City Market and Market Chinatown District
A consortium of property owners and developers in Los Angeles' Fashion District have proposed transforming the once-thriving City Market of Los Angeles into a $1 billion mixed-use complex.
Spanning ten acres, the site would be redeveloped with a hotel, housing, creating office space, retail, and an educational campus. Construction is expected to occur over a twenty-five year period.
The project site contains the potential City Market and Market Chinatown District, which the former Community Redevelopment Agency identified as being eligible for listing in the National Register of Historic Places in 1992. The district was believed to be the largest collection of pre-World War II commercial buildings associated with the Chinese community in Los Angeles.
In the summer of 2012, six months prior to the release of the Notice of Preparation (NOP) for the City Market Los Angeles Project, a large grouping of the original City Market buildings was demolished. The timing of this activity raised a number of questions about the applicant's adherence to the California Environmental Quality Act (CEQA).
As currently proposed, the project would demolish approximately 91,000 square feet of the existing structures and construct up to 1.7 million square feet. Only one of the original City Market buildings (Building 5, 1122 San Julian Street) would be retained and incorporated into the new development.
The Draft Environmental Impact Report (EIR) was released in June 2015. The City published a Recirculated Draft EIR in July 2016 in response to changes in the project's proposed land uses.
The Conservancy is currently reviewing the Final EIR, which was published in May 2017.
In 1992, the Community Redevelopment Agency of Los Angeles (CRA/LA) surveyed historic resources in the neighborhoods known as the Eastside Industrial Area. The CRA/LA identified the potential City Market and Market Chinatown District and determined that it was eligible for listing in the National Register for its associations with the early Chinese produce industry and business community.
At that time, each of the eight original City Market structures was largely intact, and the adjacent City Market Area Chinese Grouping contained twelve nearby structures from the same period of significance. The survey indicated that "further remodeling and demolition pose serious threats to the buildings in this grouping."
Since the 1992 survey, six buildings within the City Market Area Chinese Grouping have been significantly altered or demolished, leaving just half of the original district intact.
The Conservancy is deeply concerned over the pre-emptive demolition of several City Market buildings approximately six months before the release of the Notice of Preparation for the City Market Los Angeles Project. The action represents a flagrant abuse of the California Environmental Quality Act (CEQA), which exists to avoid or minimize adverse impacts through thoughtful consideration of alternative approaches to a project.
The Conservancy also believes that the Draft Environmental Impact Report (EIR) contains flawed analysis and cannot be used for purposes of adequate environmental review. First, the Draft EIR establishes boundaries for a Study Area that do not accurately reflect the presence of potential historic resources. Second, it fails to evaluate the potential significance of and impacts to all structures in the previously identified City Market Area Chinese Grouping. And third, it applies a flawed methodology to the evaluation of a potential historic district and potential district contributors by focusing on thresholds for architectural significance rather than historic or cultural significance.
While the loss of the larger City Market buildings is unfortunate, the 2012 demolition does not negate the significance of what remains. On the contrary, the remaining intact industrial buildings could be seen as even more significant given their rarity.
In our comments on the 2015 Draft EIR, we urged the City to require the preparation of a revised Cultural Resources evaluation and to circulate a Supplemental Draft EIR based on those findings. We pressed the City to mandate consideration of preservation alternatives and mitigation measures.
Though the City published a Recirculated Draft EIR in 2016, it did not include any revisions to its flawed Cultural Resources evaluation. We are deeply disappointed that the City did not use this opportunity to produce a new study on the proposed project's impacts to historic resources and will continue to press for further analysis.