A week ago, after the Los Angeles Times broke the story that cracks had started to appear inside and outside the landmark Los Angeles Times buildings in January, and that Metro had prepared a report for Federal regulators, we asked the Los Angeles Planning Department to extend the period of public comment on the Times Mirror Square Draft EIR until that report was made public. The city declined, though it left the door open to accept additional comments.
So we submitted the following public comment on the proposed redevelopment project today.
Department of City Planning
221 North Figueroa Street, Suite 1350
Los Angeles, CA 90012
Re: Case No. ENV-2016-4676-EIR
Times Mirror Square Project
May 19, 2019
Dear Mr. Lamborn,
I am a cultural and architectural historian focusing on Los Angeles in the 20th Century, and the applicant who submitted the Historic-Cultural Monument nomination for Times Mirror Square (Los Angeles Historic-Cultural Monument #1174).
This letter represents the public comment on the above noted Draft EIR both for myself, and for the Historic-Cultural Monument nomination team.
The Project has adverse impacts to the historic Times Mirror Square complex, and should under CEQA’s standards revert to one of the lesser impact Alternatives. A landmark of this caliber should not be subjected to a diminution of its cultural and architectural integrity through demolition of a contributing structure, nor through the creation of an historically inappropriate commercial Paseo.
1. DAMAGE TO TIMES MIRROR SQUARE BUILDINGS CAUSED BY METRO CONSTRUCTION
I write this public comment with a significant disadvantage, not having seen Metro’s report prepared for Federal regulators regarding cracking to interior and exterior walls that has been noted on the Project site as beginning in January 2019. The existence of the damage report was reported in the Los Angeles Times on May 12, 2019 (see attachment 1).
Without knowing the extent of the damage, which is apparently related to ongoing work for the Regional Connector Project, its current and potential future impact on the landmark structures and the cost and time needed to stabilize them before restoration can begin, it is difficult if not impossible to comment appropriately on the proposed Project and its Alternatives.
However, since my request on May 13, 2019 that, in light of the questions raised by the Los Angeles Times’ reporting, the period of DEIR comment be extended for one month was not granted, I will comment on the DEIR as it stands. I appreciate your responding on May 14, 2019 “in accordance with the CEQA Guidelines, that while not required, the Lead Agency may also respond to late comments that are received,” and trust that future public comments will be incorporated into the DEIR as more information is made public.
It is essential that Metro’s report be made available to the public, Office of Historic Resources and the Department of Building and Safety and additional comment taken before any decisions are made on the proposed Project and its Alternatives.
QUESTION #1: Will a full reporting of damage to Times Mirror Square be made available to the public and appropriate city agencies, and additional comment accepted, before this Project moves on to the next stage of the EIR process?
2. SEEMINGLY ARBITRARY DELETION OF BUILDINGS PROTECTED UNDER THE LANDMARK ORDINANCE, OCCURRING AGAINST THE BACKDROP OF AN FBI INVESTIGATION INTO ALLEGATIONS OF PUBLIC CORRUPTION
The process by which Times Mirror Square, the Historic-Cultural Monument impacted by the Project, has moved from the nomination process through the Cultural Heritage Commission, then to the Planning & Land Use Management Committee and then to City Council is highly unusual, and should be noted by the Planning Commissioners.
2a. BACKGROUND ON THE HISTORIC-CULTURAL MONUMENT APPLICATION
More than a decade ago, Ken Bernstein in the Office of Historic Resources informed me that his office would not accept a landmark nomination for anything less than the entire block, Based on this direction, I adjusted my plan to nominate the 1935 Times Building to include the Plant, Mirror and Executive Buildings. This more complex nomination, encompassing the work of three architects and spanning five decades of architectural advances and site history, required significant additional research and the assistance of numerous scholars.
Bafflingly, after the nomination finally was submitted to the Cultural Heritage Commission, the Office of Historic Resources staff report of July 2018, signed by Ken Bernstein and colleagues, stated that the Executive Building, which Mr. Bernstein had explicitly instructed me to nominate, was not significant. The Cultural Heritage Commission disagreed, and demanded that the staff report be amended to note the significance of William L. Pereira (architect of the Executive Building) and publisher Otis Chandler (who commissioned it). In the Commissioners’ opinion, the Times Mirror Square landmark includes the four interconnected buildings.
2b. FBI RAID OF JOSE HUIZAR’S CITY HALL OFFICE AND SUBSEQUENT PLANNING AND LAND USE COMMITTEE HEARING AND CITY COUNCIL VOTE
On November 7, 2018, Los Angeles City Councilman Jose Huizar was raided by the FBI, then removed from his Planning and Land Use Management Committee chairmanship. Nevertheless, on November 27, 2018, the Planning and Land Use Management Committee deferred to Councilman Huizar’s request and altered the landmark nomination by removing the Executive Building. Thus, the nomination reverted to the opinion in the July 2018 Office of Historic Resources staff report and rejected the later determination of the Cultural Heritage Commission to amend the staff report and accept the nomination.
On December 5, 2018, City Council took up the matter of Times Mirror Square’s landmarking as part of a multi-item block vote, and with no comment or discussion, unanimously approved the altered landmark.
2c. REVELATION OF $50,000 DONATION BY TIMES MIRROR SQUARE DEVELOPER TO POLITICAL COMMITTEE ASSOCIATED WITH JOSE HUIZAR
On February 7, 2019, the Los Angeles Times reported that shortly before the Planning and Land Use Management Committee vote, developer Onni Group had donated $50,000 to a political action committee with ties to Councilman Huizar and his wife (see attachment 2). The appearance of a pay-to-play agreement between a politician and developer, in which a landmark was arbitrarily altered by the Planning and Land Use Management Committee in such a way as to ease the development of two towers on the property is deeply troubling, especially against the backdrop of a still developing FBI investigation in which other City Hall figures have been named, and even more so when it threatens the preservation of so iconic a Los Angeles landmark as Times Mirror Square.
Frankly, it smells. Times Mirror Square’s fate should not be decided under a cloud.
QUESTION #2: Will you wait until the ongoing FBI investigation involving Jose Huizar’s activity as the chair of the most powerful land use committee in Los Angeles is resolved before this Project, in which Mr. Huizar took a particular and personal interest, moves on to the next stage of the EIR process?
3. PROJECT ALTERNATIVES
Under CEQA, a project EIR must include a range of plausible alternatives, with the environmentally superior alternative designated as the best option.
3a. PROJECT ALTERNATIVES REFLECTING THE CULTURAL HERITAGE COMMISSION’S DETERMINATION
In the DEIR, there are three Alternatives, which reflect the determination of the Cultural Heritage Commission that the four main structures of Times Mirror Square, not including the Pereira-designed parking garage (see section 4. below), merit preservation.
These Alternatives are:
Alternative 1: No Project / No Build Alternative
Alternative 4: Partial Preservation Alternative
Alternative 5: Full Preservation Alternative
Additionally, these three Alternatives retain the eligibility of the entire Times Mirror Square complex to be listed as an Historic District on the National and California Registers, something that might not still be the case were the Executive Building removed and the west facing facades of the Times, Plant and Mirror Buildings altered with the creation of a commercial Paseo.
Alternative 4 has the additional environmental advantages of Reduction of Solid Waste and Reduction of Energy Use.
QUESTION #3: Will you only consider Alternatives that respect the determination of the Cultural Heritage Commission and treat the Executive Building as a protected historic resource?
3b. PROJECT ALTERNATIVES IGNORING THE CULTURAL HERITAGE COMMISSION’S DETERMINATION
The Alternatives that fail to meet the standards of being environmentally superior are:
Alternative 2: 20 Percent Reduced Density Alternative
Alternative 3: All Office and Residential Alternative
In the case of Alternatives 2 and 3, the architecturally and culturally significant Executive Building would be demolished, thus resulting in the necessity to restore the west facing elevation of Times Building. This facade was lost when the Executive Building was constructed, creating a new, integrated north and west facing elevation representing master architect William L. Pereira’s adaptation of master architect Gordon Kaufmann’s design.
3c. WHY ALTERNATIVES 2 AND 3 ARE ENVIRONMENTALLY INFERIOR CHOICES
Note that the Historic Architectural Resources Survey states that the Executive Building appears to be an historic resource, specifically “The Executive Building appears eligible for listing in the California Register and as a HCM under Criterion 1 for its association with the Times Mirror Company and under Criterion 2 for its association with Otis Chandler.”
The Times Building stood intact for 37 years (1935-72). It has existed in its present form, joined to the Executive Building, for 46 years (1973-present). As explained in detail in the landmark nomination, the Executive Building is the physical manifestation of the Los Angeles Times as a mature, progressive and award-winning newspaper, and of Times Mirror Company as the first media corporation in America, an enormously successful and influential organization. The Executive Building is the only structure in the Times Mirror Square compound associated with Otis Chandler, who transformed the backwater Los Angeles Times into a respected newspaper of national significance. Otis Chandler is explicitly named in the landmark findings, which note that “However, it was under Otis Chandler that the newspaper arguably made its greatest strides in the publication circuit. During his tenure as publisher, from 1960 until 1980, the Times was retooled from a small-scale publication into a nationally-acclaimed news outlet. He professionalized the paper by significantly investing in newsroom staff and expanding into other media markets. It was during this time that the paper was thrust into the front ranks of American journalism. Circulation doubled, and the paper won more Pulitzer prizes under the leadership of Otis Chandler than it had in all other eras combined.”
Any Alternative that requires demolition of the designated historic resource Executive Building erases the property’s association with Otis Chandler, and is inherently inferior to Alternatives that preserve the Executive Building.
Further, the landmark findings state that “Times Mirror Square also ‘represents a notable work of a master designer, builder, or architect whose individual genius influenced his or her age’ as a significant work of master architects Gordon Kaufmann, Rowland Crawford, and William Pereira…. The subject property is… a noteworthy project by Pereira. Throughout his architectural career, Pereira designed few, if any other, additions to existing buildings and the Times-Mirror Headquarters Building represents a unique commission within his body of work.”
Any Alternative that requires demolition of the designated historic resource Executive Building erases the association with William Pereira, and is inherently inferior to Alternatives that preserve the Executive Building.
QUESTION #4: Will you respect the determination of the Cultural Heritage Commission and consider the Executive Building as a protected historic resource, eligible for inclusion on the California Register?
3d. THE UNSUITABLE PASEO PROPOSAL
Finally, Alternatives 2 and 3 each call for the demolition of the Executive Building and the parking garage in order to create space for a block-long commercial Paseo pass-through. Such a development is directly contrary to the history of the site.
In the years following the bombing of the Los Angeles Times Building in 1910, newspaper publisher Harrison Gray Otis, and his successor Harry Chandler, chose to commission buildings that were physically hardened against potential attack. The Times Building is a solid cube of stone, steel and concrete, with few windows and limited means of access. There was never, even before the construction of the Executive Building, any public access along the west facade of the building. To pierce the west facade of the Times Building with commercial storefronts would create a false narrative that diminishes the imposing physical sense of the landmark, and erases the structure’s history as a building that intentionally is somewhat inaccessible and only entered through the Globe Lobby.
QUESTION #5: Will you reject Alternatives that call for demolition of cultural resources including the Executive Building to clear space for any such historically inaccurate Paseo pass-through?
3e. THE MISSING ALTERNATIVE
There is no Alternative presented which breaks down the environmental impacts of Partial Preservation with a taller South tower, preservation of the Executive Building and no Paseo.
QUESTION #6: Will you require the developer to show the impacts of such a Partial Preservation / Taller South Tower Alternative?
4. CORRECTING THE RECORD ON THE MATTER OF THE PARKING STRUCTURE
Finally, note that in Section VI-I (Other CEQA Considerations – Significant Unavoidable Impacts), a footnote states that “on September 20, 2018, the Cultural Heritage Commission recommended the designation of the entire block and found that the Executive Building and parking structure were significant for the association with Pereira.” This is not accurate. The parking structure is not included in my landmarking nomination, and there was no discussion of its preservation during the Cultural Heritage Commission hearings. The commissioners amended the nomination to protect and designate the Executive Building, not the parking structure.
You do not have the power to reverse the Planning and Land Use Management Committee’s seemingly arbitrary decision to declare the Executive Building insignificant. However, you do have the ability to take the unaltered Historic-Cultural Monument, as determined by the Cultural Heritage Commission, as your base for determining historic context. Under this criteria, only Alternatives 1, 4 or 5 are acceptable.
QUESTION #7: Will you respect the determination of the Cultural Heritage Commission and consider the Executive Building as a protected historic resource, eligible for inclusion on the California Register, and not consider Alternatives that call for its demolition?
Thank you in advance for your thoughtful attention to this most complicated, interesting and, dare I say, historic matter before you.
With All My Regards,