p,, aa'a'na: 84 Base of the walls and ceiling of the Kitchen Pantry had mold like substance. 0- °:ra' CJ ).Fl I is? 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L 7',ibllaC1, lei, �_l:tl�'13,m)ja 'llIlllollra1 rlry (s Ilii] lyt lj;,, x7 A 1- m- 'aes.i7Am-' l',{' iTr TIP17111_O L1 In19'J n:f Emu min,- li„ by :7h31 ie >> ''Valli 13. :ir'irn ni uI' 11hallb „f PlIpaid TIYUg ens Dftau777 Fn�ltlazv_en.i 3 ?s 1�� rnt��l�tav?nt^11ljvuni7,e ,I;l�r]��in7t�]lr7 fir, - 'hags ij C!p; tusi." , , , ' 1 111{ i 11 ! bit) lo4-o L Hj wl� 1 IDF -wj Oc I.Q llmuwtoh,� ll'.�Ij,P � \ %Tt»dd§ R m _: ,mom m MTa _«a+:;m LLP _. 2nd _a_a_mCA _, e_w_v ;,m, � ,� " r « Ed & ƒ <%L 10281 � x � as ?:hd .� a yry »\ ^»�,. «� � . � 2 w. / \� LA A -' iung :5 an independent labo 3.t{)4' °J ✓9J,:1( W3'an'd?39 rt''ad the paai` sio W Most 3amplaw L"" 'resting nuo not a iJlidnot the sF319i'j31 ng el9' mie lo�' Ibis F- apoill. The Sj 1mlploo r fereflood horkAn O'vere lnll? 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Was .iai;5'rLl J3 3 ' Sl'e iu Jia9D1l. s t.:S an d?^-jmalon =;a'i ah ! 20m, w .:., , J. p3P'J Oni' d m::f jamays l,g LA Testing .JeI3 NIf5a7Gt1 a1�2.:C SU3ikn �9_`1[)zt ?a, t.rd J.1?Jaii Phone: (U3) 289 -9960 Fax: (32 3) 3'39-::. &32 OBax: Iri7J: /P;ncrro.taiesiiit).caai = rn�ii:e3saclsnalaU�li asiingcn'ia L�F 6JC a,':�ah L'3by .Ai1aL Qrd is I733 The Nlolri drily: Inc. 0aexo2 "l3sr lrj: 327711GU62 9193Yk,v. Olympic!lvd. roll5aubd: 9'dY09120 9 Suke 2013 R0CFjlv,)-d: '11110),2009 e twarly Hilt, CA MV V Anniy:7)d HA(11*:7t,)M PYW: THAW, Lannon, 'u7, 31,1, &N% n0wor a f . _.al UT' 3301 t3:1 al ,, 5 u afl '7 JSa8 �, CIA 2 75 The Bi m?? -a A '.`)1aywod, upwo ): ?u? ii . .e.i�," ^:1' ail`, tt ®;�'�I''Sfi half" ?Z lh °Ct� @`77 3ak7 deposKion and not gri'6) J 11, 31 fowpal V 1 1 9MdN't -]61c' in lsoy a aw91ee:3 at daP ,: `, ei7rE -uli 7u16�g :<ItJp "i1Jl�t7 ? 'low .. L' J�f_t ti�1! 7>." 3J'I .., X71. : i)'1 ,"'annul Spores era luund . "-var wfjer'9. 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Yo 5j8 =3 tfuidel731•';i 10741 EEPA g?Iid:A31ioz '1uf' rain' :Fervis4,18e}'.1nn in Ja'hoola iJnd 'ooilun), 6'tial W477578:)3 +:7°1!'3ns the t'-r)3,71'S8uiili'.?'}73a91Ang nool a 7'efrned7`a7'4113f1, A:j3 ^7,` yo P,7i`197i3iba 1'bal ks lha key, Proveniin) o i?i1173a'c+J714i'a13:3a1don IMBI U17'DtJ`M mold ?J)'Oyi1_'li. This report is 1d J+ 1S2lo ,W to ySi7413%1da 7'71,57)7.17 ldvina Jd "Id vip"D tSoroo;'3i'01ino the !'7cly :71e'ety of on of"o-uE31<_)ii sroa . W:}?j.s aanzath an occu7att1nal of anvi-'zJYI`fil'e V3i;7'7 i349:f7'y'73 physician who has - -`:_C eria73ce addressing Moor air i_',llu }i1J173B1_1Ms li' you fl l Ia 'ony Pay, 16 C00121 1,A `P r.jiig S 2.') Mi 'lian Siopp {: �ui71 n' Prrv�: r�1 9 -1 3 n, l9 Phan: (323) 2.54 79000 Fax: (333) 25?990? Woo: Ui�paivr rw.lai =,oiin�.corn email :in�adanadaLLlai��iin�.ccrn ,Mime I.4er?<Le•iy 'ENISL Ord is Z'M911726 The Mold Guy. kua. 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I surnedfaactsaboutrnold.Tim, The Occupa6onal Safma'ty and Health ;Aclrninlatraallo 3 (OSHA) httq;hr r, rrrv. osha.ov /SLTC /moldslinde;<.hQgIl +] tt o Ji,rr,r;�r. cdc.q o vlrnold/ is q s. h f r'n •, ? ��: -a �iclr ]"t,�s7T * ±n',ts, tZ ^t�J.s7ia7973 Hilo] `.ln_>`i l ^q� 2 +n ��?=l. ff't,OtY'f i - 531, i <a7'ililil ,Itlle� J. ia!,i s7D',tlL OWL HAS: Gloarinei':M sAV:6 -319'9 o zind is3door,- -,ir Expus+a es Ll, f2(mat alo.ed vbUo O-)S YINAd96I tttrf1 if (19Y.;]fl;ll nt p:iil,v�waw.nlin.uih.i oo nrnedllne��_srmujtls.hrt�i vCF b.. .•tt... ry ><.I. G`a ..•. Jb raaa)ical ar_�_n...'ml .tl..'a c. Ln. aa....• ..ra.: Ll �. :9. rP "IrJ -)4'.a _, � .i rrt� aJi1� i icn emu- �sih [�aaG�N, �a � +w'll Roma (0, 54540 F.103) 20482 4Vpb. .r ,, lf.nr, hZ.,an�.crnn Gt'rzaha>aaacrar`arai Ala.: S, y.can i- sc.e3o di1.7it Lwy "H111, 3L Ord o4: 320011738 The Mold 4 =.4y, Inc. Oustomor 10: 3 ?PJIGU62 91 GOlNeet Olympic, 31'ri. cod arced: '1'11L7�i`2tJG�J E aJ'ariy $ °ii1 &:�, w i .dne'i;z , =u;a9yircl: 'i'11,101 -W,C`? i=1, ? 1ani,.,), t Cp!aFD i, Illy t;'r rv'= 1 v, llu!!!iUl /il(I H.P.: ha Uni)ls =l Sales AW Wid Sa'le8y i d Ps'a'b ,q 'Osa .cwt nitoWO& I. xie �,ilovl<_on� im'.]tjykm "' h nallSi "ia,94] l:- l`is ?''N" e >fi' jOlucIs Ila Yom dome +,, oaflC,d?,! 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I to"'; _.. si c, ,1 Tic 0 ;Y _ s Jas ) +,l j V24, :k3 1Q d ,'aqr? {'•,i3 -.1 SANTA MONICA RENT CONTROL BOARD STAFF REPORT ON REMOVAL PERMIT APPLICATION W.1virkm PROPERTY: APPLICANT: AUTHORIZED REPRESENTATIVE FOR BOARD MEETING OF: DECISION DEADLINE:. 432R -C 2501 2nd Street Plaster Family Trust, Richard H. Plaster, Trustee, Landlord . Kevin V. Kozal, Esq., Harding Larmore Mullen Jakle Kutcher & Kozal January 14, 2010 January 31, 2010 (Waiver) CASE SUMMARY Landlord Plaster Family Trust seeks a removal permit for this two -unit property, contending the units are uninhabitable and cannot be made habitable in an economically feasible manner. The application identifies the units as 2501 and 2501 -1/2 and indicates that both units are vacant. The property was originally registered with the Board on June 12, 1979 showing Richard Plaster and Hilary S. Plaster as owners and indicating a purchase date of August 12, 1963. The units were identified as 2501 and 2501 -Rear and April 10, 1978 and April 10, 1979 rents were listed for both. Applicant Richard H. Plaster, Trustee of the Plaster Family Trust indicates that the property was inherited upon the death of his parents. Unit 2501 is a two- bedroom unit in a detached structure at the front of the property. Unit 2501 -1/2 is a detached one - bedroom unit at the rear. Board records show current Maximum Allowable Rents (MARS) of $791 for unit 2501 and $759 for unit 2501- 1/2. City records show that the Code Compliance Division of the Building and Safety Department issued an Order to Comply on July 23, 2008 describing violations that include 1) general dilapidation and improper maintenance; 2) bathroom added to the rear house without permit; 3) electrical work done without permit; 4) unsafe and uneven floors; 5) deteriorated exterior wood surfaces; 6) exposed plumbing; 7) water heater installed without permit; 8) exterior stairs removed; and 9) washer and dryer installed on the exterior of the house. The Order's required corrective actions include a permit application to make all necessary repairs and return the house to a habitable condition and insure that the property remains vacant until repairs have been made. Staff contacted the Code LegaI:KJK:Remova1sA32R -C: Staff Report Staff Rvort/Removal 4J2R -� 2501 2" Street Page 2 Compliance Officer who prepared the Order and was advised that the violations cited refer to the property's rear unit (2501 -1/2). Applicant provided copies of voluntary move -out agreements with the last occupants, asserting both units were voluntarily vacated. The agreement for unit 2501 indicates the tenant died and the tenant's caregiver, who had no agreement with the owner regarding occupancy and who paid no rent, stayed. The agreement provided for a November 30, 2008 move -out date and the payment of a relocation benefit. The agreement for unit 2501 -1/2 indicates that both the tenant and the lawful subtenant voluntarily vacated, with the tenant acknowledging termination of the rental agreement effective July 1, 2007. The application -notes that the applicant intends to redevelop the site with a multifamily house. And concerning the property's condition, it states "[A]pplicant inherited property and is unaware of maintenance history[.]" Applicant provided a detailed report from Simmonds Builders, a licensed contractor, that estimates approximately $350,000 to rebuild front unit 2501 and that states it would be impractical and cost prohibitive to rehabilitate the structure due to its advanced state of disrepair. It cites the Municipal Code section that provides that if repair costs of a structure exceed 50% of its replacement cost, the entire structure must be brought up to current technical codes or be demolished. Simmonds estimates the cost to rebuild unit 2501 -1/2 at $175,000. It cites the severely dilapidated condition as the reason it does not believe rehabilitation is possible. And, citing the Municipal Code, it notes that due to rehabilitation. costs, systems must be brought up to current technical codes. Board consultant Duane McCutcheon of ASAP Property Inspection Services inspected the property and prepared a report of his findings. He concludes that the rear structure cannot be repaired to render it habitable as repair costs exceed 50% of the $120,800 cost to replace it. McCutcheon. concludes, however, that front unit 2501 can be repaired to render it habitable. He states that while the unit's unreinforced red brick masonry foundation is unsafe and must be repaired, the unit can be made habitable at an estimated cost of $104,567. McCutcheon reviewed the Simmonds Report and concludes that much of its scope of work goes beyond that necessary to render it habitable. The' applicant provided a Mold Inspection Report and an Expanded Fungal Report to supplement the record. Based upon the conclusions drawn in these reports, applicant contends that McCutcheon's estimated cost to rehabilitate the front structure. is not reliable as it did not contemplate the need to conduct extensive mold remediation. Staff notes that the record suggests that the current condition of the two units could be the result of deferred maintenance. Applicant states that it inherited the property through a family trust in 2007 and argues that it should not be charged with deferred maintenance attributable to the prior owner. Further, as discussed below, Legal: KJK:RemovalsA32R -C: Staff.Report Staff Report/Removal 432R -C 2501 2"o Street Page 3 issues of due process should be considered when deciding whether deferred maintenance is *a factor affecting a removal permit application. Staff recommends that the permit be granted for both units 2501 and 2501 -1/2 as the record shows that the existing structures cannot be repaired to render them habitable. DISCUSSION Under section 1803(t)(2)(i) of the Rent Control Law (RCL) (Article XVIII, Santa Monica City Charter) approval of a removal permit may be granted: "If the Board finds that the controlled rental unit is uninhabitable and is incapable of being made habitable in an economically feasible manner Habitability Both Simmonds Builders, the applicant's contractor, and Board consultant Duane McCutcheon' note the unsafe condition of unit 2501's unreinforced masonry foundation. Simmonds states that the interior mid -span supports which consist of 4x4 posts are set on top of the brick foundation with no visible means of a solid connection. It cites termite damage to cross braces and foundation supports. It recommends the entire foundation system be replaced to make the unit safe and structurally sound. In addition, the mold inspection report and analysis found levels of mold spores.suggesting active mold growth in several areas of unit 2501. Mr. McCutcheon concludes that unit 2501's deteriorated unreinforced masonry foundation is the main issue that renders the structure not tenantable. He states that it is common knowledge that this type of foundation is a high seismic risk and has been considered unsafe by the real estate and building industries for twenty years or more. Both Simmonds and McCutcheon cite unit 2501's non - permitted, substandard, covered porch and recommend its removal and reconstruction. The porch currently houses the unit's water heater, refrigerator, and laundry hookups. Regarding rear unit 2501 -1/2, Simmonds and McCutcheon concur that it cannot be repaired to render it habitable. They cite the lack of foundation footings and the severe sloping of existing floors and that the later -added bathroom addition is resting directly on grade, with no foundation below it. Both agree that the substandard, non - permitted bathroom can only be removed and replaced to make it code - compliant. Both experts conclude that unit 2501 -1/2 cannot be repaired to render it habitable under Municipal,Code section 8.84.040 which would require that the structure be I Duane McCutcheon has been a licensed general building contractor (currently inactive) since 1971. He is certified as an ICBO Combination Dwelling Inspector, a master inspector for the California Real Estate Inspection Association, and a member of the International Conference of Building Officials and the International Association of Electrical Inspectors. Le9aI:KJK:Removals:432R -C: Staff Report Staff Re Port/Removal 4oLR �.. 2501 2" Street Page 4 demolished. 2 These conclusions are consistent with the findings of the Code Compliance Office who cited the landlord for failure to maintain various technical codes. Staff recommends that the Board find that units 2501 and 2501 -1/2 are not habitable within the meaning of RCL section 1803(t)(2)(i). The finding, consistent with the opinions of the applicant's contractor and the Board's consultant, and the Code Compliance Order, is supported by a preponderance of the evidence. Economic Feasibility of Rehabilitation RCL section 1803(t)(2)(i) provides the Board shall grant the removal permit if it finds that rehabilitation of the unit cannot be done in an economically feasible manner. In the typical case, an analysis is done to determine whether the property can generate sufficient income to absorb the cost of rehabilitation and still provide the owner with a fair return. However, as set forth below, neither of the structures qualifies for rehabilitation under the City's Municipal Code. Unit 2501 -1/2 The evidence shows that unit 2501 -1/2's current condition precludes its conforming "to all requirements of the Technical Codes." The experts agree that its substandard foundation and resultant damage to the floors require a new foundation. Both also agree. that the non - permitted and substandard bathroom must be removed. Mr. McCutcheon reports that replacing the foundation and related repairs to restore structural integrity and the removal of the bathroom alone would cost $72,000. That amount exceeds 50% of the unit's $120,800 replacement cost. County Assessor records list an 1895 year -built date for the property. While it does not indicate which of the two structures was built then, the 514 square -foot rear unit is consistent with the original cottage -type buildings erected at, that time. They were, as here, built without adequate foundation and with materials that were not designed to last over one hundred years. This is consistent with the experts' conclusion that the unit's overall construction is substandard. Thus, rear unit 2501 -1/2 cannot be salvaged, let alone rehabilitated to conform to all current technical codes. Per section 8.84.040, demolition is the only option available to applicant.. Unit 2501 Simmonds states that due to extensive structural damage, there is a significant possibility that unit 2501 would collapse while attempting to lift it from its existing footings. 2 Section 8.84.040:provides in pertinent part: "Whenever an existing building or structure has been damaged, or is in need of repairs, or the owner desires to make repairs, alteration or rehabilitation in an amount exceeding fifty percent of the replacement cost of the building or structure, the entire building or structure shall be made to conform to all requirements of the Technical Codes or shall be demolished." LegaI:KJK:Remova1sA32R -C: Staff Report Staff Report/Removal 432R -C 2501 2" Street Page 5 It considers the structure a worksite hazard and states that it is more economical, efficient, and safe to remove the entire structure. Simmonds estimates $350,000 to replace unit 2501 with a new structure and $316,578 to repair it. The scope of repair includes lifting, temporary shoring and foundation replacement; replacement of gypsum wallboard, cabinetry, doors, and windows; rough plumbing and all plumbing fixtures; roof; ceramic tile, linoleum and wood flooring. Simmonds notes that the repair cost exceeds the. replacement cost by over 90% thereby requiring that the structure conform to all the requirements of the technical codes or it must be demolished. It concludes that it is simply impractical and cost prohibitive to rehabilitate a building in this advanced state of disrepair. Mr. McCutcheon reports that the Simmonds estimate to repair unit 2501 is high because it exceeds the work required to make the unit tenantable. McCutcheon notes that his estimate of $104,567 is to "restore the house to its last tenantable state." He cites Civil Code section 1941.13 when setting forth his opinion that the Simmonds estimate includes repairs and improvements that may be desirable but not necessary. McCutcheon notes wood rot damage related to long -term water leakage. He cites the improper conversion of the bathtub to a shower without adequate waterproofing as the cause. Repairs required include removal of the non - permitted, substandard covered porch; installation of a new foundation skirt wall; a new furnace; water heater relocation; new roof covering; plaster repair; and interior and exterior painting. He estimates the total cost of repair at $104,567. In response to applicant's request, McCutcheon provided a supplement to his report that includes commentary on the Simmonds scope of work. He also broke down his own proposed repairs into component parts and gave individual estimates for each. His estimate of $104,567 to render unit 2501 habitable remains. Staff provided applicant with a copy of Mr. McCutcheon's breakdown. Lastly, applicant provided a mold inspection report and an expanded fungal report to show that McCutcheon's repair estimate, is not reliable as it did riot contemplate mold remediation. It contends that even using McCutcheon's estimate as the base line, remediation costs put the overall cost of repair above 50% of McCutcheon's replacement cost, thus triggering Municipal Code section 8.84.040 and the requirement that all systems be brought up to current technical codes or the structure be demolished. 3 Civil Code section 1941 provides in pertinent part: "The lessor of a building intended for the occupation of human beings must, in the absence of an agreement to the contrary, put it into a condition ft for such occupation, and repair all subsequent dilapidations, thereof, which render it untenantable, * * *" Subsection 1941.1 provides in pertinent part that "[A] dwelling shall be deemed untenantable for purposes of section 1941 if it substantially lacks any of the following affirmative characteristics, * * *" It includes nine enumerated characteristics such as effective waterproofing; operable plumbing and gas facilities; approved water supply; heating facilities; electrical lighting and wiring; building and grounds kept clean and sanitary; adequate garbage and rubbish receptacles; floors, stairways, and railings maintained in good repair; and a locking mail receptacle for each unit. LegaI:KJK:Remova1s:432R -C: Staff Report Staff Re�ort/Removal 4DLR -(, 2501 2" Street Page 6 The mold inspection, by The Mold Guy, found mold -like substances in the walls and cabinets of the kitchen, the kitchen pantry, the walls and ceiling of the bathroom, the south wall in the front bedroom closet, and the north wall of the front bedroom. Laboratory analysis of samples taken from these areas found very high mold spore counts of aspergillus /penicillium and traces of either chaetomium, cladosporium, or stachybotrys type molds. The remediation recommended includes: 1) Kitchen - remove cabinets, floor and walls within four feet of contaminated and impacted building materials; 2) Pantry - remove ceilings, walls and floor two feet beyond contaminated and impacted building materials; 3) Bathroom — remove tub, toilet, and sink to properly remove the ceiling, walls and floor two feet beyond contaminated and impacted building materials; 4) Front Bedroom Closet - remove walls four feet from the floor and two feet beyond the contaminated and. impacted building materials; and 5) Front Bedroom — remove damaged north wall. These recommendations are for work done by a certified remediation company following guidelines for mold remediation protocols by the IICRC S520.4 The Expanded Fungal Report states that in general, the levels and types of fungi in the indoor air should be similar to or lower than those found in the outdoor air. The report contrasts spore counts from outside with those found inside. It notes that higher . levels of spores may indicate the presence of moisture sources and resultant fungal growth. As mentioned, high levels of aspergillus /penicillium were found in all tested areas and trace levels of three other mold types were found in some. After reviewing the mold inspection and laboratory analysis reports, McCutcheon advised staff that the recommended remediation would indeed raise his repair estimate to an amount greater than 50% of the replacement cost, thereby triggering the requirement for full compliance with all technical codes or demolition. The cost required to render unit 2501 habitable exceeds 50 % of its replacement costs. Rehabilitation would require that all systems be brought up to current technical codes making demolition the only available option. Since the analysis above results in a recommendation to grant the removal permit for both units, staff recommends that the Board find the usual analysis to determine whether rehabilitation is economically feasible is not required. 4 The S520 is a procedural standard and reference guide for the remediation of mold damaged structures and contents. The S520 is based on reliable remediation and restoration principles, research and practical experience, and attempts to combine essential academic principles with practical elements of water damage restoration for technicians facing "real -life" mold remediation challenges. The S520 is written for use by those involved in the mold remediation industry, and is the result of collaboration among microbiologists and other scientists, public health professionals, industrial hygienists, remediation contractors, restoration service companies, cleaning and restoration training schools, trade associations. that service the professional restoration industry, allied trade - persons, and others with related professional and practical experience. LegaI:KJK:Remova1s:432R -C: Staff Report Staff ReporURemoval 432R-C; 2501 2" Street Pace 7 Deferred Maintenance Former Chapter 5 of Board regulations implemented the removal permit procedures and included standards for the Board to consider.5 Those standards precluded the consideration in the rehabilitation feasibility analysis the costs of making repairs necessitated by a landlord's failure to maintain a property in good repair. While Chapter 5 has been suspended, the strong public policy that disfavors the deterioration of rental housing, the basis for the standard, may still be considered. The application provides that the subject property was inherited by current owner Plaster Family Trust. Applicant Richard H. Plaster took over as trustee of the trust in 2006. As noted, the property was first registered with the Board in 1979 by Richard and Hilary S. Plaster, the current trustee's parents, who purchased it in 1963. Thus, the property has been controlled by some individual or entity of the Plaster Family for decades. The City's Order to Comply cited the owner for failure to maintain technical codes, suggesting that the condition is of long standing duration. Indeed, regarding the rear unit it states "the structure is maintained in a substandard condition due to general dilapidation and improper maintenance. It is not unreasonable to conclude that the current state of the property's two units is a result of deferred maintenance. Trustee Richard H. Plaster contends that he had no control of the property during his father's ownership and that had the property been sold to an unrelated owner, that new owner would not. be charged with deferred maintenance. Lastly, Plaster states that it was his understanding that the front house had been occupied by a long -term tenant who did not want any work performed because she did not want to be disturbed. Staff notes that there is no decrease petition activity in Board records for this property. Nor is there anything in the property's site file showing complaints regarding maintenance. Similarly, Building and Safety records show no indication of maintenance issues until July, 2007 which resulted in the issuance of the outstanding Order to Comply. Thus, there is an issue as to whether the prior owner had notice of the deterioration. Board regulations require written notice of maintenance conditions to an owner prior to the filing of a decrease petition, By analogy, the Board should consider issues of notice and due process in this context. In the absence of evidence of such notice, the Board should find that deferred maintenance is not a determining issue. 5 Chapter 5 was suspended on July 24, 1999 shortly after implementation of full vacancy decontrol pursuant to the Costa - Hawkins Rental Housing Act (CIV. Code, § 1954.50 et seq.). Legal:KJK:Remova1s:432R -C: Staff Report Staff Re yort/Removal 4.,zR _ 2501 2" Street Pape 8 RECOMMENDATION Staff recommends that the Board grant removal application 432R -C for units 2501 and 2501 -1/2 as they cannot be rehabilitated to render them habitable within the meaning of Rent Control Law section 1803(t)(2)(i). Staff recommends further that the Board adopt the analysis in this staff report as the basis for its decision as well as the proposed findings of fact and conclusions of law accompanying this report. Legal: KJK:Removals:432R -C: Staff Report Findings and Conclusims (Proposed) Removal Permit 432R -C 2501 2nd Street Page 1 FINDINGS OF FACT AND CONCLUSIONS OF LAW (Proposed) The Board having considered all the evidence in this matter, including documentary evidence, written and oral arguments and the written and oral presentation of its staff, does hereby adopt the following: 1. The subject property, located at 2501 2nd Street in Santa Monica, was developed With two residential rental units. Unit 2501 is a detached two- bedroom unit at the front of the property; unit 2501 -1/2 is a detached one - bedroom unit at the rear. 2. The property was first registered with the Board on June 12, 1979 by former owners Richard Plaster and Hilary S. Plaster who purchased it on August 12, 1963. Applicant Richard Hilary Plaster, Trustee of Plaster Family Trust indicates the property was inherited upon the death of his parents. 3. On July 23, 2008, the Santa Monica Building and Safety Department's Code Compliance Division issued an Order to Comply that notes general dilapidation and improper maintenance; a bathroom added without permit; electrical work done without permit; unsafe and uneven floors; deteriorated wood surfaces; exposed plumbing; water heater installed without permit; exterior stairs removed; and washer and dryer installed on the exterior of the house. The cited violations apply to rear unit 2501-1/2. 4. Units 2501 and 2501 -1/2 were vacant at the time the application was filed. The last occupants vacated pursuant to voluntary vacancy agreements. 5. The unreinforced masonry foundation of unit 2501 is deteriorated and poses a high seismic risk. There is no evidence of a connection between the foundation and the structure. Unit 2501's non - permitted porch which houses its water heater,.refrigerator, and laundry hookups is substandard and should be removed. The improper conversion of the unit's bathtub to a shower caused water leakage and wood rot damage to the structure. 6. A mold inspection and laboratory analysis shows the presence of high levels of aspergillus /penicillium spores in unit 2501's kitchen, pantry, bathroom, front bedroom closet and front bedroom. Trace amounts of three other mold types were found in some of these areas. Higher levels of spores may indicate the presence of moisture sources and resultant fungal growth. Extensive mold remediation is recommended. 7. Unit 2501 -1/2 lacks foundation footings and shows severe sloping of its existing floors. The later -added bathroom has no foundation and rests directly on LegaI:KJK:432R -C Prop Findings and Conclusions Findings and Conclu6ior, ,Proposed) Removal Permit 432R -C 2501.2nd Street Page 2 grade. Both the applicant's contractor and the Board's consultant conclude that unit 2501 -1/2 cannot be repaired to render it habitable. . 8. Units 2501 and 2501 -1/2 are uninhabitable within the meaning of Rent Control Law section 1803(t)(2)(i). 9. The costs to rehabilitate units 2501 and 2501 -1/2 to render them habitable exceed 50% of the cost of replacement structures. 10. Municipal Code section 8.84.040 provides that when an existing building is in need of rehabilitation at a cost exceeding fifty percent of the replacement cost of the structure, the entire structure must be made to conform to all requirements of the technical codes or it shall be demolished. 11. Units 2501 and 2501 -1/2 cannot be rehabilitated to render them habitable. 12. There is no need to conduct an economic analysis to determine whether it is economically feasible to rehabilitate units 2501 and 2501 -1/2. Legal: KJKA32R -C Prop Findings and Conclusions SANTA MONICA RENT CONTROL BOARD 1685 Main Street, Santa Monica, CA 90401 (310) 458 -8781 REMOVAL PERMIT APPLICATION NOTICE OF DECISION OF RENT CONTROL BOARD CASE NO. 432R -C APPLICANT'S NAME: Plaster Family Trust, Richard H. Plaster, Trustee, Landlord, by Kevin V. Kozal, Esq., HARDING LARMORE KUTCHER & KOZAL, Landlord Representative PROPERTY ADDRESS: 2501 2nd Street DATE OF DECISION: January 14, 2010 The following decision is rendered: [XX] A. Removal permit is granted. [ ) B. Removal permit is denied. A copy of findings of fact and conclusions of law: [XX] is attached. , [ ] will be forthcoming. The Board's decision is final. You may seek judicial review within ninety (90) days of the date of decision in accordance with Chapter 10 of the Rent Control Regulations and Section 1094.5 of the Code of Civil Procedure. The entire record of this hearing is available for inspection at the Rent Control Office, City Hall, Room 202, Santa Monica, CA. Copies sent to: [XX] . Applicant [XX] Applicant's Authorized Representative [ l Date: January 19, 2010 Ntc of Decision - 432R -C- Plaster Family Trust Findings and Conclusions Removal Permit 432R -C 2501 2nd Street Page 1 FINDINGS OF FACT AND CONCLUSIONS OF LAW The Board having considered all the evidence in this matter, including documentary evidence, written and oral arguments and the written and oral presentation of its staff, does hereby adopt the following: 1. The subject property, located at 2501 2nd Street in Santa Monica, was developed with two residential rental units. Unit 2501 is a detached two- bedroom unit at the front of the property; unit 2501 -1/2 is a detached one- bedroom unit at the rear. 2. The property was first registered with the Board on June 12, 1979 by former owners Richard Plaster and Hilary S. Plaster who purchased it on August 12, 1963. Applicant Richard Hilary Plaster, Trustee of Plaster Family Trust indicates the property was inherited upon the death of his parents. 3. On July 23, 2008, the Santa Monica Building and Safety Department's Code Compliance Division issued an Order to Comply that notes general dilapidation and improper maintenance;.a bathroom added without permit; electrical work done without permit; unsafe and uneven floors; deteriorated wood surfaces; exposed plumbing; water heater installed without permit; exterior stairs removed; and washer and dryer installed on the exterior of the house. The cited violations apply to rear unit 2501 -1/2. 4. Units 2501 and 2501 -1/2 were vacant at the time the application was filed. The last occupants vacated pursuant to voluntary vacancy agreements. 5. The unreinforced masonry foundation of unit 2501 is deteriorated and poses a high seismic. risk. There is no evidence of a connection between the foundation and the structure. Unit 2501's non- permitted porch which houses its water heater, refrigerator, and laundry hookups is substandard and should be removed. The improper conversion of the unit's bathtub to a shower caused water leakage and wood rot damage to the structure. 6. A mold inspection and laboratory analysis shows the presence of high levels of aspergillus /penicillium spores in unit 2501's kitchen, pantry, bathroom, front bedroom closet.and front bedroom. Trace amounts of three other mold types were found in some of these areas. Higher levels of spores may indicate the presence of moisture sources and resultant fungal growth. Extensive mold remediation is recommended. 7. Unit 2501 -1/2 lacks foundation footings and shows severe sloping of its existing floors. The later -added bathroom has no foundation and rests directly on grade. Both the applicant's contractor and the Board's consultant conclude that unit 2501 -1/2 cannot be repaired to render it habitable. Legal:KJK:432R -C Findings and Conclusions -FINAL Findings and Cor siu „s Removal Permit 432R -C 2501 2nd Street Page 2 8. Units 2501 and 2501 -1/2 are uninhabitable within the meaning of Rent Control Law section 1803(t)(2)(i). 9. The costs to rehabilitate units 2501 and 2501 -1/2 to render them habitable exceed 50% of the cost of replacement structures. 10. Municipal Code section 8.84.040 provides that when an existing building is in need of rehabilitation at a cost exceeding fifty percent of the replacement cost of the structure, the entire structure must be made to conform to all requirements of the technical codes or it shall be demolished. 11. Units 2501 and 2501 -1/2 cannot be rehabilitated to render them habitable. 12. There is no need to conduct an economic analysis to determine whether it is economically feasible to rehabilitate units 2501 and 2501 -1/2. Legal:KJK:432R -C Findings and Conclusions -FINAL SANTA MONICA RENT CONTROL BOARD 1685 Main Street, Room 202 Santa Monica, California 90401 (310) 458 -8751 NOTICE TO PARTIES. REQUESTING RECORD OF ADMINISTRATIVE PROCEEDINGS (Revised 9 -08) The Board expects payment of a deposit based on the estimated cost of preparing the administrative record before it will prepare the administrative record. Upon receipt of a request for the administrative record, the Board will prepare an estimate of the cost and provide the estimate to the requesting person and the amount of deposit required. Payment of the deposit is expected within 10 days of receipt of the estimated cost of preparing the record. Upon receipt of the required deposit, the Board will prepare the transcript. The administrative record will not be released until the person requesting the record pays the full amount of the actual cost of preparing the record. If the deposit paid exceeds the actual cost of the preparing the record, the balance will be refunded. The requirements in this notice are in accordance with the requirements of Code of Civil Procedure sections 1094.5 and 1094.6. Requests for preparation of administrative records shall be subject to the following procedures: . 1. Time for Preparation of Record: The administrative record will be prepared and delivered to the requesting party within 190 days of a rp oper request, unless the requesting party consents to extend that time. (C.C.P., § 1094.6(c).) 2. Requests Within 10 Days of Final Board Decision: A party delivering a proper request within 10 days of the date of final Board decision will thereby extend the time for filing its petition for writ of administrative mandamus (C.C.P., § 1094.6) until 30 days after the administrative record is delivered to it. 3. Requests Within 90 Days of Final Board Decision: Upon receiving a rp oper request more than 10 days but less than 90 days after final Board decision, the Board will prepare the administrative record as provided in (1), above, but the time for filing a petition for writ of administrative mandamus will not be extended beyond the 90 days after final Board decision as specified in (C.C.P:, § 1094.6(b). 4. Requests More Than 90 Days After Final Board Decision: The Board will not prepare the administrative record upon an otherwise proper request made more than 90 days after the final Board decision unless the party appends a conformed copy of a petition for writ of administrative mandamus filed within the 90 day period after the Board decision. The party must additionally specify whether the delivery of the petition is intended to constitute service of the petition or whether the party intends to serve the petition at a later date. 5. Request for Incomplete Record: A party may, by an otherwise proper and timely request, specify that less than all components of the administrative record be prepared in lieu of the entire record. Such a request will be acted upon in the same manner as a request for preparation of a complete record. However, the Board Ntc of Decision- 432R -C- Plaster Family Trust reserves the right to oppose a petition for writ of administrative mandamus on grounds that a petitioner has failed to provide an adequate record for review of errors alleged in a petition. A party may enter into a stipulation with the Board's legal staff that a partial administrative record be deemed sufficient to allow review, if legal staff is apprised of the specific allegations of error to be presented by a petitioner. 6. Contents of Proper Request: To be deemed proper, a request for preparation of an administrative record must: a. be in writing, typed or printed legibly; b. identify the administrative proceeding by administrative number and title; C. specify the date of final Board decision; d. specify the documents, transcripts, or other matters to be included, and whether such constitute the entire record; e. acknowledge that the requesting person will pay the required deposit based on the Board's estimate of the cost of preparing the record within 10 days of receipt of the estimate, and that the requesting person will furnish payment of the actual cost of preparing the record upon notification of the, actual cost and prior to delivery; f. be signed by the requesting party. The signature of an attorney will not be deemed sufficient unless the attorney expressly states that he or she represents a party and is authorized to request preparation of the record on its behalf. 7. Requests not meeting the foregoing requirements will be returned to the requesting party with an indication of their defects. If the defects are corrected and the request is resubmitted, it will be processed in accordance with the time limits in paragraphs 2 through 4, based on the date of resubmission. 8. Requests for preparation of the administrative record will be irrevocable once received. Responsibility for payment of the actual costs of preparing the administrative record may thereafter be avoided only by special arrangement with the Board or by order of court. Dated: January 19, 2010 Ntc of Decision- 432R -C- Plaster Family Trust TRACY H. CONDON Administrator