4. ENVIRONMENTAL IMPACT ANALYSIS C. CULTURAL RESOURCES 2. HISTORICAL RESOURCES

1. INTRODUCTION This section evaluates potential Project impacts on historical resources and is based on the Historical Resources Assessment Report (Assessment) included in Appendix C‐3 of this Draft EIR. Potential effects on archaeological and paleontological resources are evaluated in Section 4.C.1, Archaeological and Paleontological Resources, of this Draft EIR.

2. ENVIRONMENTAL SETTING a. Existing Conditions The Project Site is located at 6250 West Sunset Boulevard in the Hollywood community of the City of Los Angeles, approximately eight miles northwest of the City’s downtown area and approximately 14 miles northeast of the Pacific Ocean.1 The Project Site is located on parcels identified with Assessor Parcel Numbers (APNs) of 5546‐025‐002 through 011 in the eastern portion of the city block bounded by Sunset Boulevard to the north, Leland Way to the south, commercial uses and North El Centro Avenue to the east, and commercial uses and Vine Street to the west.

Constructed in 1938, the ECT Building was designed by notable Los Angeles Architect Gordon B. Kaufmann (1888‐1949) with interiors by Count Alexis de Sakhnoffsky (1901‐1964) and/or Frank Don Riha (1899‐ 1957) for Earl Carroll (1892‐1948). The massive building is constructed of reinforced concrete with a rectangular footprint and an arched truss roof surrounded by a parapet. The ECT Building is characterized by its flat surfaces and exhibits simple vertical linear detailing in the Moderne style on the front facade. The most historically recognizable detail on the exterior of the building is a concrete and steel single‐story portico with a thin steel marquee, which is supported by a series of five columns. While the massing and footprint of the building are rectilinear, the interior design places heavy emphasis on the use of streamlined curves from the shape of the walls to the design of the handrails. A detailed description and evaluation of the ECT Building is provided in the Assessment included in Appendix C‐3. The ECT Building is historically significant for its association with the development of luxury nightclubs in Hollywood and Earl Carroll as a person who is important to local, , and/or national history, and it is architecturally significant as an excellent example of Moderne architecture and a representative work of architect Gordon B. Kaufmann. The primary period of significance is 1938, the date of construction. The secondary period of significance extends from its construction in 1938 to Earl Carroll’s untimely death in a 1948 plane crash. Because it has been determined eligible for the National Register, and it is eligible for the California Register and as a local Historic‐Cultural Monument, the ECT Building is considered historical resource under CEQA. In 1997, Nickelodeon purchased the Project Site renaming the theater Nickelodeon on Sunset, and currently uses it to film children’s cable television shows. Approximately nine years later, Essex Portfolio, L.P. (Essex Property Trust, Inc.) purchased the property on July 18, 2006 and retained Nickelodeon as a tenant.

1 The ECT Building has the address of 6230 Sunset Boulevard.

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(1) Historical Background (a) Recreation and Entertainment Venues in Hollywood and the ECT Building The ECT Building is historically significant for its association with the development of recreation and entertainment venues in Hollywood. Between 1912 and mid‐1920s, the blocks surrounding Sunset Boulevard and Vine Street were the core of motion picture filmmaking in Hollywood. During the late 1920s and early 1930s the area became associated with radio, television and entertainment venues. The NBC Radio City building was built at the corner of Vine Street and Sunset Boulevard, and the CBS Columbia Square complex was located on Sunset Boulevard and Gower Street, with ABC facilities just south of Sunset Boulevard on Vine Street. Entertainment venues were developed within the midst of this entertainment‐ industry area because entertainment venues were a vital part of the studios’ public relations.

Originally constructed in 1938 by prominent Los Angeles architect Gordon B. Kaufmann, the ECT Building was the pinnacle of night club glamour during Hollywood’s Golden Age. The success of the Earl Carroll theater spurred development of other entertainment venues on Sunset Boulevard, including Florentine Gardens and the . These primary entertainment venues played a significant role in Hollywood’s growth and development. Carroll’s Ziegfield‐like revues brought old Broadway entertainment to California and other important entertainment industry projects on Sunset Boulevard followed. Apart from other nightlife venues, the area of Sunset near the ECT Building was soon lined with the studios of record companies, including Columbia, Decca, and Dot Records.2 Many of these entertainment venues no longer exist either in Hollywood, or on the Sunset Strip in West Hollywood or in Mid‐Wilshire where they were once located. Those that do, such as the ECT Building, Florentine Gardens, and the Palladium, are now a rare architectural building type and figure prominently in the context of the built environment of Hollywood. They belong to a special type of entertainment venues capable of holding very large numbers of patrons for social activities. Their distinguishing characteristics are primarily their interior decoration, the large size and scale of their main public spaces and their box‐like exteriors.

When the ECT Building was first built it “rivaled every nightclub in the world.”3 The theater and the productions it staged represented a larger and more lavish version of American nightlife, and its presence in Hollywood signaled a new era for West Coast entertainment. The Moderne architecture and streamline interior design with its one‐of‐a‐kind ceiling lights and luxury finishes attracted celebrities, tourists, and locals alike, with over two‐million visitors attending shows during the theater’s first decade. By employing forward thinking designers such as Gordon B. Kaufmann, Frank Don Riha, Count Alexis de Sakhnoffsky, Martin Deutsch, Willy Pogany, and Bert Mako, Earl Carroll created a building that exuded modernity and embraced technology and innovation from its unusual lighting system to the mechanics of the revolving stages. The theater’s ten year life span as the Earl Carroll Theater paralleled the rise and fall of big‐ production Hollywood nightlife. When smaller and more intimate clubs became the main draw in the 1940s, Earl Carroll’s stood as one of the few big‐production theaters still drawing large crowds.4 The end of the World War II and the transfer of most local crime syndicates and their gambling money to Las Vegas contributed in part to the decline of the Hollywood nightclub. Indeed, Earl Carroll’s death and the

2 Gregory Paul Williams, The Story of Hollywood: An Illustrated History (Los Angeles: BL Press LLC, 2005): 264‐266. 3 Heimann, Out with the Stars: Hollywood Nightlife in the Golden Era (New York: Abbeville Press, 1985): 171. 4 Ibid., 202.

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March 2015 4.C.2 Historical Resources subsequent closure of his theater signaled the end of such large‐scale dinner theater productions in Hollywood forever.5

Following the death of Earl Carroll in 1948, the golden age of the ECT Building soon faded away and the ECT Building cycled through a number of different occupants and owners who used the Project Site as an entertainment venue, but the shows they staged were not as popular as the original productions produced by Earl Carroll. The ECT Building continued to be used as a performing arts venue and television studio occupied by the Moulin Rouge nightclub, Aquarius Theater, and Center Theater Group‐Mark Taper. These theater companies hosted many productions including Hair, Purple, Lenny, Zoot Suite, and even two live performances by the Doors. During the daytime, the theater operated as a television studio; Jack Bailey’s Queen for a Day was filmed for approximately eighteen years at the Project Site and The Chevy Chase Show was filmed briefly for a few months. Since 1997, Nickelodeon has occupied the Project Site using the ECT Theater to produce children’s cable television shows.

(b) Earl Carroll (1892‐1948) Born in Pittsburgh, Earl Carroll (1892‐1948) led an adventurous life as a composer, producer, director, songwriter, and impresario in New York and Hollywood. Carroll left home at the age of seventeen and traveled the world as a ship stowaway. After the death of his father in 1912, he took a position as a staff writer for a New York publishing company where he began writing songs that earned him recognition, and later served in the US Army Air Force during World War I. After the war, he built a theater in New York City at 7th Avenue and 49th Street, naming it after himself. In 1923, he produced the first “Earl Carroll Vanities” to rival Ziegfeld’s Follies and George White’s Scandals. He achieved fame as the producer and director of Broadway revues, in particular, the "Earl Carroll Vanities," which featured popular songs and showgirls in extravagant, often minimal, costumes. According to biographer Ken Murray, Carroll, nicknamed “Troubadour of the Nude,” invented “pasties” in order for his scantily clad showgirls to circumvent obscenity laws. In 1926, Carroll paid Peggy Hopkins Joyce, a famous New York showgirl, to disrobe on stage in a bathtub of champagne at an after‐hours party, which got him six months in federal prison. The 1929 stock market crash hurt the success of his theater, so Carroll began to produce shows for the road. In 1933, Carroll accepted Paramount’s invitation to produce the 1934 film “Murders at the Vanities,” which featured Beryl Wallace. Because of Carroll’s success in Hollywood he received financial support from Jessie Schuyler, widow of wealthy Beverly Hills banker‐real estate agent Walter Farnum Schuyler, to construct his Hollywood Theater in 1938. He continued to produce over 60 Broadway musicals and films and wrote numerous Broadway stage scores. Carroll died aboard a commercial airliner crash in June 1948 along with his companion and star performer, Beryl Wallace.6

(c) Moderne Style Architecture The geometrically inspired forms of Moderne style (1920 ‐ 1940) has sources in the earlier ‘zigzag’ style as well as the sleek curves of 1920s industrial design and typography. During its heyday, the Moderne

5 Ibid., 218‐219. 6 Historic Resources Group, “Preliminary Assessment of the Property at 6230 Sunset Boulevard: Earl Carroll Theatre,” July 11, 2006. “Earl Carroll,” The Billboard (June 26, 1948): 45. Cecilia Rasmussen, “LA Then and Now: ‘Body Merchant’ Packed Them In,” Los Angeles Times (February 12, 2006). “Three Theater Careers Ended by Tragic Death,” Los Angeles Times (June 18, 1948): 2.

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4.C.2 Historical Resources March 2015 style was widespread and its influence was visible at all scales, from new automobiles, airplanes, trains and ships to delicate household items. The style typically incorporates long curves, teardrop forms, and a streamlined, pared‐down, machine‐like aesthetic. Moderne style architectural detailing references precision, speed, technology and streamlined forms and includes asymmetrical facades, horizontal detailing, flat roofs, and the ample use of curves. Windows often consist of glass block or are framed by rounded shapes, which may curve around walls or run the length of a facade. Common Moderne style surfaces are smooth stucco or concrete, often with grooves or lines, either along walls or as balustrade elements.7 Extant examples of the Moderne style in Hollywood include the Ivar Theater, 1605 Ivar Avenue; commercial building, 6272 Yucca Street; commercial building, 6316 Yucca Street; and Dr. Adams Medical Center, 6634 W. Sunset Boulevard.8

Entertainment venues constructed in Hollywood during the 1920s and 1930s often incorporated high design in a variety of popular styles, such as Art Deco and Moderne, to attract stylish patrons and advertise their modernity. The Moderne style is also associated with Los Angeles’s sustained prominence in automobile and early aerospace industry and culture. Other Moderne style entertainment venues in Los Angeles, included the ‐style Hollywood Palladium, across the street from the ECT Building (extant); Streamline Moderne style NBC Radio City, northeast corner of Vine and Sunset Boulevard (demolished); and Streamline Moderne style Pan‐Pacific Auditorium, 7600 W. Beverly (demolished).

(d) Architect Gordon B. Kaufmann (1888‐1949) Architect Gordon B. Kaufmann (1888‐1949) was a prolific Southern California architect and is responsible for several prominent Hollywood buildings including the Florentine Gardens on Hollywood Boulevard (1938), the ECT Building (1938) on the Project Site, the Hollywood Palladium (1940) directly to the north of the Project Site. Kaufmann was born and educated in London, England, graduating from the London Polytechnic Institute. Kaufmann’s professional career in Los Angeles included a partnership in the firm Johnson, Kaufmann, Coate, which was responsible for the design of many notable public buildings in Los Angeles. Kaufmann later opened and managed his own office.

Kaufmann’s body of work follows stylistic patterns distinctive to Southern California where Mission, Mediterranean and period revival styles of the 1920s shift towards Art Deco, Moderne, and Modernist styles in the 1930s and 1940s. With a portfolio as broad in type and style as the Hoover Dam, Edward L. Doheny, Jr.’s Greystone in Beverly Hills, Claremont College buildings, Scripps College’s original campus, the Santa Anita Race Track, the Times‐Mirror Building, the Athenaeum at Cal Tech, and countless homes, Kaufmann is an architect of unique distinction.

(2) Identified Historical Resources in the Project Vicinity There are twenty‐four (24) previously identified potentially eligible historical resources recorded within the Project vicinity (an approximately 0.25‐mile radius), which are provided in the Assessment in Appendix G. Of the twenty‐four (24) previously identified historical resources, there are thirteen previously identified

7 Virginia and Lee McAlester, A Field Guide to American Houses, (New York: Alfred A. Knopf, 1990):464‐467. 8 Chattel Architecture, Planning & Preservation, Inc., Historic Resources Survey of the Hollywood Redevelopment Area, Prepared for the Community Redevelopment Agency of the City of Los Angeles in collaboration with PCR Services Corporation and LSA Associates, Inc. (February 2010).

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March 2015 4.C.2 Historical Resources individual historical resources that could be indirectly affected by the Project as the result of alteration of their immediate surroundings, as summarized below.

There is one historical resource which is eligible for the National Register, and listed in the California Register and as a Los Angeles Historic Cultural Monument in the Project vicinity:

. CBS Columbia Square (P‐19‐167953): 6121 Sunset Boulevard; International style commercial complex; designated HCM #947 and individual property determined eligible for National Register and listed in California Register (2S3); located approximately 297 feet (0.06 mile) to east of the Project Site; direct view of the Project.

There are five historical resources that appear individually eligible for listing in the National Register in the Project Vicinity:

. Columbia Pictures Corporation: 1438 Gower Street; 1‐and‐2 story Period Revival‐style movie studio constructed circa 1929; appears eligible for National Register as an individual property through survey evaluation (3S); located approximately 726 feet (0.14 mile) to east of the Project Site; distant view of the Project.

. Sunset & Gower Studios: 1440 Gower Street; 2‐and‐5 story Corporate Modern movie studio complex constructed circa 1950; appears eligible for National Register as an individual property through survey evaluation (3S); located approximately 704 feet (0.13 mile) to east of the Project Site; distant view of the Project.

. Hollywood Palladium, 6201 Sunset Boulevard (P‐19‐168084); Streamline Moderne theater constructed in 1940; appears eligible for National Register as an individual property through survey evaluation (3S); located directly across Sunset Boulevard to north of the Project Site; direct view of the Project.

. Pete’s Flowers/Morgan Camera Shop, 6260‐62 Sunset Boulevard; 1‐story Vernacular brick commercial building; appears eligible for National Register as an individual property through survey evaluation (3S); located on the adjacent parcel to west of the project site; the primary view is toward Sunset Boulevard and Pete’s Flowers/Morgan Camera Shop would not have a direct view, but there would be conjunctive views of the Pete’s Flowers/Morgan Camera Shop and the Project from the sidewalk and the Sunset Boulevard.

. Home Savings and Loan: 1500 Vine Street; 2‐story New Formalist bank designed by Millard Sheets constructed in 1967; appears eligible for National Register as an individual property through survey evaluation (3S); located approximately 355 feet (0.06 mile) to northwest of the Project Site; distant view of the Project.

There are three historical resources that appear individually eligible for listing in the California Register in the Project Vicinity:

. Union Western Recorders: 6050 Sunset Boulevard; 2‐story Modern commercial building constructed 1917/1932; appears eligible for California Register as an individual property through survey

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evaluation (3CS); located approximately 1233 feet (0.23 mile) to northeast of the Project Site; distant view of the Project.

. Hollywood Town House Motel: 6055 Sunset Boulevard; Mid‐Century Modern style motel constructed in 1958; appears eligible for California Register as an individual property through survey evaluation (3CS); located approximately 1099 feet (0.21 mile) to east of the Project Site; distant view of the Project.

. Radio City Building: 6087 Sunset Boulevard; 4‐story Art Deco commercial building; appears eligible for California Register as an individual property through survey evaluation (3CS); located approximately 783 feet (0.15 mile) to east of the Project Site; distant view of the Project.

There is one historic district that has been determined eligible for listing in the National Register in the Project Vicinity:

. Afton Square/DeLongpre District (P‐19‐168117): District boundary includes residential properties constructed during 1920s on eastern half of block between Leland Way on the north, El Centro Avenue to the east, DeLongpre Avenue to the south and Vine Street to the west; district determined eligible for National Register by consensus through Section 106 process and listed in the California Register (2D2); located directly to the south of Project Site; four contributors on the south‐side of the 6200 Block of Leland Way (contributors to the district include 6206 Leland, 6214 Leland, 6218 Leland, and 6224 Leland) have direct views of the Project.

There are three ineligible properties that may warrant special consideration in the local planning process in the Project Vicinity:

. 3‐Story Apartment Building: 6250 Leland Way; constructed 1930/1936; property that may warrant special consideration in local planning process (6Q); located approximately 37 feet (0.01 mile) to south of the Project Site; direct view of the Project, across Leland Way to the northeast.

. 1‐story Spanish Colonial Revival Duplex: 6251 Leland Way; construction date unknown; property that may warrant special consideration in local planning process (6Q); located adjacent to Project Site to west; oriented facing Leland Way to south, no direct view of the Project from the front of the property, but there is a direct view from the east facing windows and the backyard.

. 2‐Story Craftsman Bungalow: 6263 Leland Way; constructed 1911/1925; property that may warrant special consideration in local planning process (6Q); located approximately 117 feet (0.03 mile) to west of the Project Site; distant view of the Project.

(3) Historical Resources Identified within the Project Site The ECT Building (P‐19‐168083) has been found eligible for listing in the National Register on three separate occasions. As part of the 1979 Hollywood Revitalization survey, the ECT Building was assigned a CHR status code of 3S or “Appears eligible for NR as an individual property through survey evaluation.”9 The ECT

9 Denver Miller and Christy Johnson, DPR Form: Earl Carroll Theatre, Moulin Rouge, Hullabaloo, 6230 Sunset Boulevard, Hollywood, Prepared for Hollywood Revitalization Committee, Inc. (October 1979).

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Building was again assigned a status code of 3S in 2002.10 In February 2010 during the Hollywood Redevelopment Project Area survey, the ECT Building was again assigned a CHR status code of 3S and was found eligible for listing in the National Register.11

(a) Statement of Significance Since nearly five years have passed since the time of the previous survey, the ECT Building was reevaluated.12 The current architectural description and significance evaluation is included in the Assessment provided in Appendix C‐3 in this Draft EIR. The ECT Building appears to be potentially eligible as an historical resource under criteria A, B, and C of the National Register, criteria 1, 2, and 3 of the California Register, and under the criteria of the Los Angeles Cultural Heritage Ordinance (Los Angeles Administrative Code, Section 22.130) as a Los Angeles Historic Cultural Monument. The ECT Building is significant for its association with a pattern of events regarding the development of luxury nightclubs in Hollywood; with Earl Carroll as a person who is important to local, California, and/or national history; and architecturally, as an excellent example of Moderne architecture and a representative work of architect Gordon B. Kaufmann. The primary period of significance is 1938, the date of construction. The secondary period of significance extends from its construction in 1938 to Earl Carroll’s untimely death in a 1948 plane crash.

(b) Character‐Defining Features Analysis A summary of existing architectural elements, features, materials, finishes and spaces that presently contribute to the eligibility of the ECT Building as a historical resource is presented below. The character‐ defining features of the ECT Building are classified below as significant, contributing and non‐contributing. Significant primary character‐defining features are the most important for the integrity and eligibility of a historical resource. Contributing character‐defining features are secondary and tertiary features that taken together with the primary features convey a property’s significance as a historical resource. Significant primary character‐defining features that retain integrity are from the primary period of significance (1938, the date of construction). Contributing character‐defining features that retain integrity are from the secondary period of significance (1938‐1948, from the date of construction to the death of Earl Carroll). Non‐contributing features are later additions or alterations that do not detract substantially from the integrity or significance of a resource. A detailed character‐defining features analysis is included in the Assessment report in Appendix C‐3 in this Draft EIR.

10 Catherine Barrier, Myra L. Frank & Associates, Inc., DPR Form: Earl Carroll Theater, 6230 Sunset Boulevard, Los Angeles, Prepared for City of Los Angeles Community Redevelopment Area (December 5, 2001). From City of Los Angeles Community Redevelopment Area Historic Survey, Hollywood Redevelopment Plan Update EIR (2002). 11 Tanya Sorrell, LSA Associates, DPR Form: Earl Carroll Theatre, Aquarius Theater, 6230 Sunset Boulevard, Hollywood, Prepared for Community Redevelopment Agency, Inc. (December 18, 2008). From Chattel Architecture, Planning & Preservation, Inc., Historic Resources Survey of the Hollywood Redevelopment Area, Prepared for the Community Redevelopment Agency of the City of Los Angeles in collaboration with PCR Services Corporation and LSA Associates, Inc. (February 2010). 12 Cal. PRC. Code 5024.1(g)(4) If the survey is five or more years old at the time of its nomination for inclusion in the California Register, the survey is updated to identify historical resources which have become eligible or ineligible due to changed circumstances or further documentation and those which have been demolished or altered in a manner that substantially diminishes the significance of the resource. ‐ See more at: http://codes.lp.findlaw.com/cacode/PRC/1/d5/1/2/s5024.1#sthash.L0Ivz5i4.dpuf

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(i) Significant Exterior Features . Massing and Construction, including the rectangular massing and footprint, convex arched truss roof, parapet around the roof perimeter, and reinforced concrete construction. . The west elevation is almost entirely unchanged and includes the smooth, unadorned painted concrete walls, two rows of ribbon windows with steel frames, and primary openings into the lobby underneath porte‐cochère. . The north elevation is also in a substantially original condition consisting of smooth concrete walls with eight vertical groves that were formerly used for zeon13 tubes (removed), two window openings near the west corner, piers between the window openings, concrete curbing running in front of the windows and piers, and a secondary entrance with concrete awning on the east end of the primary (north) elevation. . The east elevation has smooth painted concrete walls. The north portion of the east elevation has smooth concrete walls with vertical groves that were formerly used for zeon tubes (removed) and the rear portion of the wall steps down and is painted board‐formed concrete. . The rear (south) elevation consists of painted board‐formed concrete of the original portion of the rear wall, window openings, and has a double‐door opening into green room on the east portion of the rear wall. . Three bay steel porte‐cochère extending from the west elevation.

(ii) Contributing Landscape . Located to the west of the ECT Building is a parking area contemporary to the original ECT Building. . Low brick wall along the northern lot line extending west from the porte‐cochère.

(iii) Non‐Contributing Exterior Features . 550 square foot addition for toilet rooms and entrance on the west elevation just south of the primary entrance added in 1993. . 7,022 square foot addition on the rear elevation, constructed between 1955 and 1972.14 . Parking kiosk circa 1950s to the west of the porte‐cochère. . Ticket window adjacent to the primary entrance.

(iv) Significant Interior Spaces The lobby is divided into five character‐defining spaces: the Lobby Entry, the Entrance to the Main Lobby, the Main Lobby Passageway, and the East and West Lobby Bar Areas, as described in the following bullet points. The Lobby Entry is the first space a visitor encounters when entering the ECT Building from the primary entrance. The next space is the Entrance to the Main Lobby Passageway, a transition space between

13 Introduced by the General Eclectic Company and Claude Neon Electrical Products Corporation in June of 1938, zeon was a new lighting tube touted as having a low current consumption, it was available in a multitude of colors, and flexible enough to highlight architectural designs and create intricate designs. 14 The rear addition does not appear on 1955 Sanborn Map, but is shown on a 1972 historical aerial, therefore constructed between 1955 and 1972.

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March 2015 4.C.2 Historical Resources the Lobby Entry and the Main Lobby Passageway. The Main Lobby Passageway is a corridor leading the visitor from the Lobby Entry and Entrance to the Main Lobby to the Dining Room and Stage, East and West Bar Areas, or upstairs via the Imperial Staircase to the restrooms/lounges. Located to the north of the Main Lobby Passageway are the East and West Lobby Bar Areas.

. The Lobby Entry spatial arrangement remains intact and has a low ceiling, two sets of stairs flanking semi‐circular counter and podium, and an entrance to secondary office on south wall with original wood door frame. The features include terrazzo on entrance lobby floor and stairs, a lighting well in middle of low ceiling, black structural glass wall and attached fluted column with decorative ceiling molding north of entrance and second fluted column attached to north of stair wall (behind both fluted columns are coves), and the south wall is covered with floor‐to‐ceiling mirrors (replaced‐ in‐kind). The tear‐drop shaped podium has a figural sculpture designed by Martin Deutsch surmounting the east end and consists black structural glass sheathing, original circular handrail fasteners, and semi‐circular canopy covered with brass. The walls of the stairways are sheathed with black structure glass finished with a scalloped design. . The Entrance to Main Lobby has a female figural sculpture designed by Martin Deutsch rising from the east end of the football shaped podium into the main lobby space. The ceiling is high and the west wall is convex to frame the sculpture. Structural glass panels frame the entrance to the stairway and foyer. . The Main Lobby Passageway spatial arrangement remains generally intact; however, the lobby’s south wall is an addition. The existing main lobby originally connected the theater sitting area to the two existing bars and imperial stairway to the second‐floor restrooms/lounges and has a concave north wall and high‐ceiling. The two lobby bar areas are visually separated from the lobby by a row of fluted columns and low‐ceiling. Smoke colored mirrors on the curved wall above stairway to second‐floor restrooms/lounges. Streamline Moderne‐style fluted lighting well located on the underside of the low ceiling above the imperial staircase and below the smoke colored mirrors. Streamline Moderne‐style brass decorative ceiling features flank the fluted light element and are also attached to the top of the columns. . East and West Lobby Bar Areas include the two lobby bar areas (east and west) bisected by a stairway and visually separated from the lobby by a row of fluted columns and low ceiling. The bars are concave in plan and have a black painted wood countertop, wood veneer skirting sectioned by brass vertical elements, and brass foot rail. The columns are constructed of glass and plexy tubing with two brass tubes encircling the capital. There is a wall of mirrors behind the bar above service counter‐top and storage. Two etched glass murals featuring nude women at the west end of the western bar and east end of the eastern bar. . Imperial Staircase to second‐floor restroom/lounges consists of an imperial staircase flanked by stepped curvilinear Streamline Moderne brass handrails leads to a landing where staircases branch to the east and west leading to the respective women’s and men’s restrooms, two fluted columns frame the base of the stairway, and two figural sculptures of women by Willy Pogany flank the staircase landing.

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(v) Contributing Interior Spaces . Women’s Restroom/Lounge (second floor of lounge) retains spatial arrangement and plan of the central lounge with a circular plan that has an alcove and a room for the restroom, rounded stucco walls, ceiling molding, and base board molding, and original door with round light in lounge. . Men’s Restroom/Lounge (second floor of lounge) retains spatial arrangement and plan, lounge area with circular plan and has a decorative ceiling grill, toilet room accessed off of lounge, wood molding around doors, and decorative ceiling grill in lounge. . Dining Room and Stage retains overall open space of former dining room/auditorium, stage floor, concave east wall with opening for boxed seats, closet with machinery and rotating stage staircase, stage machinery, wood truss ceiling, and wood catwalk . Basement Turntable Area consists of wood rotating stage with metal wheels and metal track, turntable machinery to operate rotating stage, and fire‐proof door. . Greenroom (dining room/stage level) retains spatial arrangement and convex walls. . Hair and Makeup Room (dining room/stage level) retains spatial arrangement. . Rear stairway in the southeast corner of the building to dressing rooms consists of spatial arrangement, wood stairs, wood floor and baseboard molding, and wood door and frame. . Dressing Room Hallway (2nd and 3rd floors along eastside of building) consists of spatial arrangement, wood floor and baseboards, and wood molding around doorways. . Second Floor/Northwest Corner Office Suite includes general spatial plan, convex walls, and some wood baseboards. . Third Floor/Northwest Corner Office Suite – Carroll’s Office includes general spatial arrangement, wood baseboards, wood molding around doorways, and observation windows overlooking theater. . Stairs to Basement Kitchen consists of general spatial arrangement, stairway to basement, and wood baseboards.

(c) Setting (i) Significant: Frontal and Oblique Views of the ECT Building from North and West along Sunset Boulevard In its historic setting, the significant character‐defining North façade was always the most public elevation, which was visible from east and west along Sunset Boulevard and had a large Beryl Wallace zeon sign (removed) and signature blocks (removed). The secondary public elevation was the west façade (significant character‐defining elevation) obliquely visible from Sunset Boulevard to the west and has the primary entrance oriented to vehicular drop‐off and parking underneath the porte‐cochère fronting Sunset Boulevard. The setting of the ECT building has not changed significantly despite infill development along Sunset Boulevard. The relationship between the ECT Building and the Hollywood Palladium and CBS Columbia Square is readable as a corridor of Moderne and International style buildings from the 1930s.

(ii) Contributing: Oblique Views From East along Sunset Boulevard and North along Leland Way The contributing character‐defining east (side) elevation is obliquely visible from El Centro Avenue and Sunset Boulevard and partially obscured by a one story‐strip mall at the southwest corner of El Centro

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Avenue and Sunset Boulevard. The east (side) elevation was utilitarian in design and historically there was a neighboring automotive support building located adjacent to the east (side) elevation, as shown on the 1955 Sanborn map. The contributing character‐defining features located on the rear (south) elevation are obliquely visible from Leland Way because of a rear addition and concrete block wall running along the south property line. Also, compared to the other primary elevations, the rear (south) elevation has a utilitarian appearance. As a result, the rear (south) elevation contributes less to the character of the ECT Bbuilding compared to the other elevations. b. Regulatory Framework Historic resources fall within the jurisdiction of several levels of government. Federal laws provide the framework for the identification, and in certain instances, protection of historic resources. Additionally, states and local jurisdictions play active roles in the identification, documentation, and protection of such resources within their communities.

(1) Federal Level (a) National Register of Historic Places The National Register was established by the NHPA as “an authoritative guide to be used by federal, state, and local governments, private groups and citizens to identify the Nation’s cultural resources and to indicate what properties should be considered for protection from destruction or impairment.”15 The National Register recognizes properties that are significant at the national, state, and/or local levels.

To be eligible for listing in the National Register, a resource must be significant in American history, architecture, archaeology, engineering, or culture. Four criteria for evaluation have been established to determine the significance of a resource:

A. It is associated with events that have made a significant contribution to the broad patterns of our history;

B. It is associated with the lives of persons significant in our past;

C. It embodies the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction;

D. It yields, or may be likely to yield, information important in prehistory or history.16

Districts, sites, buildings, structures, and objects that are 50 years in age must meet one or more of the above criteria and retain integrity (this is, convey their significance) to be eligible for listing. Under the National Register, a property can be significant not only for the way it was originally constructed, but also for the way

15 36 CFR Section 60.2. 16 “Guidelines for Completing National Register Forms,” in National Register Bulletin 16, U.S. Department of Interior, , September 30, 1986. This bulletin contains technical information on comprehensive planning, survey of cultural resources and registration in the NRHP.

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4.C.2 Historical Resources March 2015 it was adapted at a later period, or for the way it illustrates changing tastes, attitudes, and uses over a period of time.17 Within the concept of integrity, the National Register recognizes seven aspects or qualities that, in various combinations, define integrity: Location, Design, Setting, Materials, Workmanship, Feeling, and Association.

To retain historic integrity, a property will always possess most of the aspects and depending upon its significance, retention of specific aspects of integrity may be paramount for a property to convey its significance.18 Determining which of these aspects are most important to a particular property requires knowing why, where and when a property is significant.19 For properties that are considered significant under National Register Criteria A and B, National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation (“National Register Bulletin 15”) explains, “a property that is significant for its historic association is eligible if it retains the essential physical features that made up its character or appearance during the period of its association with the important event, historical pattern, or person(s).”20 In assessing the integrity of properties that are considered significant under National Register Criterion C, National Register Bulletin 15 states, “a property important for illustrating a particular architectural style or construction technique must retain most of the physical features that constitute that style or technique.”21

(2) State Level (a) California Register of Historical Resources The OHP, as an office of the California Department of Parks and Recreation (“DPR”), implements the policies of the NHPA on a Statewide level. The OHP also carries out the duties as set forth in the PRC and maintains the HRI and the California Register. The State Historic Preservation Officer (“SHPO”) is an appointed official who implements historic preservation programs within the State’s jurisdictions. Also implemented at the State level, CEQA requires projects to identify any substantial adverse impacts which may affect the significance of identified historical resources.

The California Register was created by Assembly Bill 2881 which was signed into law on September 27, 1992. The California Register is “an authoritative listing and guide to be used by State and local agencies, private groups, and citizens in identifying the existing historical resources of the State and to indicate which resources deserve to be protected, to the extent prudent and feasible, from substantial adverse change.”22

17 National Register Bulletin 15, p. 19. 18 The National Register defines a property as an “area of land containing a single historic resource or a group of resources, and constituting a single entry in the National Register of Historic Places.” A “Historic Property” is defined as “any prehistoric or historic district, site, building, structure, or object at the time it attained historic significance. Glossary of National Register Terms, http://www.nps.gov/nr/publications/bulletins/nrb16a/nrb16a_appendix_IV.htm, accessed June 1, 2013. 19 National Register Bulletin 15, p. 44. 20 “A property retains association if it is the place where the event or activity occurred and is sufficiently intact to convey that relationship to an observer. Like feeling, association requires the presence of physical features that convey a property’s historic character. Because feeling and association depend on individual perceptions, their retention alone is never sufficient to support eligibility of a property for the National Register.” Ibid., p. 46. 21 “A property that has lost some historic materials or details can be eligible if it retains the majority of the features that illustrate its style in terms of the massing, spatial relationships, proportion, pattern of windows and doors, texture of materials, and ornamentation. The property is not eligible, however, if it retains some basic features conveying massing but has lost the majority of the features that once characterized its style.” Ibid., p. 46. 22 PRC Section 5024.1(a).

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The criteria for eligibility for the California Register are based upon National Register criteria.23 Certain resources are determined by the statute to be automatically included in the California Register by operation of law, including California properties formally determined eligible for, or listed in, the National Register.24

The California Register consists of resources that are listed automatically and those that must be nominated through an application and public hearing process. The California Register automatically includes the following:

. California properties listed on the National Register and those formally Determined Eligible for the National Register; . California Registered Historical Landmarks from No. 770 onward; . Those PHI that have been evaluated by the OHP and have been recommended to the State Historical Commission for inclusion on the California Register.25

Other resources which may be nominated to the California Register include:

. Individual historical resources; . Historical resources contributing to historic districts; . Historical resources identified as significant in historical resources surveys with significance ratings of Category 1 through 5; . Historical resources designated or listed as local landmarks, or designated under any local ordinance, such as an HPOZ.26

To be eligible for the California Register, a historic resource must be significant at the local, State, or national level, under one or more of the following four criteria:

1. Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

Additionally, a historic resource eligible for listing in the California Register must meet one or more of the criteria of significance described above and retain enough of its historic character or appearance to be

23 PRC Section 5024.1(b). 24 PRC Section 5024.1(d). 25 Ibid. 26 PRC Section 5024.1(e)

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4.C.2 Historical Resources March 2015 recognizable as a historic resource and to convey the reasons for its significance. Historical resources that have been rehabilitated or restored may be evaluated for listing. Integrity is evaluated with regard to the retention of seven aspects of integrity similar to the National Register, location, design, setting, materials, workmanship, feeling, and association. Also like the National Register, it must also be judged with reference to the particular criteria under which a resource is proposed for eligibility. Alterations over time to a resource or historic changes in its use may themselves have historical, cultural, or architectural significance. It is possible that historical resources may not retain sufficient integrity to meet the criteria for listing in the National Register, but they may still be eligible for listing in the California Register. A resource that has lost its historic character or appearance may still have sufficient integrity for the California Register if it maintains the potential to yield significant scientific or historical information or specific data.27

(3) Local Level (a) City of Los Angeles The City enacted a Cultural Heritage Ordinance in April 1962 which defines City Monuments. According to the Ordinance, City Monuments are sites, buildings, or structures of particular historic or cultural significance to the City in which the broad cultural, political, or social history of the nation, state, or City is reflected or exemplified, including sites and buildings associated with important personages or which embody certain distinguishing architectural characteristics and are associated with a notable architect. These City Monuments are regulated by the City’s Cultural Heritage Commission and the City Council.

(b) Los Angeles Cultural Heritage Ordinance The Los Angeles Cultural Heritage Ordinance (Los Angeles Administrative Code, Chapter 9, Division 22, Article 1, Section 22.171.7) establishes criteria for designating local historic resources as City Monuments. A City Monument is any site (including significant trees or other plant life located on the site), building or structure of particular historic or cultural significance to the City of Los Angeles, such as historic structures or sites:

. In which the broad cultural, economic or social history of the nation, State or community is reflected or exemplified; . Which are identified with historic personages or with important events in the main currents of national, State or local history; . Which embody the distinguishing characteristics of an architectural type specimen, inherently valuable for a study of a period, style or method of construction; or . Which are a notable work of a master builder, designer, or architect whose individual genius influenced his or her age.

A proposed resource may be eligible for designation if it meets at least one of the criteria above.

27 Codified in California Code of Regulations, Title 14, Chapter 11.5, Section 4852(c) which can be accessed on the internet at http://ohp.parks.ca.gov

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When determining historic significance and evaluating a resource against the Cultural Heritage Ordinance criteria above, the Cultural Heritage Commission and the staff of the Office of Historic Resources often ask the following questions:

. Is the site or structure an outstanding example of past architectural styles or craftsmanship? . Was the site or structure created by a “master” architect, builder, or designer? . Did the architect, engineer, or owner have historical associations that either influenced architecture in the City or had a role in the development or history of Los Angeles? . Has the building retained “integrity”? Does it still convey its historic significance through the retention of its original design and materials? . Is the site or structure associated with important historic events or historic personages that shaped the growth, development, or evolution of Los Angeles or its communities? . Is the site or structure associated with important movements or trends that shaped the social and cultural history of Los Angeles or its communities?28

With regard to integrity, the seven aspects of integrity of the National Register and California Register are the same and the threshold of integrity for individual eligibility is similar. However, the threshold of integrity for HPOZs is lower; a contributing structure in an HPOZ is a building that was constructed during the predominant period of development in the neighborhood and that has retained most of its historic features.

3. ENVIRONMENTAL IMPACTS a. Methodology The analysis in this section was conducted by PCR personnel who meet and exceed the Secretary of the Interior’s Professional Qualification Standards in history and architectural history. The key steps taken in completing the Assessment Report which serves as the basis for this section of the Draft EIR are listed below.

. The historical resources evaluation involved a review of the National Register and its annual updates, the California Register, the Statewide Historical Resources Inventory database maintained by the State Office of Historic Preservation (“OHP”) and the California Historical Resources Information System (“CHRIS”), and the City of Los Angeles’s inventory of historic properties to identify any previously recorded properties within or near the Project Site, as well as environmental review assessments for other projects in the vicinity. An intensive pedestrian survey was also undertaken to document the existing conditions of the property and Project vicinity. In addition, the following tasks were performed for the study: . Searched records of the National Register, California Register, California Historic Resources Inventory Database, and City of Los Angeles City Historic‐Cultural Monuments designations.

28 What Makes a Resource Historically Significant? City of LA Office of Historic Preservation, http://preservation.lacity.org/ commission/what‐makes‐resource‐historically‐significant, accessed July 7, 2013.

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. Conducted field inspections of the study area and the ECT Building, and utilized the survey methodology of the State OHP. . Photographed the ECT Building on the Project Site and examined other properties in the area that exhibited potential architectural and/or historical associations. Conducted site‐specific research on the property utilizing building permits, assessor’s records, Sanborn fire insurance maps, City directories, historical photographs, California Index, Avery Index, Online Archive of California, Bison Archives, USC Digital Collections, historical Los Angeles Times, AIA historical directory, and other published sources. Conducted research at the City of Los Angeles Department of Building and Safety and Hollywood Heritage. Contacted Museum of Neon Art, Los Angeles Historic Theater Foundation, and Los Angeles Conservancy. . Reviewed and analyzed ordinance, statutes, regulations, bulletins, and technical materials relating to federal, state, and local historic preservation, designation assessment processes, and related programs. . Evaluated potential historic resources based upon criteria used by the National Register, California Register, and City of Los Angeles Cultural Heritage Ordinance. . Assessed the Project against the CEQA thresholds for determining the significance of impacts to historical resources. b. Thresholds of Significance The thresholds for determining the significance of environmental effects on historical resources are derived from the State CEQA Guidelines as defined in Section15064.5 and the L.A CEQA Thresholds Guide.

According to the State CEQA Guidelines, a project involves a “substantial adverse change” in the significance of the resource when one or more of the following occurs:

. Substantial adverse change in the significance of an historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired. . The significance of a historical resource is materially impaired when a project:

A. Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the California Register of Historical Resources; or

B. Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the PRC or its identification in a historical resources survey meeting the requirements of Section 5024.1(g) of the PRC, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or

C. Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for

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inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.

The L.A. CEQA Thresholds Guide states that a project would normally have a significant impact on a significant resource if it would cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5 of the State CEQA Guidelines when one or more of the following occurs:

. Demolition of a significant resource; . Relocation that does not maintain the integrity and significance of a significant resource; . Conversion, rehabilitation, or alteration of a significant resource which does not conform to the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (“Standards”); or . Construction that reduces the integrity or significance of important resources on the site or in the vicinity.29

Under CEQA, a proposed development must be evaluated to determine how it may impact the potential eligibility of a structure(s) or a site for designation as a historic resource. The Standards were developed as a means to evaluate and approve work for federal grants for historic buildings and then for the federal rehabilitation tax credit (see 36 Code of Federal Regulations (“CFR”) Section 67.7). Similarly, the Los Angeles Cultural Heritage Ordinance provides that compliance with the Standards is part of the process for review and approval by the Cultural Heritage Commission of proposed alterations to City Monuments (see Los Angeles Administrative Code Section 22.171.14.a.1). Therefore, the Standards are used for regulatory approvals for designated resources but not for resource evaluations. Similarly, CEQA recognizes the value of the Standards by using them to demonstrate that a project may be approved without an EIR. In effect, CEQA has a “safe harbor” by providing either a categorical exemption or a negative declaration for a project which meets the Standards (see State CEQA Guidelines Section 15331 and 15064.5(b)(3)).

Based on the above considerations, the factors listed in the L.A. CEQA Thresholds Guide have been reviewed and refined to address both the State and City guidelines. As such, the Project would have a significant impact on historic resources, if:

HIST‐1 The Project would demolish, destroy, relocate, or alter a historical resource such that eligibility for listing on a register of historical resources would be lost (i.e., no longer eligible for listing as a historic resource); or

HIST‐2 The Project would reduce the integrity or significance of important historical resources on the Project Site or in the vicinity such that eligibility for listing on a register of historical resources would be substantially changed.

29 L.A. CEQA Thresholds Guide, Section D.3. Historical Resources, City of Los Angeles, 2006, p. D.3‐1.

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4.C.2 Historical Resources March 2015 c. Project Characteristics As described in Chapter 2.0, Project Description, of this Draft EIR, the Project would construct a new seven‐ story, 90‐foot tall, mixed‐use building on the western portion of the Project Site with approximately 4,700 square feet of ground floor commercial space oriented towards Sunset Boulevard, and 200 residential units located on floors three through seven on Sunset Boulevard and one through seven on Leland Way. The Project would retain the ECT Building, and includes the removal of an approximately 550 square‐foot later non‐contributing addition to the ECT Building, to be replaced with a new canopy designed in conformance to the Standards, removal of a contributing wall fronting Sunset Boulevard and a surface parking area, minor maintenance and upgrades to the ECT Building exterior, such as painting and limited material restoration, and potential interior modifications to support creative office use. A new seven‐story mixed‐use building would be constructed adjacent to the ECT Building on the contributing surface parking area and would have a semi‐public Paseo separating the new building from the ECT Building. d. Project Impacts

Threshold HIST‐1: The Project would result in a significant impact on historical resources if it would demolish, destroy, relocate, or alter a historical resource such that eligibility for listing on a register of historical resources would be lost (i.e., no longer eligible for listing as a historic resource).

Impact Statement HIST‐1: Potential tenant improvements to the interior of the ECT Building could significantly impact the character‐defining features of the ECT Building’s interior such that it would be rendered ineligible for the National Register, California Register, or as a City Monument. With implementation of a recommended mitigation measure, this impact would be less than significant. Other changes proposed by the Project would not have a significant impact on the ECT Building.

The changes proposed by the Project would not materially impair the significance of the ECT Building as a historical resource, since the character‐defining features of the ECT Building from its period of significance would be retained, and the only change to the building would be removal of a non‐contributing 550 square‐ foot 1993 addition located on the west elevation of the ECT Building. As further described in the CEQA Impacts Analysis provided in the Assessment included in Appendix C‐3, removal of a contributing wall located along the north property line, and a contributing surface parking lot, would not materially impair the significance of the ECT Building as a historical resource. The character‐defining porte‐cochère would be retained and incorporated into the Project and vehicular access and parking would be also be included in the Project.

The Project also includes the potential for minor maintenance and upgrades to the ECT Building exterior and potential future tenant improvements to the interior of the ECT Building, including those that could occur to help accommodate creative office use; these improvements would be undertaken in accordance with the Standards. Creative office use, if developed as a use in the future, would continue the historical use of the ECT Building as an entertainment and production venue, and would require minimal change to the ECT Building’s distinctive materials, features, spaces, and spatial relationships, per the Standards. Proposed tenant improvements would be reviewed by a qualified preservation consultant and plans would be reviewed by the City’s Office of Historic Resources, as stipulated in the mitigation measure below (MM‐HIS‐ 1), to ensure interior improvements conform to the Standards such that significant character‐defining historic spaces, features, finishes, art glass and sculpture are preserved. Since the Project proposes selected

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March 2015 4.C.2 Historical Resources rehabilitation to the ECT Building that would conform to the Standards, and would include mitigation to ensure tenant improvements preserve significant character defining features, after Project completion the ECT Building would retain eligibility as a historical resource and the Project would have a less than significant impact on historical resources.

Threshold HIST‐2: The Project would result in a significant impact on historical resources if it would reduce the integrity or significance of important resources on the Project Site or in the vicinity.

Impact Statement HIST‐2: Indirect impacts of new construction on historic resources would be less than significant. The Project would not reduce the integrity or significance of important historical resources on the Project Site or in the Project vicinity.

The new seven‐story building proposed by the Project has the potential to alter the immediate surroundings of the ECT Building by adding height and density to the contributing surface parking area directly to the west. To avoid adverse indirect impacts to the historical and architectural significance of the ECT Building, the Project design of the new seven‐story building maintains the ECT Building as a physical and visual focal point on the Project Site. Through the design of an open‐air Paseo between the ECT Building and the new building proposed by the Project, the ECT Building would retain its integrity and prominence along Sunset Boulevard, and would remain visible from the east and west traveling along Sunset. In addition, the new building is being designed in accordance with Standards 9 and 10; and as such it is compatible in massing, size, scale, and materials of the ECT Building; the contemporary design is distinguished from the historic architecture of the ECT Building; and the new building stylistically references the design and character of the ECT Building. The new building proposed by the Project would remove the contributing parking area and low wall, which are secondary and tertiary contributing features that are not of primary importance, yet the Project would retain the porte‐cochère, a significant primary character‐defining feature that conveys the ECT Building’s historical associations with automobile culture. Parking and vehicular access would be provided by the Project within the new building. As a result, the ECT Building would retain integrity and significance as a historical resource after the contributing parking area and wall are removed. Therefore, because potential indirect effects to the ECT Building would be avoided through compatible design of the new building, compliance with the Standards, and retention of the porte‐cochère, parking, and vehicular access, the Project would have a less than significant indirect impact on historical resources under CEQA.

In summary, as discussed in Section 6.2 of the Assessment, the new building’s size, scale and massing would be compatible with the on‐site historic resource and the ECT Building would retain its historical significance as a prominent entertainment venue in Hollywood, it would remain visually prominent, and would retain its associations to entertainment and automobile culture on Sunset Boulevard. Furthermore, the Project does not propose or anticipate new additions to any historic resources either on the Project Site or in the vicinity of the Project Site. Therefore, indirect impacts to the ECT Building are less than significant.

Indirect impacts were analyzed to determine if the Project would result in a substantial material change to the integrity and significance of historical resources within the Project vicinity. The Project would have no impact on thirteen (13) historical resources with limited distant or direct views of the Project including:

. Columbia Pictures Corporation, 1438 Gower Street, located to the southeast of the Project would have distant views of the Project and would continue to maintain its relationship to the ECT Building.

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A one‐and‐four story AT&T building blocks the view of the Project. Further, the Project would be effectively distanced from this historic resource by El Centro Avenue. For these reasons, the significance and integrity of the Columbia Pictures Corporation would not be materially impaired by alterations to its surroundings caused by the Project. . Sunset & Gower Studios, 1440 Gower Street, located to the east of the Project would have distant views of the Project and would maintain its relationship to the ECT Building. A one‐and‐four story AT&T building blocks the view of the Project. Further, the Project would be effectively distanced from this historic resource by El Centro Avenue and a strip‐mall located at the corner of Sunset Boulevard and El Centro Avenue. For these reasons, the significance and integrity of the Columbia Pictures Corporation would not be materially impaired by alterations to its surroundings caused by the Project. . The three‐story apartment building located at 6250 Leland Way is located to the south of the Project Site on the south‐side of Leland Way. The apartment building would have a direct view of the Project. During the 2010 CRA Hollywood Historic Resources Survey, the apartment building was assigned a 6Q status code, “may warrant special consideration in local planning process.” The apartment building has low integrity. Because of modern infill development and asphalt parking lots, adjacent to the apartment building to the east and west are large asphalt parking lots, the apartment building has been isolated from its historic setting and is a non‐contributor to the adjacent Afton Square/DeLongpre District. Designed in conformance to the Standards, the rear (southern) façade of the Project is compatible to the lower‐scale residential neighborhood along Leland Way, as the ground‐floor residential units would include private street level entryways, balconies, stepped‐back landscaping, and the first two levels would be sheathed in a different color scheme. As a result, the Project respects the historic setting of the apartment building and the Project would not alter the surroundings of the apartment building in a manner that would materially impair its significance as a potential historic resource. . The one‐story Spanish Colonial Revival style duplex located at 6251 Leland Way is located adjacent to Project Site to west. The duplex faces south towards Leland Way. During the 2010 CRA Hollywood Historic Resources Survey, the duplex was assigned a 6Q status code, “may warrant special consideration in local planning process.” The duplex has fair integrity. Because of modern infill development and large asphalt parking lots, adjacent to the duplex to the east and west, the duplex has been isolated from its historic setting and is a non‐contributor to the adjacent Afton Square/DeLongpre District. Designed in conformance to the Standards, the rear (southern) façade of the Project is compatible to the lower‐scale residential neighborhood along Leland Way, as the ground‐floor residential units would include private street level entryways, balconies, stepped‐back landscaping, and the first two levels would be sheathed in a different color scheme. As a result, the Project respects the historic setting of the duplex and would not alter the surroundings of the duplex in a manner that would materially impair its significance as a potential historic resource. . The two‐story Craftsman style bungalow located at 6263 Leland Way is located to the east of the Project Site and would have a distant view of the Project. The bungalow faces south towards Leland Way. During the 2010 CRA Hollywood Historic Resources Survey, the duplex was assigned a 6Q status code, “may warrant special consideration in local planning process.” The bungalow has fair integrity. Because of modern infill development and asphalt parking lots, adjacent to the bungalow to the east and west are large asphalt parking lots, the bungalow has been isolated from its historic setting and is a non‐contributor to the adjacent Afton Square/DeLongpre District. Designed in conformance to the Standards, the rear (southern) façade of the Project is compatible to the lower‐

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scale residential neighborhood along Leland Way, as the ground‐floor residential units would include private street level entryways, balconies, stepped‐back landscaping, and the first two levels would be sheathed in a different color scheme. As a result, the Project respects the historic setting of the bungalow and the Project would not alter the surroundings of the duplex in a manner that would materially impair its significance as a historic resource. Union Western Recorders, 6050 Sunset Boulevard, located on the south‐side of Sunset Boulevard east of the Project would have distant views of Project. The Project would be effectively distanced from this historic resource by El Centro and Gower Avenues. For these reasons, the significance and integrity of the Union Western Recorders would not be materially impaired by alterations to its surroundings caused by the Project. . Hollywood Town House Motel, 6055 Sunset Boulevard, located on the north‐side of Sunset Boulevard east of the Project would have distant views of Project. The Project would be effectively distanced from this historic resource by El Centro and Gower Avenues and infill commercial development along Sunset Boulevard. For these reasons, the significance and integrity of Hollywood Town House Motel would not be materially impaired by alterations to its surroundings caused by the Project. . Radio City Building, 6087 Sunset Boulevard, located on the north‐side of Sunset Boulevard east of the Project would have distant views of Project. The Project would be effectively distanced from this historic resource by El Centro and Gower Avenues and infill commercial development along Sunset Boulevard. For these reasons, the significance and integrity of the Radio City Building would not be materially impaired by alterations to its surroundings caused by the Project. . CBS Columbia Square, 6215 Sunset Boulevard, located across Sunset Boulevard to the northeast of the Project would have direct views of the Project. The Project would not alter the relationship visual relationship between CBS Columbia Square, the Hollywood Palladium, and the ECT Building. These three building constructed between 1937 and 1940 would retain their visual relationships and architectural and historical significance as a grouping of entertainment related properties. Further, the Project would be effectively distanced from this historic resource by El Centro Avenue. For these reasons, the significance and integrity of the CBS Columbia Square complex would not be materially impaired by alterations to its surroundings caused by the Project. . Hollywood Palladium, 6201 Sunset Boulevard, located directly south of the Project across Sunset Boulevard would have direct views of the Project. The new development on the west portion of the Project Site, which would be across Sunset Boulevard from the Hollywood Palladium, is compatible to the ECT Building and historic setting and would not affect existing views of the Earl Carroll Theatre or Hollywood Palladium. Further, the Project would not affect the visual relationship between the Hollywood Palladium and the ECT Building. The development of the Project would not alter the surroundings of the Hollywood Palladium in a manner that would materially impair its significance as a historical resource. . Home Savings and Loan, 1500 Vine Street located at the northeast corner of Vine Street and Sunset Boulevard, northwest of the Project would have no views of the Project. The high‐rise building at 6255 Sunset Boulevard effectively separates the new development from the Home Savings & Loan building; therefore the Project would not alter the surroundings of Home Savings & Loan in a manner that would materially impair its significance as a historic resource. . The boundaries of the Afton Square/DeLongpre District include Leland Way on the north, El Centro Avenue to the east, DeLongpre Avenue to the south and Vine Street to the west. The district has 45 contributing properties. Of those contributors, there are only four contributors located to the southeast of the ECT Building that would have direct views of the Project; these contributors are

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located on the south‐side of Leland Way and include 6206 Leland, 6214 Leland, 6218 Leland, and 6224 Leland. Designed in conformance to the Standards, the rear (southern) façade of the Project is compatible to the lower‐scale residential neighborhood along Leland Way, as the ground‐floor residential units would include private street level entryways, balconies, stepped‐back landscaping, and the first two levels would be sheathed in a different color scheme. After Project completion the Afton Square/DeLongpre District would retain its eligibility for the National Register and listing in the California Register. Therefore, the Project would not alter the surroundings of Afton Square/DeLongpre District in a manner that would materially impair its significance as a historic resource. . Hollywood Legion Stadium, 1628 El Centro Avenue, located northeast of the Project on El Centro Avenue across Selma Avenue would have a limited distant view of the Project. The location is somewhat isolated from the Project Site by existing buildings to its south, most notably a parking structure at the corner of Selma Avenue and El Centro Avenue. Therefore, the Project would not alter the surroundings of the Hollywood Legion Stadium in a manner that would materially impair its significance as a historic resource.

The Project would have a less than significant impact on one (1) historical resource with a direct view of the Project:

. Pete’s Flowers/Morgan Camera Shop, 6260‐62 Sunset Boulevard, is located on Sunset Boulevard adjacent to the Project to the west of the Project. The primary façade of Pete’s Flower/Morgan Camera Shop faces north towards Sunset Boulevard and the Project would not be visible from the shop’s storefront windows, a primary character‐defining feature, and the east elevation of the building is a brick wall with one window. However, it would be possible to have a direct view of the Project from the rear of 6260‐62 Sunset Boulevard which faces south. Constructed in 1938, the design of the Vernacular brick commercial building is attributed to Rudolph Schindler. Character‐ defining features of Pete’s Flowers/Morgan Camera Shop include the footprint, massing, reinforced brick walls, storefronts, storefronts, sign integrated into the primary elevation, and painted sign on the east elevation. The air compressor located on the east elevation is non‐character defining. The seven‐story Project would be constructed adjacent to, but not abutting the eastern elevation of Pete’s Flowers/Morgan Camera Shop, and there would be a clear separation between the Project and Pete’s Flowers/Morgan Camera. The introduction of commercial storefronts on the first‐floor of the new building facing Sunset Boulevard relates to the storefronts of the adjacent Vernacular brick commercial building and the Hollywood Palladium. The storefronts are compatible with the historic development patterns and character of the Project Site’s context on Sunset Boulevard. However, the Project would obscure a deteriorated painted advertisement for the Morgan Camera Shop on the east elevation. The historic setting of Pete’s Flowers/Morgan Camera, also constructed during the same year as the ECT Building, includes the ECT Building and parking area to the east, and as such the massing and painted advertisement on the east elevation of Pete’s Flowers/Morgan Camera has always been visible from Sunset Boulevard. Historically located within the corridor of other entertainment venues, the Morgan Camera Shop’s painted advertisement most likely attracted entertainment industry guests who frequented the Earl Carroll Theater, the Hollywood Palladium, and other businesses in the area. The Project would have an adverse indirect impact on Pete’s Flowers/Morgan Camera Shop by obscuring the character‐defining painted wall sign on the east elevation. However, although obscured, these features would not be physically affected, and the front façade of Pete’s Flowers/Morgan Camera Shop would remain visually prominent. Therefore, after

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Project completion Pete’s Flowers/Morgan Camera Shop would retain its eligibility as an individual resource and impacts would be less than significant. Nonetheless, it is recommended that an updated DPR Survey Form be prepared to record the character‐defining massing and east elevation with the painted advertisement and include a brief written narrative and photographs to ensure information about these features of Pete’s Flowers/Morgan Camera Shop are documented in a City survey. e. Cumulative Impacts Of a list compiled by Crain & Associates of 70 cumulative projects that are planned or under construction in the Project area, eleven may have historic resources located on the same site. They are as follows:

. Cumulative Project 5: Lanewood Condos, 7045 Lanewood Avenue. Location of a historic property built in 1925, which needs to be reevaluated (formerly deemed eligible for listing) (P‐19‐168059, CHR Status Code 7N). . Cumulative Project 9: Quality Restaurant, 6608 W Hollywood Boulevard. Location of S.H. Kress Company Building, which is a contributor to a National Register District (CHR Status Code 1D). . Cumulative Project 10: Hudson Building, 6523 W Hollywood Boulevard. Location of the Holly Cinema, built in 1920, and listed in the National Register and the California Register as a contributor to a District(P‐19‐167557; CHR Status Code 1D, 4/4/85) . Cumulative Project 15: Hotel & Restaurant Project, 6381 W. Hollywood Boulevard. Location of the Security Trust & Savings Bank, built in 1920, and listed in the National Register and the California Register as a contributor to a district (P‐19‐171016; CRH Status Code 1D, 4/4/85). . Cumulative Project 17: Millennium Hollywood Mixed Use, 1744 N. Vine Street. Location of Capitol Records Tower, 1750 Vine Street, built 1954, locally listed Historic‐Cultural Monument #857, and determined eligible for individual listing in the National Register (P‐19‐167595, CRH Status Code 2S2, 8/01/97). Location of H. L. Gogerty Building, 6272‐6284 Yucca Street and 1770 N. Vine Street, built 1930, individually eligible for listing in the California Register (2010 CRA survey, CRH Status Code 3CS). . Cumulative Project 26: CBS Columbia Square Mixed‐Use, 6121 Sunset Boulevard. Location of Columbia Square, CBS, KNXT, built in 1937, which is eligible for listing in the National Register (P‐19‐ 167953, CHR Status Code 3S). . Cumulative Project 33: Mixed‐Use, 5555 Hollywood Boulevard. Location of historic resource built 1914/1940, which appears to be individually eligible for local listing (CHR Status Code 5S3). . Cumulative Project 59: Palladium Residences Project, 6201 W. Sunset Boulevard. Location of a Hollywood Palladium built in 1940, which appears eligible for National Register (P‐19‐168084, CHR Status Code 3S). . Cumulative Project 65: Hotel, 6600 Sunset Boulevard. Location of a historic property built in 1928, which needs to be reevaluated (formerly deemed eligible for listing (P‐19‐168078, CRH Status Code 7N). . Cumulative Project 66: Gramercy Place Private School, 1717 Gramercy Place. Location of the Hollywood Christian Church, built 1922 (P‐19‐167087, CHR Status Code 3S).

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. Cumulative Project 67: Highland Center Mixed‐Use Project, 1600 Highland Avenue. Location of a historic property built in 1919, which is individually eligible for local listing (P‐19‐168025, CHR Status Code 5S2).

The analysis of cumulative impacts to historical resources evaluates whether the impacts of the Project, considered together with impacts of cumulative projects, would be cumulatively considerable and therefore significant. Cumulative impacts would occur if the Project and cumulative projects have combined significant adverse effects on historic resources in the immediate vicinity, contribute to changes within the same historic district, or involve resources that are examples of the same style or property type as those within the Project Site. Significant adverse effects are impacts that would substantially change eligibility of historical resources or districts.

(1) Resources in the Local Vicinity Of the eleven cumulative projects, two are located in the immediate vicinity of the Project. Cumulative Project 26, CBS Columbia Square Project is located across the street from the Project Site on the north side of Sunset Boulevard across El Centro Avenue. Cumulative Project 59, the Palladium Residences Project (6201 Sunset Boulevard), is located on the north side of Sunset Boulevard across the street from the Project Site. The Project and these nearby cumulative projects contain historic structures and contribute collectively to the historic character of 1930s development along Sunset Boulevard.

Both the CBS Columbia Square Project and the Palladium Residences Project, located on the north side of Sunset Boulevard, have placed new development behind the historic Hollywood Palladium and CBS/KNXT buildings. The two buildings would remain significant historical resources and would maintain their spatial relationships with one another, Sunset Boulevard, and to the ECT Building.

The CBS Columbia Square Project, as recently modified and currently under construction would not have significant impacts on historic resources, including the CBS/KNXT building, the Palladium, the Selma La Baig Historic District located to its eastern side and historical resources on Sunset Boulevard and in the project vicinity.30 The CBS Columbia Square Project proposes a mixed‐use development to include a 30‐story residential tower, two six‐story and one two‐story office buildings, 13,500 square feet for a health club, and 39,400 square feet of retail and residential uses. The Project also involves the reuse and rehabilitation of the existing, historically designated Radio Building, Studio A, the Television Building, and Sunset Courtyard according to the Standards. Following the implementation of the Project, adjacent historic resources would retain their eligibility for historic designation and the Columbia Square Project would have a less than significant impact on surrounding historical resources.

CH Palladium, LLC has a current proposal for a mixed‐use development on the Hollywood Palladium parcel that would include the construction of additional buildings on adjacent surface parking lots. The buildings are designed to conform to the Standards, and the project also includes a proposal to rehabilitate and designate the Hollywood Palladium as a HCM. Based on a review of this project, it is expected that it would have a less than significant adverse impact on historical resources because the Hollywood Palladium and the

30 CEQA No.: ENV‐2013‐16‐MND, Addendum to the Environmental Impact Report for the Columbia Square Project, ENV‐2007‐819‐EIR. June 7, 2013

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March 2015 4.C.2 Historical Resources other identified historic resources in the vicinity would retain adequate integrity to remain eligible for listing in the National Register and/or the California Register and/or as Historic‐Cultural Monument.

The remaining cumulative projects are located at distances of approximately 1,400 feet to 5,500 feet from the Project Site, isolated by intervening development and located in a number of locations of varying character and context. Overall, no significant cumulative impact would occur.

(2) Resources Located within a Historic District The Project is not located within a historic district, but is located in close proximity to the Afton Square/DeLongpre District. The boundaries of the Afton Square/DeLongpre District are Leland Way on the north, El Centro Avenue to the east, DeLongpre Avenue to the south and Vine Street to the west. There are four contributors on the southside of Leland Way in close proximity to the Project, however, the Project would not materially impact the significance or integrity of the contributors or the historic district. After Project completion, the Afton Square/DeLongpre District will retain its eligibility as a district determined eligible for the National Register and listed in the California Register. And because the ECT Building is being retained, the ECT Building will retain its eligibility as a historical resource and continue to contribute to the surrounding setting of the Afton Square/DeLongpre District. Therefore, the Project would not have a potential to adversely affect the context or historical resources of a historic district.

(3) Same Architectural Style or Property type The ECT Building is historically significant for its association with the development of recreation and entertainment venues in Los Angeles, and as an outstanding example of Moderne architecture from 1938 designed by architect Gordon B. Kaufmann. The historic structure associated with the 6201 Sunset project (Cumulative Project 59), the Hollywood Palladium is also a Streamline Moderne‐style entertainment venue designed by architect Gordon B. Kaufmann in 1940. Another major entertainment venue, Florentine Gardens, also opened in 1938 at 5955 Hollywood Boulevard as a dinner theater; however, no project is currently proposed for the Florentine Gardens site. The Columbia Broadcasting System (CBS) studio complex built in 1938 at Columbia Square is a functionalist International Style project designed by New York architect William Lescaze, that is significant in Modern architectural design and for its importance in the history of the television and radio broadcasting; however, it is a broadcasting studio and is not representative of an entertainment venue property type or theater. Hollywood is unique for its high concentration of historic resources that are significant in the history of the entertainment industry. Only in Hollywood would two major entertainment venues, the Hollywood Palladium and the ECT Building, be designed by the same architect, and situated across the street from one another, with a major broadcasting studio in close proximity.

As noted above, neither the Project nor the two cumulative projects propose to demolish or alter their respective historic buildings which would retain their eligibility after project completion. All propose to maintain their character defining features. Therefore, the three cumulative projects would retain examples of those features that represent the work of the architect and the architectural style or property type.

(4) Summary The Project, together with cumulative projects, would not significantly affect historic resources in the immediate vicinity, contribute to changes within a historic district, or involve adverse changes to resources

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4.C.2 Historical Resources March 2015 that are examples of the same style or property type as those within the Project Site. The two cumulative projects in the Project’s immediate vicinity would preserve and retain their historic resources as part of their respective developments, as is the case with the ECT Building and the proposed Project. The Project and cumulative projects are not in a historic district, nor would they adversely impact historic districts in the vicinity.

Further, as indicated above, the Project would have a less than significant impact on similar historic resources. With respect to the ECT Building’s status as a representative entertainment venue property type, the Project would retain the ECT Building, which would remain eligible as a historical resource. Therefore, even if there were significant cumulative impacts associated with other cumulative projects’, the Project would not have a cumulatively considerable contribution to cumulative impacts on historic resources.

4. MITIGATION MEASURES Creative office or interior modifications associated with other future uses of the ECT Building have a potential to result in a significant unavoidable impact to the character‐defining features of the ECT Building’s interior, therefore, the following mitigation measure would reduce potential impacts to the ECT Building to a less than significant impact.

MM‐HIS‐1: If the ECT Building is reused as a creative office, or other owner or tenant improvements are proposed that have the potential to materially impair the historical significance of the ECT Building, the improvements shall be designed and undertaken to comply with the Standards. Prior to designing or implementing owner or tenant improvements that have the potential to alter the identified significant character defining features of the building, the owner or tenant, as appropriate, shall engage a qualified preservation consultant to review the proposed improvements and the compatibility of new design and construction components with retained historic features. A qualified preservation consultant is an architectural historian, historic architect, or historic preservation professional who satisfies the Secretary of the Interior’s Professional Qualification Standards for History, Architectural History, or Architecture, pursuant to 36 CFR 61, and has at least 10 years experience in reviewing architectural plans for conformance to the Secretary’s Standards and Guidelines. The preservation consultant shall review the final project plans for conformance to the Secretary of the Interior’s Standards and prepare a memorandum commenting on the projects adherence to the Standards and pertinent preservation recommendations, if any. The memorandum shall be submitted to the City’s Office of Historic Resources for review and approval prior to project approval or issuance of a building permit, if any. The owner or tenant shall undertake and complete construction in a manner consistent with the preservation consultant's and City’s recommendations, and the preservation consultant shall complete and submit a monitoring report to the City at project completion to ensure that the Project meets the Standards to the degree feasible and does not materially impair the historical significance of the ECT Building.

In regards to Pete’s Flowers/Morgan Camera Shop, while adverse impacts to Pete’s Flowers/Morgan Camera Shop would be less than significant, it is recommended that an updated DPR Form be prepared to record the character‐defining massing and east elevation with the painted advertisement. The updated DPR Form should include a brief written narrative and photographs to ensure information about these features is documented in a City survey.

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5. LEVEL OF SIGNIFICANCE AFTER MITIGATION The incorporation of the mitigation measure above (MM‐HIS‐1), would reduce potential direct adverse impacts to the ECT Building from potential future tenant improvements for creative office use to a less than significant impact on historical resources under CEQA.

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