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Home My WebLink About1/8/2020 Item 2, Papp (2) Wilbanks, Megan From:James Papp <jamesralphpapp@hotmail.com> Sent:Wednesday, To:CityClerk; Corey, Tyler Subject:545 correspondence to Planning Commission: exception to the exemption Attachments:545 Higuera PC exception to exemption Cooper Krieger Papp.pdf Sorry for the last minute submittal, just approved by the other signatories. James 1 8 January 2020 Planning Commission City of San Luis Obispo Dear Planning Commissioners: The Community Development Department has claimed a Class 32 (Infill) Exemption from Environmental Review for the four-story hotel, retail, and apartment complex at 545 Higuera/486 Marsh. This letter is presented as a fair argument supported by substantial evidence that an exception to the exemption applies due to cumulative impact (Guidelines 15.300.2.b), both aesthetic and on historical significance (24084.1) on the Dana Street— North Higuera Street neighborhood, developed in the 1860s and 1870s on land owned by Tomás Higuera, Blas Castro, Ramona Carillo de Pacheco de Wilson, and Governor Romualdo Pacheco Jr. (Harris and Ward Map of San Luis Obispo, 1870; San Luis Obispo County Deed Book, Castro-Simmler, 29 June 1865; Wilson and Pacheco–Simmler 27 Nov. 1869) and having in the intervening 150 years maintained a consistent, unified character of low-built, widely-spaced family homes, gardens, outbuildings, and small business buildings. In the last 3 years, 8 new major multi-story, multi-lot projects comprising 43 buildings that dwarf the size and dramatically alter the density of this small but historic neighborhood have been approved or are under construction: the 3-story Modern on Marsh, 4-story Paseo Carmel, 30 2-story prefabs at 546 Higuera, 4½-story Lofts at the Creamery, 4-story San Luis Square, 5-story Vespar Hotel, 4-story Monterey Place, 4-story Palm-Nipomo Parking Structure, and the SLO Repertory Theater. The Palm-Nipomo Parking Structure/SLO Rep was the only one of these with an EIR, concluding “the proposed project would adversely affect the Downtown Historic District by inserting a new visual feature that is inconsistent with the height, scale, and massing of the resources that characterize the historic district.” But the impact on the immediate Dana-Higuera residential section of dramatically lower, smaller, and less dense buildings—is even more severe. Unlike the majority of buildings in the neighborhood, these new projects comprise tens of thousands of square feet each, are built to the lot lines, and are designed predominately as glass, stucco, masonry, or metal boxes. The proposed project at 545 is a typical: a glass and stone box complex fifty times the size of its gabled neighbor, the Robert Pollard House, from 1876 the oldest documented wood frame structure in its original location in the city. North Higuera–Dana neighborhood, Carleton Watkins, 1876 (detail). 2 The block formed by Higuera, Carmel, Marsh, and Nipomo Streets relates to the parallel- angled Dana Street across San Luis Obispo Creek as San Luis Obispo’s original Western residential and light industrial suburb, pictured in Carleton Watkins’ 1876 earliest photograph of the town (Metropolitan Museum of Art). The Norcross House, Jack Carriage House, and Hays-Latimer Adobe are three still extant buildings identifiable in it. The Jack Carriage House is the oldest surviving transport-related building in the city. In the early 1990s, San Luis Obispo’s Cultural Heritage Committee (according to Dan Krieger, then chair) discussed creating a unified historic district of Dana and Higuera. An early concept anticipated connecting them with a physical bridge. Instead, Dana Street and West Monterey (with the Simmler/Butrón, Hays-Latimer, and Heyd Adobes; Anderson, Barneberg, and Nichols Houses; and Harmony Creamery) became attached to the Downtown Historic District, of which they are atypical, and Higuera was orphaned, though with as high a concentration National Register, Master List, and National Register– and Master List–eligible resources as any of the city’s designated historic districts, including CURRENT STRUCTURES WITH HISTORIC DESIGNATION 10 National Register of Historic Places (NRHP) 1 536 Marsh St, Jack House (1878) NRHP contributing 1 536 Marsh St, Jack Wash House (ca 1878) Master List 7 535 Higuera St, Pollard House (1876) 546 Higuera St, Norcross House (1874) Golden State Creamery (1928) 536 Marsh St, Jack House (1878) 536 Marsh St, Jack Wash House (ca 1878) 536 Marsh St, Jack Carriage House (before 1876) 547 Marsh St, Kaetzel House (1905) Contributing List 1 412 Marsh St, Wilkinson House (E. D. Bray, 1915) ELIGIBLE STRUCTURES AND LANDSCAPE 24 NRHP 4 536 Marsh St, Jack Garden (ca 1879) 536 Marsh St, Jack Carriage House (before 1876) 412 Marsh St, Wilkinson House (1915) 497 Marsh St, Pinho House (ca 1887) Master List 7 508 Higuera St, Henry House (before 1903) 514 Parker Cottage (before 1903) 520 Higuera St, Howey Bungalow (after 1916) 525–27 Higuera St, Logan Apartments/Logan Stables (circa 1887 as the 16th District Fair stables, converted 1912 and 1923) 565 Higuera St, Negranti Packard Repair Shop (1928) 3 450 Marsh St, Lima House (ca 1900) 461–63 Marsh St, Firpo Duplex (1926) Contributing List 13 452 Higuera St, Kinkade House (remodel circa 1921) 458–504 Higuera St, Dody Duplexes (1923) (3 buildings) 518 Higuera St, Connolly Cottage (1924) 523 Higuera St, Rogers House (1933) 532 Higuera St, Campbell Refrigeration (ca 1941) 544 Higuera St, Johnston Bungalow (1922) 544 A, B, C, & D, Higuera St, Johnstone Court (1921) (2 structures) 563 Higuera St, Negranti Packard Dealership (late 1930s) 464 Marsh St, Craftsman duplex (now shops and apartments) 567 Marsh St, Smith House (1922) (Sources Historic Permit Archive, Cal Poly Special Collections; Sanborn Maps; Tribune and Telegram reports; and oral histories) These are not only individual historic buildings, they are numerous enough, and retain enough of their original setting, to relate to one another as a California Register–eligible historic district. The 32 listed and eligible buildings of the North Higuera section comprise fifty percent of that area’s buildings, based on a period of significance of 1874–1941 during which its mixed used nature continued to be emphasized by innovative architecture. The fact that North Higuera was not designated as a city historic district is likely class-based, as San Luis Obispo’s current designated residential historic districts are wealthy and purely residential, not mixed use with light industrial, and housed the city’s council members, commissioners, and other movers and shakers when the districts were formed. A much younger district than Dana-Higuera was, ironically, designated the Old Town Historic District. All these buildings in the Higuera section, except for the Jack House, Kaetzel House, Henry House, Logan Apartments, and Craftsman duplex at 464 Marsh, are one-story. The Modern on Marsh next to 464 (below) demonstrates the impact of the flood of new projects on the aesthetics of the North Higuera–Dana neighborhood and the resultant impact to its ability to communicate its significance as a historic district. To refer to the Secretary of the Interior’s Standards on Rehabilitation, the massing, size, scale, and architectural features (or lack thereof) are so incompatible as to jeopardize the historic integrity of these properties and their environment. 4 Craftsman duplex at 464 Marsh (left) and the Modern on Marsh (center) The 36 new 2- to 4½-story buildings approved or built just on this block already outnumber the 32 National Register–, Master List–, and Contributing List–designated and – eligible buildings that define the aesthetic and historic character and continuity of this neighborhood. Without an EIR for cumulative impact, undoubtedly even more will flood in piecemeal with none of the environmental review that the people of the neighborhood and the citizens of San Luis Obispo and of California are entitled to under CEQA and to which the courts have traditionally shown deference. Allan Cooper, AIA Emeritus Professor of Architecture, California Polytechnic State University, San Luis Obispo Former Member, City of San Luis Obispo Planning Commission Dan Krieger, PhD Professor Emeritus of History, California Polytechnic State University, San Luis Obispo Former Chair, City of San Luis Obispo Cultural Heritage Committee James Papp, PhD Architectural Historian, Secretary of the Interior’s Professional Qualification Standards Former Chair, City of San Luis Obispo Cultural Heritage Committee