HOLLYWOOD HERITAGE'S POSTITION ON MILLENNIUM PROJECT

Preservation Issue: Hollywood Heritage's Position on the Millennium Project (Capitol Records Building) proposed for Hollywood. Following a recent meeting, a Hollywood Heritage member contacted our office and asked if we could clarify our position on the proposed Millennium project for the Capitol Records property.  The Board of Hollywood Heritage and its Preservation Issues Committee are continuing to meet with Millennium regarding the project. Our only public position at this time is our response to a draft EIR which is as follows: February 16, 2013 Srimal Hewawitharana, Environmental Specialist II Los Angeles Department of City Planning 200 N. Spring Street, Room 750 Los Angeles, CA 90012 Dear Ms. Hewawitharana: Re: Millennium Hollywood Project, ENV-2011-675-EIR The Board of Directors of Hollywood Heritage, its Preservation Issues Committee and its members, thank you for the opportunity to review and comment on the Millennium Hollywood Project, and the accompanying Draft Environmental Impact Report (DEIR). For three decades Hollywood Heritage has been an advocate of the preservation and protection of Hollywood's historic resources. We support the goal of preserving what is most significant in Hollywood, while encouraging responsible new and infill development. Our organization has nominated many of the current Historic Cultural Monuments, listed the Hollywood Boulevard Commercial and Entertainment District in the National Register of Historic Places at the national level of significance, provided technical assistance to developers and owners of significant properties, and participated in public policy discussions through the formulation of the Community Redevelopment Plan of 1986 and subsequent urban design plans, specific plans and in property entitlement discussion involving historic resources. These efforts have resulted in the rehabilitation of significant landmarks and districts in Hollywood. Our expertise in this area has led us to the conclusion that the Millennium Hollywood project has significant and adverse impacts on a number of Hollywood's historic resources. CEQA guidelines define a project as having a significant environmental impact when the project causes a substantial adverse change in significance of a historical resource as defined in State CEQA Section 15064. The City of Los Angeles CEQA Thresholds Guide (2006, p. D.3-3) also maintains that a project would have a significant impact on historic resources if the project results in a substantial adverse change in the significance of a historic resource by construction that reduces the integrity or significance of important resources on the site or in the vicinity via alteration of the resource's immediate surroundings. While we appreciate some of the mitigation measures designed to preserve the historic Capitol Records and Gogerty Building, we believe that the proposed project would substantively alter the context in which these buildings gained their significance by compromising the immediate surroundings. Portions of the project are grossly out of proportion with the identified resources, thereby minimizing them and irretrievably altering their setting. Additionally, while we appreciate the inclusion of open space, the current design significantly changes the pedestrian environment of Hollywood. Like many previous developments, it draws pedestrians away from the street and irrevocably alters the historic street wall along Vine and Argyle. We also find the current version of the Millennium Hollywood Draft EIR to be deficient in its assessment that the project would not cause an adverse change in significance for the Hollywood Boulevard Commercial and Entertainment Historic District. The heart of Hollywood is listed in the National Register of Historic Places and functions as one of the City of Los Angeles' major tourist destinations and economic engines. The Hollywood Boulevard Commercial and Entertainment Historic District is a 12 block area of the commercial core. The district contains 103 of the most important buildings in Hollywood, listed at the national level of significance in the National Register of Historic Places. The development pattern of the 1920s and 1930s was characterized by the construction of buildings of generally 12 stories at major intersections, flanked by one and two-story retail structures. The District was formally designated by the National Park Service on behalf of the Secretary of the Interior in 1985. At the time, there were over 60 contributors and approximately 40 non-contributors which all dated from the 1905-1935 period of significance. Since its listing, the District has seen significant and positive restorations, now having the largest collection of restored historic theaters in use in the nation. The District can count the beneficial reuse of the Broadway and Equitable Buildings, the Hollywood Professional Building, and the Nash Building, and many restorations, spurring the renaissance of Hollywood. But the District has suffered the loss of several contributors, and has seen the addition of overly-large developments such as Hollywood and Highland, the W Hotel and Madame Tussaud's. The current Millennium Hollywood project fails to significantly address the negative impact created by the mass and height of the proposed development in regards to the existing structures in the vicinity. This will be the largest tower in the area. While creating opportunities to see landmarks such as the Hollywood Sign from areas within the development, the project fails to address the fact that these new view lines will alter views that have been publicly available since the inception of these landmarks. In the "Related Projects" section of the DEIR, which compares this project with other projects nearby, unapproved, proposed developments are used alongside existing structures, allowing the square footage increase that this project suggests to be seen as more reasonable. However, the structures included on the comparative chart are all less than one-third the size of the proposed Millennium tower. The only project that is as large is the proposed redevelopment of the Paramount Studios Lot. At 1,385,700 sq. ft., the Paramount Lot is a much larger property and does not have any single building of a comparative height as proposed by Millennium. The addition of the proposed tower will overwhelm contributing properties in the district and the proposed "separation" of new and old construction is simply not an adequate mitigation measure. Hollywood Heritages appreciates the efforts of the project's developers and will work diligently with them to ensure the preservation and protection of all of Hollywood's historic resources. Sincerely, Bryan Cooper President, Hollywood Heritage, Inc.