L Park Baldwin City of Industry K Anaheim 22 405 5 N Irwindale La Mirada Heights D Hacienda V WI NONA BL Whittier 10 Beach 210 A Huntington Figure 1 605 60 Cerritos N Norwalk Pico South Rivera Alhambra Pasadena Montebello Pasadena Monterey Park 91 Downey 110 FR Lakewood Paramount 710 Long Beach Angeles National Forest Signal Hill Rock Eagle 2 105 Vernon 405 South Gate Compton Park Gardena Carson 134 5 Huntington Glendale 110 Lake Silver Project Location Map Burbank Hills Torrance Lake Baldwin 101 Toluca 210 Hawthorne Verdes Inglewood North H 10 107 Hollywood Rancho Palos West Lake View Terrace Lake View R City Culver Hollywood 170

D Beverly Hills Beverly Hills 5 Van Airport Nuys Los Angeles Los International San 1 Beach Oaks 0

Redondo Beach 1 Sherman Fernando

Hermosa Beach Manhattan H A R AV R D VLB D 405 El Segund 101 Brentwood PROJECT LOCATION 5 Marina Del Rey Encino Miles Santa Monica 118 1

Proter Ranch DE LONGPRE AVE LONGPRE DE Pacific Ocean Northridge 0

1601-1605 S. Hobart Blvd.





















1600-1608 N. Serrano Ave. V TEW ETSE R N EVA Project Site 400


Scale (Feet)

HAROLD WY HAROLD GARFIELD PL GARFIELD SAI NT AN W 0 Source: Thomas Guide and Parker Environmental Consultants, 2011. Thomas Guide and Parker Environmental Source: Source: Killifer Flammang Architects, Conceptual Design, Level P1 / First Floor Plan, 07/29/2010.

Figure 2 Proposed Site Plan DR


Harold Apartments Community Room 5521 Harold Way

Harold Way

©2012 Google - Map data ©2012 Google -

W Figure 3 - Scoping Meeting Location Map Harold Apartments - Community Room 5521 Harold Way Los Angeles, CA 90027 N N








SCH # 2012031014 Historic Historic Utilities Public ImpactsDetermined Quality Air Greenhouse Gas Emissions Gas Greenhouse Aesthetics Planning and Use Land Noise

A. A. B. C. D. E. F. G. H. Alternatives IV. Significant Than Less IV. IV. IV. IV. IV. IV. IV. (Wastewater) V. Impacts Cumulative Process CEQA Other State Agencies 1. Office of Planning and Research Scott Morgan, Director 1400 10th Street n P.O. Box 3044 Sacramento, CA 95812-3044 Date: March 2, 2012 2. Native American Heritage Commission Dave Singleton, Program Analyst 915 Capitol mall, Room 364 n n Sacramento, CA 95814 Date: March 7, 2012 Attachment: Native American Contact List Local Agencies 3. South Coast Air Quality Management District Ian MacMillan Program Supervisor, CEQA Inter- Governmental Review, Planning, Rule n Development & Area Sources 21865 Copley Drive Diamond Bar, CA 91765-4182 Date: April 4, 2012 4. Los Angeles County MTA Scott Hartwell, CEQA Review Coordinator, Long Range Planning n One Gateway Plaza Los Angeles, CA. 90012 Date: March 20, 2012 5. City of Los Angeles Bureau of Sanitation Ali Poosti, Acting Division Manager n n Wastewater Engineering Services Division Date: March 22, 2012 Other Agencies/Individuals

Coronel Apartment Project Draft EIR Responses to the NOP State Clearinghouse No. 2012031014 Page 1 of 2

City of Los Angeles Department of City Planning ENV-2012-110-EIR April 2012





SCH # 2012031014 Historic Historic Utilities Public ImpactsDetermined Quality Air Greenhouse Gas Emissions Gas Greenhouse Aesthetics Planning and Use Land Noise

A. A. B. C. D. E. F. G. H. Alternatives IV. Significant Than Less IV. IV. IV. IV. IV. IV. IV. (Wastewater) V. Impacts Cumulative Process CEQA Other 6. Los Angeles Conservancy Adrian Scott Fine, Director of Advocacy 523 West Sixth Street, Suite 826 n n Los Angeles, CA 90014 Date: April 4, 2012 7. Armen Makasjian & Associates Armen Makasjian, Commercial Property Appraiser n n n n 5111 Santa Monica Blvd. #205 Los Angeles, CA 90029 Date: March 26, 2012 8. Barry Cohan, General Partner of Serrano Ave LP n n n n Date: March 15, 2012 9. Victor Adjemian P.O. Box 292554 n n n n n Los Angeles, CA 90029 Date: March 12, 2012 10. Doug Haines P.O. Box 93596 n n n n n Los Angeles, CA 90093-0596 Date: March 14, 2012 Source: Parker Environmental Consultants, April 2012.

Coronel Apartment Project Draft EIR Responses to the NOP State Clearinghouse No. 2012031014 Page 2 of 2

South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765-4182  (909) 396-2000

April 4, 2012

Srimal P. Hewawitharana, Environmental Specialist II Department of City Planning, Environmental Analysis Section 200 N. Spring Street, Room 750 Los Angeles, CA 90012

Notice of Preparation of a CEQA Document for the Coronel Apartment Project

The South Coast Air Quality Management District (SCAQMD) appreciates the opportunity to comment on the above- mentioned document. The SCAQMD’s comments are recommendations regarding the analysis of potential air quality impacts from the proposed project that should be included in the draft CEQA document. Please send the SCAQMD a copy of the Draft EIR upon its completion. Note that copies of the Draft EIR that are submitted to the State Clearinghouse are not forwarded to the SCAQMD. Please forward a copy of the Draft EIR directly to SCAQMD at the address in our letterhead. In addition, please send with the draft EIR all appendices or technical documents related to the air quality and greenhouse gas analyses and electronic versions of all air quality modeling and health risk assessment files. These include original emission calculation spreadsheets and modeling files (not Adobe PDF files). Without all files and supporting air quality documentation, the SCAQMD will be unable to complete its review of the air quality analysis in a timely manner. Any delays in providing all supporting air quality documentation will require additional time for review beyond the end of the comment period.

Air Quality Analysis The SCAQMD adopted its Environmental Quality Act (CEQA) Air Quality Handbook in 1993 to assist other public agencies with the preparation of air quality analyses. The SCAQMD recommends that the Lead Agency use this Handbook as guidance when preparing its air quality analysis. Copies of the Handbook are available from the SCAQMD’s Subscription Services Department by calling (909) 396-3720. The lead agency may wish to consider using land use emissions estimating software such as the recently released CalEEMod. This model is available on the SCAQMD Website at:

The Lead Agency should identify any potential adverse air quality impacts that could occur from all phases of the project and all air pollutant sources related to the project. Air quality impacts from both construction (including demolition, if any) and operations should be calculated. Construction-related air quality impacts typically include, but are not limited to, emissions from the use of heavy-duty equipment from grading, earth-loading/unloading, paving, architectural coatings, off-road mobile sources (e.g., heavy-duty construction equipment) and on-road mobile sources (e.g., construction worker vehicle trips, material transport trips). Operation-related air quality impacts may include, but are not limited to, emissions from stationary sources (e.g., boilers), area sources (e.g., solvents and coatings), and vehicular trips (e.g., on- and off-road tailpipe emissions and entrained dust). Air quality impacts from indirect sources, that is, sources that generate or attract vehicular trips should be included in the analysis.

The SCAQMD has developed a methodology for calculating PM2.5 emissions from construction and operational activities and processes. In connection with developing PM2.5 calculation methodologies, the SCAQMD has also developed both regional and localized significance thresholds. The SCAQMD requests that the lead agency quantify PM2.5 emissions and compare the results to the recommended PM2.5 significance thresholds. Guidance for calculating PM2.5 emissions and PM2.5 significance thresholds can be found at the following internet address: Srimal P. Hewawiharana -2- April 4, 2012

In addition to analyzing regional air quality impacts the SCAQMD recommends calculating localized air quality impacts and comparing the results to localized significance thresholds (LSTs). LST’s can be used in addition to the recommended regional significance thresholds as a second indication of air quality impacts when preparing a CEQA document. Therefore, when preparing the air quality analysis for the proposed project, it is recommended that the lead agency perform a localized significance analysis by either using the LSTs developed by the SCAQMD or performing dispersion modeling as necessary. Guidance for performing a localized air quality analysis can be found at

In the event that the proposed project generates or attracts vehicular trips, especially heavy-duty diesel-fueled vehicles, it is recommended that the lead agency perform a mobile source health risk assessment. Guidance for performing a mobile source health risk assessment (“Health Risk Assessment Guidance for Analyzing Cancer Risk from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis”) can be found on the SCAQMD’s CEQA web pages at the following internet address: An analysis of all toxic air contaminant impacts due to the decommissioning or use of equipment potentially generating such air pollutants should also be included.

Mitigation Measures In the event that the project generates significant adverse air quality impacts, CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized during project construction and operation to minimize or eliminate significant adverse air quality impacts. To assist the Lead Agency with identifying possible mitigation measures for the project, please refer to Chapter 11 of the SCAQMD CEQA Air Quality Handbook for sample air quality mitigation measures. Additional mitigation measures can be found on the SCAQMD’s CEQA web pages at the following internet address: Additionally, SCAQMD’s Rule 403 – Fugitive Dust, and the Implementation Handbook contain numerous measures for controlling construction-related emissions that should be considered for use as CEQA mitigation if not otherwise required. Other measures to reduce air quality impacts from land use projects can be found in the SCAQMD’s Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning. This document can be found at the following internet address: In addition, guidance on siting incompatible land uses can be found in the California Air Resources Board’s Air Quality and Land Use Handbook: A Community Perspective, which can be found at the following internet address: CARB’s Land Use Handbook is a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process. Pursuant to state CEQA Guidelines §15126.4 (a)(1)(D), any impacts resulting from mitigation measures must also be discussed.

Data Sources SCAQMD rules and relevant air quality reports and data are available by calling the SCAQMD’s Public Information Center at (909) 396-2039. Much of the information available through the Public Information Center is also available via the SCAQMD’s World Wide Web Homepage (

The SCAQMD staff is available to work with the Lead Agency to ensure that project-related emissions are accurately identified, categorized, and evaluated. If you have any questions regarding this letter, please call Ian MacMillan, Program Supervisor, CEQA Section, at (909) 396-3244.


Ian MacMillan Program Supervisor, CEQA Inter-Governmental Review Planning, Rule Development & Area Sources

IM LAC120306-07 Control Number

April 4, 2012

Submitted electronically Ms. Srimal P. Hewawitharana Environmental Specialist II Los Angeles City Hall 200 N. Spring Street, Room 750 Los Angeles, CA 90012 Email: [email protected]

Re: Notice of Preparation – Coronel Apartment Project – ENV-2012-110-EIR

Dear Ms. Hewawitharana:

On behalf of the Los Angeles Conservancy, we submit these comments on the Notice of Preparation (NOP) of an Environmental Impact Report for the Coronel Apartment Project and the need to consider preservation alternatives that retain the Pueblo Revival style Ehrbar Residence at 1601 N. Hobart Boulevard. The Los Angeles Conservancy is the largest local historic preservation organization in the United States, with over 6,700 members throughout the Los Angeles area. Established in 1978, the Conservancy works to preserve and revitalize the significant architectural and cultural heritage of Los Angeles County through advocacy and education.

I. Architectural significance of Ehrbar Residence, 1601 N. Hobart Boulevard

a. The Pueblo Revival style in Los Angeles

Completed in 1920, the Ehrbar Residence is an early, local example of Pueblo Revival architecture, and appears to be an uncommon representative of this style in the City of Los Angeles. The Pueblo Revival style draws on both Native American and Spanish Colonial prototypes from the American Southwest, referencing one of the few regional architectural forms to develop within the nation’s borders. The emergence of the Pueblo Revival style largely dates from the early years of the twentieth century, with early campus buildings at the University of Albuquerque in and the New Mexico state building at the Panama-California Exposition in in 1915 serving as early notable examples of the style that fostered its popularity in the following decades.

The style is characterized by the massive lines associated with the original prototypes in the American Southwest, and features stuccoed walls, flat roofs, blunt angles and strongly rounded edges on walls and roofs, and projecting volumes which evoke the characteristic massing and adobe construction of the originals.

In the Los Angeles region, the Pueblo Revival style was seldom chosen during the period in which architects were actively designing residences in a wide variety of period revival styles (mid-1910s-1930s). These ranged widely and included those based on European precedents, such as Tudor Revival and French Provincial styles, more exotic choices such as Egyptian Revival, and also the widely popular Spanish Colonial Revival. So seldom is the Pueblo Revival style encountered in Los Angeles from its historic period of development1 that published Los Angeles-based architectural guides and histories do not provide a context for the existence and development of this style in the region.

Two notable regional examples of Pueblo Revival architecture from the years in which period revival architecture was historically popular include the Worrell “Zuni” House (1924), 710 Adelaide Place in Santa Monica and the Andy Anderson House (1938), 22912 Bluebird Drive in Calabasas, both of which serve to illustrate the range of expression achieved with the style. The one-story Andy Anderson House closely follows the rustic stylistic details found on the prototype originals, including wooden vigas and wood lintels over windows. With the Worrell “Zuni” House, architect Robert Stacey-Judd introduced an exotic touch with large, multi-paned windows outlined in a stepped, Mayan-influenced theme found neither among the prototype originals nor within the standard architectural vocabulary of the revival.

Architect Hewitt’s Ehrbar Residence exhibits character defining features of the Pueblo Revival style, including the characteristic massing with projecting volumes, walls with strongly rounded edges at the roof parapet, blunt angles, and battered wall extensions embellishing the building’s corners, which slope inward toward the roof parapet. Architect Hewitt introduced a formal influence through the use of arched, multi-paned windows on the primary elevation and associated spaces.

The occurrence of the Pueblo Revival style in the Los Angeles region, and within the City of Los Angeles in particular, appears to be limited to very few examples. The Ehrbar Residence therefore represents a rare resource type.

b. Architect H. Harwood Hewitt

The architect of the Ehrbar Residence, H. Harwood Hewitt (1874-1926), practiced in Los Angeles between 1913 and 1926 and appears to have had a distinguished career, receiving notable commissions for large residences and estates and for commercial and civic structures throughout the region.

Hewitt is profiled in the Biographical Dictionary of American Architects Deceased from which the following excerpt describes some of his work locally:

In Los Angeles where he established an office in 1913 his best known works were schools, including the Owensmouth (now Canoga Park) High in the San Fernando Valley, and a Parochial School in Los Angeles on La Brea Avenue, near Pico…In

1 A renewed interest in the Pueblo Revival style has occurred in the Los Angeles region, which appears to date from the late 1970s. Examples of Pueblo Revival residential architecture from the 1970s and later exist in communities ranging from Mar Vista and Brentwood in Los Angeles and also in Manhattan Beach.

2 addition he designed a number of fine residences, a notable example of which was the Hanson house in Flintridge. Shorty before his decease Mr. Hewitt completed sketches for what would have been his most important project, a new building for the Los Angeles Ebell Club, completed after his death by the firm of Hunt & Burns.2

Hewitt’s architectural training included studies at the Massachusetts Institute of Technology and also the Ecole des Beaux Arts in Paris, where he graduated with highest honors. In Los Angeles, he became a member, and served as Secretary, of the Allied Architects Association. His local work was profiled often in leading architectural journals and also in the Los Angeles Times, where the Ehrbar Residence received mention.3 His Hanson House in La Canada Flintridge earned him a world prize in architecture through the International Exposition of Architecture and Fine Arts in New York in 1925. Hewitt “also received several awards of honor from the Southern California Chapter of the American Institute of Architects for distinguished work in architectural design.”4

II. The Draft EIR should evaluate a range of reasonable alternatives that retain and reuse the Ehrbar Residence at 1601 N. Hobart Boulevard

A key policy under the California Environmental Quality Act (CEQA) is the lead agency’s duty to “take all action necessary to provide the people of this state with historic environmental qualities and preserve for future generations examples of major periods of California history.”5 CEQA “requires public agencies to deny approval of a project with significant adverse effects when feasible alternatives or feasible mitigation measures can substantially lessen such effects.”6 Courts often refer to the EIR as “the heart” of CEQA because it provides decision makers with an in-depth review of projects with potentially significant environmental impacts and analyzes a range of alternatives that reduce those impacts.”7

As currently proposed, the project would remove four existing 2-story apartment buildings, including the Ehrbar Residence at 1601 N. Hobart Boulevard, originally constructed as a single family residence but currently utilized as a multi-family dwelling. Because the project would involve the demolition of a historic resource, the Draft EIR must evaluate at least one potentially feasible alternative that incorporates the Ehrbar Residence at 1601 N. Hobart Boulevard into the project and retains its eligibility as a historic resource.

The Draft EIR should consider the reuse of Ehrbar Residence, either through continued use as a multi-family dwelling, or as a combination of community room and office space called for in the

2 Withey, Henry F. AIA and Elsie Rathburn Withey. Biographical Dictionary of American Architects (Deceased). Facsimile edition, 1970. Henessey & Ingalls, Inc. Los Angeles, 1956: 282‐283. 3 Attractive Hollywood Home. Los Angeles Times. July 18, 1920: V2. 4 Noted Architect Expires. Los Angeles Times. Jan. 30, 1926: A6. 5 Public Resource Code, Sec. 21001 (b), (c). 6 Sierra Club v. Gilroy City Council (1990) 222 Cal.App.3d 30, 41, italics added; also see PRC Secs. 21002, 21002.1. 7 County of Inyo v. Yorty (1973) 32 Cal.App.3d 795; Laurel Heights Improvement Association v. Regents of the University of California (1993) 6 Cal.4th 1112, 1123.

3 conceptual design within the NOP. Currently the proposed site plan depicts the proposed community room and office spaces located at the east portion of the project, which is the site of the Ehrbar Residence.

The Draft EIR should also examine a reduced density alternative that would retain and reuse the Ehrbar Residence. As proposed in the NOP, the project would result in a net increase of 24 dwelling units. There are currently 30 units at the project site, of which three are at the Ehrbar Residence. Fewer units could allow more flexibility in incorporating the Ehrbar Residence into the project, while at the same time allowing for a reduction in parking spaces and the required size of the subterranean garage.

Because the project site is located in the Vermont/Western Transit Oriented District Specific Plan/Station Neighborhood Area Plan (SNAP), there may be potential for the project to further reduce the number of parking spaces currently proposed.

Thank you for the opportunity to provide comments on the Notice of Preparation for the Coronel Apartment Project. We look forward to reviewing this project further as part of a Draft Environmental Impact Report (DEIR). Please do not hesitate to contact me at (213) 430-4203 or [email protected] should you have any questions or concerns.


Adrian Scott Fine Director of Advocacy



Article 6 -- No Title Los Angeles Times (1886-1922); Jul 18, 1920; ProQuest Historical Newspapers: Los Angeles Times (1881-1988) pg. V2

Reproduced with permission of the copyright owner. Further reproduction prohibited without permission.