HomeMy WebLinkAboutItem 12 - Review of an Appeal by San Luis Architectural Protection (545 Higuera & 486 Marsh)Item 12
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Council- d. Report
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Department Name:
Cost Center:
For Agenda of:
Placement:
Estimated Time:
FROM: Michael Codron, Community Development Director
Prepared By: Shawna Scott, Senior Planner
Community Development
4003
June 2, 2020
Public Hearing
60 minutes
SUBJECT: REVIEW OF AN APPEAL (FILED BY SAN LUIS ARCHITECTURAL
PROTECTION) OF THE PLANNING COMMISSION'S DECISION TO
APPROVE A FOUR-STORY MIXED -USE PROJECT CONSISTING OF 5,241
SQUARE FEET OF GROUND -FLOOR RETAIL, EIGHT HOTEL SUITES,
AND 39 RESIDENTIAL UNITS WITH A REQUEST FOR A THREE -LEVEL
MECHANICAL PARKING LIFT SERVING 48 SPACES, A FOURTH -FLOOR
ROOF DECK, AND ASSOCIATED TREE REMOVALS, WITH A CLASS 32
(INFILL) EXEMPTION FROM ENVIRONMENTAL REVIEW (545 HIGUERA
STREET AND 486 MARSH STREET)
RECOMMENDATION
Adopt a resolution (Attachment A) denying the appeal and upholding the Planning
Commission's approval of a new four-story mixed -use project with 5,241 square feet of ground -
floor retail, eight hotel suites, and 39 residential (apartment) units, with a request for a three -level
mechanical parking lift serving 48 spaces, a fourth -floor roof deck, and associated tree removals.
REPORT -IN -BRIEF
The applicant, Taylor Judkins, submitted an application for a new four-story mixed -use project
located in the Downtown Commercial (C-D) zone. The Architectural Review Commission
(ARC) reviewed the proposed project on September 9, 2019 and October 21, 2019 for
consistency with the Community Design Guidelines (CDG) and voted to recommend approval of
the project with additional direction for minor modifications (7-0). Following the ARC meeting,
the applicant submitted revised plans to address the ARC's recommendations for the Planning
Commission's (PC) consideration (Attachment B). On January 8, 2020, the PC reviewed the
proposed project, and a motion passed (5-2) to continue the item to a date uncertain with
direction provided to the applicant, related to consistency with the CDG. The applicant
incorporated design changes to the project, which were reviewed by the PC, resulting in the PC's
approval of the project on February 26, 2020 (4-2-1) (Attachment C).
The scope of this report is to provide an evaluation of the project in terms of its consistency with
the City's General Plan, Zoning Regulations and Design Guidelines and other applicable City
policies and standards. The Council is being asked to review the proposed project in
consideration of the appeal, however, the review is considered de novo and Council is not limited
to acting on the items brought up in the appeal.
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Based on the analysis set forth below, staff is recommending the City Council deny the appeal,
thereby upholding the Planning Commission's approval of the project, and approve the waiver of
development standards to allow increased height and lot coverage, as requested by the Applicant
(Attachment D). If the Council denies the appeal, the project will have the necessary entitlements
needed to move forward for building permits. While the staff recommendation is to deny the
appeal and approve the project, the City Council may choose to uphold the appeal. If the City
Council chooses to uphold the appeal and deny the project, or approve the project with reduced
density, special findings are needed as required by State law to form an adequate basis for the
action. Should the Council want to pursue either of these options, specific direction should be
provided so that Staff can return during a future meeting with the necessary findings. The
following discussion provides additional background and analysis of the proposed project and
the appeal.
DISCUSSION
Site Information and Setting
The project applicant is Taylor Judkins, G3 Concepts and he is represented by Ten Over Studios.
The 0.79-acre project site consists of two parcels located between Higuera and Marsh Streets,
within the Downtown Planning Area (Downtown Commercial zone). Surrounding uses include
offices, a bank, commercial uses, a senior living facility, and residential uses. Surrounding zones
include Commercial Retail to the north, south, and west, and Downtown Commercial to the
north and east. Historic structures in the immediate vicinity include the Pollard House (adjacent
to the site, to the southwest), the Norcross House (across Higuera Street, to the north), and the
Jack House and Gardens (approximately 100 feet to the east).
Proposed Project
The proposed mixed -use project consists of two buildings, each up to 50 feet in height,
connected by an unenclosed bridge on the fourth floor. Parking would be provided within a
ground -floor garage, and surface parking spaces (totaling 74 vehicle spaces). The mechanical
parking lifts would be located within the garage. The proposed development would consist of the
following:
Building A: 3,198 square feet of retail space fronting Higuera Street; three studio units (448 to
530 square feet in size), six one -bedroom units (671 to 874 square feet in size), and three two -
bedroom units (938 to 1,001 square feet in size); eight hotel suites (372 to 1,260 square feet in
size); wrap -around walkways and decks; private balconies; and, a long-term bicycle storage
room.
Building B: 2,043 square feet of retail space fronting Marsh Street; five studio units (447 to 629
square feet in size), 14 one -bedroom units (700 to 807 square feet in size), and eight two -
bedroom units (798 to 1,174 square feet in size); wrap -around walkways and decks; a 705-square
foot roof deck on the fourth floor; private balconies; and, an enclosed garage and three -level
mechanical parking lift (48 spaces).
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Site Improvements: The existing non -historic buildings onsite would be demolished, and trees
proposed for removal include one jacaranda, three Chinese elms, two carrot wood trees, one
bottlebrush tree, and one Pyrus tree. Existing Chinese Pistache and New Zealand Christmas
street trees would remain, in addition to existing parking lot trees adjacent to the bank to the
northeast. Proposed site landscaping includes 19 strawberry trees (10 to 15 feet in height at
maturity), seven coral gum eucalyptus (36 feet tall at maturity), five forest pansy redbud trees
(20 feet tall at maturity), one Chinese Pistache (25 feet tall at maturity), and a variety of shrubs.
A decorative paver walkway and patios would surround the proposed buildings. An artificial turf
play area, pea gravel patio, and sitting bench are proposed adjacent to the southwest side of
Building A; this public area would be located behind a proposed six-foot tall wood screen wall.
The existing access drive between Marsh and Higuera Streets would remain, and a crosswalk
with decorative pavers is proposed between the new buildings and the shared parking area to the
northeast; this walkway is also intended to accommodate a future connection to the Jack House,
as envisioned in the Downtown Concept Plan'. Short-term bicycle parking would be provided
adjacent to each building.
Proiect Phasing: The applicant proposes to construct the project in phases. The first phase
would consist of the construction of Building B, followed by the construction of Building A.
Recommended condition of approval 12 would require submittal of a Construction Phasing Plan
to ensure trash/recycling, provision of parking, and other potential temporary effects would be
addressed during construction of the project.
Previous Advisory Body Action
On January 8, 2020, the Planning Commission reviewed the proposed project, and a motion
passed (5-2) to continue the item to a date uncertain with direction provided to the applicant,
related to consistency with the CDG. The applicant incorporated design changes to the project,
which were reviewed by the Planning Commission, resulting in the Planning Commission's
approval of the project on February 26, 2020 (4-2-1).
The ARC reviewed the proposed project on September 9, 2019 and October 21, 2019 for
consistency with the CDG and voted to recommend approval of the project with additional
direction for minor modifications (7-0-0). Following the ARC meeting, the applicant submitted
revised plans to address the ARC's recommendations for the Planning Commission's
consideration.
Policy Context
Land Use Element
The project is consistent with the General Plan Land Use Element,2 because: the proposed retail,
hotel, and residential uses are consistent with uses intended for the Downtown area (Land Use
Element Policies 3.8.5, 4.1, and 4.2.1); as proposed and conditioned the project incorporates
landscaping, setbacks, and step -backs to provide a protection of existing residential uses (Land
Use Element Policy 4.2); and, the project includes public gathering space, onsite walkways and
' Downtown Concept Plan: https://www.slocily.org/government/department-directory/community-
development/plannin -zonin specific-area-plans/downtown
2 City of San Luis Obispo Land Use Element: https://www.slocity.org/home/showdocument?id=6635
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paths, and connections to sidewalks (Land Use Element Policies 4.4 and 4.5). The project is
compatible with historically significant and other existing buildings in the immediate
neighborhood (Land Use Element Policies 4.16 and 4.20.4). The project is consistent with
General Plan Land Use Element Policy 2.2.7, because the project is located within a half -mile of
an existing transit stop, and is proximate to bicycle routes, parks, open space, and commercial
uses.
Appeal
On March 9, 2020, Babak Naficy, Attorney filed an appeal on behalf of San Luis Architectural
Protection ("SLAP") and Save Our Downtown ("SOD") of the Planning Commission's decision
to approve the proposed project (Attachment D).
Staff Analysis of Appeal Letter
Staff has provided an analysis below of the points outlined in the Appeal Letter.
The project is not consistent with the Community Design Guidelines (CDG).
The appellant states that the proposed project is inconsistent with the Community Design
Guidelines, citing specific guidelines contained within CDG Chapter 5 (Residential Project
Design), including 5.3.A.1, 5.3.13, 5.3.C, 5.4.A.1, 5.4.A.3, 5.4.C.1, 5.4.C.2. The CDG states that
Chapter 5 guidelines apply to "the design of new residential subdivisions and to multi -family and
clustered residential projects.... single-family homes on sensitive sites, vacant infill parcels, and
that are proposed as replacement structures within established neighborhoods."
The proposed mixed -use project is located within the Downtown Commercial (C-D) zone;
therefore, the appropriate and applicable CDG Chapter is Chapter 4 (Downtown Design
Guidelines). The CDG states that "the primary goal of the following downtown design guidelines
is to preserve and enhance its attractiveness to residents and visitors as a place where: people
prefer to walk rather than drive; and where the pleasant sidewalks, shading trees, and variety of
shops, restaurants, and other activities encourage people to spend time, slow their pace, and
engage one another. The design of buildings and their setting, circulation, and public spaces in
the downtown have, and will continue to play a crucial role in maintaining this character and
vitality. Another principal goal of these guidelines is to implement the vision of the downtown
Conceptual Physical Plan [Downtown Concept Plan] wherever feasible."
The appellant also cites inconsistency with CDG 1.4(A)(4), which states:
1.4 — Goals for Design Quality and Character
A. Keep San Luis Obispo architecturally distinctive, don't let it come "anywhere USA. "
4. Design with consideration of the site context in terms of the best nearby examples
of massing, scale, and land uses when the site is located in a notable area of the
city (for example, the Downtown, Old Town).
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The CDG states that: "the ARC may interpret these design guidelines with some flexibility in
their application to specific projects, as not all design criteria may be workable or appropriate for
each project. Guidelines that contain `should' language will be followed unless not doing so will
result in better implementation of other guidelines or General Plan policies. The overall objective
is to ensure that the intent and spirit of the design guidelines are followed."
As described in the February 26, 2020 Planning Commission Agenda Report, the proposed
project includes a two-story fagade facing Higuera Street (proximate to the historic Pollard
House) and provides a visual transition between this project site and one and two-story buildings
immediately adjacent to the project site. In response to Planning Commission direction at the
January 8, 2020 hearing, the applicant had revised the project to incorporate a variety of revised
elements, which reduce the apparent massing of the structure by better reflecting pedestrian -scale
elements present in the Downtown, and complementing elements of historic structures present
within the area. The most prominent project revision was the use of brick and stucco materials,
which are more commonly found throughout the Downtown and demonstrate improved
compatibility with the neighborhood.
The plans reviewed by the Planning Commission on February 26, 2020 incorporate a variety of
exterior changes intended to promote consistency with the CDG. The proposed revisions that
promote improved neighborhood compatibility and preservation of the historic character of the
downtown area, and soften the overall appearance of the buildings include: limestone material is
replaced by brick, and metal and wood siding materials are replaced by smooth -finished stucco,
consistent with Downtown Design Guidelines for finish materials; the shape, size, orientation,
framing, and location of the windows has been modified to reflect existing vertically -oriented
windows on neighboring buildings, the windows on all elevations will be consistent, and clear
glass is proposed; revised window design incorporates larger window headers (light in color) and
a reduction in the metal and glazing between windows; the material between the second and
third -floor windows would match the window frame to further enhance the vertical composition
on the elevation; a bulkhead is incorporated into the stepped -back storefront (which also reduces
the size of the storefront windows) on the north elevation of Building B; the application of
vertical rather than angular canopy posts to better reflect linear posts present on proximate
buildings; addition of an awning on the north elevation of Building A; overall massing is broken
down with decks and balconies, additional decks and balconies are shown on the second and
third floors, and modification of balcony railings from metal and glass to all metal; and the use of
lighter shades of tan, particularly on the second and third floors (compared to the previously
proposed project).
The sum of these exterior changes would result in improved compatibility with the surrounding
area while allowing for the project to maintain its own identity, consistent with the CDG. In
addition to improved consistency with the CDG, the proposed changes also promote visual
compatibility with the surrounding area, and maintain the visual character of the neighborhood,
particularly this southern extent of the Downtown.
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Based on the applicant's previous revisions and a condition of approval requiring further
refinement of exterior materials through review by staff and the Community Development
Director upon submittal of building permits, staff recommended and the Planning Commission
found the project consistent with the CDG and applicable regulations, guidelines, and standards.
2. The project is not exempt from the California Environmental Quality Act (CEQA) because
it may cause a substantial adverse change in the significance of "historic resources,"
particularly the Pollard House, Norcross House, and Pinho House.
State CEQA Guidelines Section 15300.2 (Categorical Exemptions, Exceptions) states that: A
categorical exemption shall not be used for a project which may cause a substantial adverse
change in the significance of a historical resource. The State CEQA Guidelines specifies how to
determine if there would be a significant impact to a historical resource, and states the following:
15064.5 (b) (Determining the Significance of Impacts to Archaeological and Historical
Resources): A project with an effect that may cause a substantial adverse change in the
significance of an historical resource is a project that may have a significant effect on the
environment.
• 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 an historical resource is materially impaired when a project:
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, local register of historical resources.
The SWCA Historic Preservation Report and Historical Compatibility Improvement Letter
prepared for the project: 1) does not identify a substantial adverse change as defined by CEQA;
and 2) states that none of the adjacent historic properties and none of the more distantly located
historic properties will be subject to any indirect impacts that threaten their eligibility as
significant historical resources.
Therefore, pursuant to the State CEQA Guidelines, the project would not cause a substantial
adverse change in the significance of an historical resource and would not have a significant
effect on the environment.
3. Owing to unusual circumstances, the project is capable of causing a significant adverse
impact on historical resources unlike a typical "infill project" this project is surrounded by
historically significant structures in a neighborhood that has a strong historic feel.
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The project is consistent with the General Plan, which identifies the role of the Downtown as
followed: Downtown is the community's urban center serving as the cultural, social,
entertainment, and political center of the City for its residents, as well as home for those who
live in its historic neighborhoods. The City wants its urban core to be economically healthy, and
realizes that private and public investments in the Downtown support each other.... Downtown's
visitor appeal should be based on natural, historical, and cultural features, retail services,
entertainment and numerous and varied visitor accommodations. By providing storefront
commercial retail uses, a limited number of hotel units, and residential units, the project meets
the intent of the General Plan for the Downtown.
The Downtown Concept Plan identifies the project block (27) for commercial mixed use and
hospitality uses, and states that: "New commercial mixed use and hospitality are envisioned in
this block, with historic resources remaining. A mid -block paseo in alignment with Beach Street
connects pedestrians between Marsh and Higuera Streets and to Block 28." The mixed -use
project includes commercial and hospitality uses and incorporates a public paseo with the
potential for a future connection to the Jack House, consistent with the plan. The site does not
include any historic resource, and the existing historic resources in the proximity would remain,
consistent with the Downtown Concept Plan.
What constitutes an unusual circumstance is dependent on the context of the project, and whether
that circumstance is unusual for the type of project in the actual area in which the project occurs.
The proposed project consists of a mixed -use development and is consistent with Zoning
Regulations specific to the C-D zone. As noted in the project statistics, the height of the structure
(50 feet) meets the height standard, the FAR and lot coverage is less than what is allowed to be
considered in the C-D zone, and the property line setbacks exceed the minimum required. The
project's height, size, and scale are generally consistent with other buildings in the Downtown.
The appellant notes that the City has approved multi -story, multi -family, residential [and mixed
use projects] in the vicinity, and consistent with the General Plan and Zoning Ordinance, it is
reasonably expected that additional applications would be received for similar types of
developments. A project that is consistent with zoning standards and the size and scale of other
buildings in the City's Downtown is not unusual. The fact the project would be located in an area
with historic resources is not unusual. because the presence of historic resources adjacent to the
site is not an unusual circumstance in this area of the City's Downtown.
This issue has been carefully studied by City staff because there is an "exception" to normal
CEQA exemptions, like the infill exemption, for projects "which may cause a substantial adverse
change in the significance of a historical resource."3 However, staff has determined through the
evaluation process of this project that its construction will not impact or change the significance
of any historical resource.
4. The project is not subject to the "infill" exemption or any exemption because the project is
inconsistent with the CDG and LUCE CR-2 3.3.5.
s Historical Resources. A categorical exemption shall not be used for a project which may cause a substantial
adverse change in the significance of a historical resource. (CEQA Guidelines Section 15300.2(f))
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Conservation and Open Space Element Policy 3.3.5 (Historic districts and neighborhoods) states
that: "In evaluating new public or private development, the City shall identify and protect
neighborhoods or districts having historical character due to the collective effect of Contributing
or Master List historic properties." The project site is not located within an identified historic
district or neighborhood, and as noted above, the project site is currently developed with
commercial and office development, and the General Plan and Downtown Concept Plan calls for
the type of development proposed in this location. The project incorporates features to provide
separation and transition between the site and the identified historic resource and would not
affect the eligibility of those resources to remain.
5. The project is not subject to an exemption from CEQA because the project was required to
incorporate mitigation measures in order to reduce the significance of the project's impacts
and inconsistency with historical resources.
The proposed project's modifications through staff and advisory body review do not constitute
mitigation measures as defined by CEQA. No significant adverse impact to historic resources
was identified for the project as proposed.
6. The project is capable of causing a cumulatively significant impact on historical resources.
The State CEQA Guidelines state that categorical exemptions are inapplicable when the
cumulative impact of successive projects of the same type in the same place, over time is
significant. While the combination of other projects in the vicinity have resulted in a cumulative
effect, none of the projects resulted in a significant effect and as noted above, the proposed
project would not have a significant effect on historical resources as defined by the State CEQA
Guidelines. Furthermore, the project is consistent with the General Plan and Zoning Regulations,
in addition to the CDG, and would not have a project -specific or cumulative effect on aesthetics.
7. The project is not a "housing development project" subject to and as defined by the Housing
Accountability Act [Government Code 65589.5 (h)(2)(13)].
The section of the Government Code cited by the appellant clearly states that this mixed -use
housing project is a "housing development project" subject to the process prescribed by the Act:
(h) The following definitions apply for the purposes of this section:
(2) "Housing development project" means a use consisting of any of the following:
(B) Mixed -use developments consisting of residential and nonresidential uses with
at least two-thirds of the square footage designated for residential use.
Staff concludes that this project is subject to the requirements of the Housing Accountability Act.
8. Staff incorrectly advised the Planning Commission that the project would not cause a
significant impact on a historic resource because losing eligibility for listing as a historic
resource is not the only measure of the significance of project's impacts on a historic
resource. The Historic Preservation Ordinance (HPO) identifies an adverse impact as
"effects, impacts or actions that are detrimental or potentially detrimental to a historic
resource's condition, architectural or historical integrity."
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As reviewed by the Planning Commission, the project would not result in an adverse impact as
defined by the HPO. The Historical Compatibility Letter provides a basis for this conclusion,
stating that "Although the heights of Buildings A and B are greater than the height of the existing
office buildings, the general footprint remains roughly the same and provides a measure of
architectural continuity as a result, particularly for the Norcross House and the Pinho House. The
setting for the Pollard House at 535 Higuera Street will be much improved by the widening of
the buffer between the historic property and the project; removal of the asphalt driveway and the
addition of landscaping and attractive hardscape represents a design approach that relates well to
the concrete driveway, trees, and shrubbery on the Pollard parcel. As mentioned in the Historic
Preservation Report, none of the adjacent historic properties (and I would include the Pinho
House in that designation) and none of the more distantly located historic properties will be
subject to any indirect impacts that threaten their eligibility as significant historical resources."
9. Staff failed to refer the project to the Cultural Heritage Committee (CHC) for evaluation:
The HPO, specifically section 14.01.030(C)(7) states that the Cultural Heritage Committee
(CHC) shall review and make recommendations ... on applications and development review
projects which include ... the following: Proposed actions of public agencies that may affect
historic or cultural resources within the City.
HPO Section 14.01.040 states that the Community Development Director is responsible for
interpreting and implementing this ordinance and helping the CHC carry out its duties.
Notwithstanding Section 14.01.030C 1-5 and 7 of this ordinance, the Director may determine
that CHC review is not required for actions or projects that do not adversely affect historic
resources.
To ensure clarity about projects subject to Cultural Heritage Committee review, staff worked
with the CHC to develop a matrix identifying those projects that will be referred to the
Committee for a recommendation. In this case, the project is not located in a historic district and
there are no historic resources located on the property to be developed.
As noted above, the project would not have an adverse effect on historic resources; therefore, the
project was not referred to the CHC.
Public Engagement
Consistent with the City's Public Engagement and Noticing (PEN) Manual and the City's
Municipal Code, the project was noticed per the City's notification requirements for
Development Projects. Newspaper legal advertisements were posted in the New Times ten days
prior to each advisory body meeting (Architectural Review, Planning Commission, City
Council). Additionally, postcards were sent to both tenants and owners of properties located
within 300 feet of the project site ten days before each advisory body hearing. Public comment
was provided to the advisory bodies through written correspondence and through public
testimony at each of the hearings.
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CONCURRENCE
Staff comments provided during review of the proposed project and appeal are incorporated into
the presented evaluation and conditions of approval.
ENVIRONMENTAL REVIEW
The project is categorically exempt under Class 32, In -Fill Development Projects; Section 15332
of the State California Environmental Quality Act (CEQA) Guidelines, because the project is
consistent with General Plan policies for the land use designation and is consistent with the
applicable zoning designation and applicable regulations. The project site occurs on a property of
no more than five acres, which is currently developed with existing commercial and office uses
and associated parking, is substantially surrounded by urban uses, and has no value as habitat for
endangered, rare or threatened species. The project would be served by adequate required
utilities and public services. The project has been reviewed by the City Public Works
Department, Transportation Division, and no significant traffic impacts were identified, based on
the size and location of the project. Based on the current use of the site, the proposed project as
designed, the location of the project, and compliance with existing Zoning and Municipal Code
Regulations including the City's Noise and Stormwater Regulations, the project would not result
in any significant effects related to noise, air quality, or water quality.
FISCAL IMPACT
Budgeted: Yes Budget Year: N/A
Funding Identified: No
Fiscal Analysis:
Funding Sources
Current FY Cost
Annualized
On -going Cost
Total Project
Cost
General Fund
N/A
State
Federal
Fees
Other:
Total
Per policy, Development Services fees are based on 100% cost recovery. However, during the
2016 Fee Study the Council approved a 25% cost recovery for Appeals. The average estimated
labor cost for a Tier 1 Appeal is $3,116, and the current fee for non -applicants is $640.
When the General Plan was prepared, it was accompanied by a fiscal impact analysis, which
found that overall, the General Plan was fiscally balanced. Accordingly, since the proposed
project is consistent with the General Plan, it has a neutral fiscal impact. There is no fiscal
impact associated with the approval of this project.
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ALTERNATIVES
1. Uphold the appeal, thereby denying the project. The Council can deny the project based on
findings of inconsistency with California State Law, the City's General Plan, Zoning
Regulations, and other applicable City regulations. Should Council want to pursue this
alternative, Staff recommends that specific information be provided in order for Staff to
return with findings to support Council direction.
2. Continue consideration of the appeal to a future date. The Council can continue review of
the appeal to a future meeting. If this alternative if taken, the Council should provide
direction to staff regarding additional information needed to make a decision.
Attachments:
a - Draft Resolution
b - COUNCIL READING FILE - Planning Commission and ARC Agenda Reports and
Minutes
c - COUNCIL READING FILE - Applicant Narrative and Plans
d - Appeal Application and Letter
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Item 12
RESOLUTION NO. (2020 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, DENYING AN APPEAL OF THE PLANNING
COMMISSION'S APPROVAL OF A 50-FOOT TALL MIXED -USE
PROJECT CONSISTING OF 5,241 SQUARE FEET OF GROUND -FLOOR
RETAIL, EIGHT HOTEL SUITES, AND 39 RESIDENTIAL UNITS,
INCLUDING MECHANICAL PARKING LIFTS, AND A CATEGORICAL
EXEMPTION FROM ENVIRONMENTAL REVIEW, AS REPRESENTED
IN THE STAFF REPORT AND ATTACHMENTS (545 HIGUERA STREET,
486 MARSH STREET, ARCH-0017-2019)
WHEREAS, the Architectural Review Commission of the City of San Luis Obispo
conducted a public hearing in the Council Hearing Room of City Hall, 990 Palm Street, San Luis
Obispo, California, on September 9, 2019, and continued review of the project to a date uncertain,
pursuant to a proceeding instituted under ARCH-0017-2019, Taylor Judkins, applicant; and
WHEREAS, the Architectural Review Commission of the City of San Luis Obispo
conducted a public hearing in the Council Hearing Room of City Hall, 990 Palm Street, San Luis
Obispo, California, on October 21, 2019, recommending the Planning Commission find the project
consistent with the Community Design Guidelines and two directional items related to colors and
architectural details, pursuant to a proceeding instituted under ARCH-0017-2019, Taylor Judkins,
applicant; and
WHEREAS, the Planning Commission of the City of San Luis Obispo conducted a public
hearing in the Council Chamber of City Hall, 990 Palm Street, San Luis Obispo, California, on
January 8, 2020, pursuant to a proceeding instituted under ARCH-0017-2019, Taylor Judkins,
applicant, and moved to continue review of the entitlement to a date uncertain; and
WHEREAS, the Planning Commission of the City of San Luis Obispo conducted a public
hearing in the Council Chamber of City Hall, 990 Palm Street, San Luis Obispo, California, on
February 26, 2020, pursuant to a proceeding instituted under ARCH-0017-2019, Taylor Judkins,
applicant and approved the mixed -use project with a Categorical Exemption from environmental
review; and
WHEREAS, on March 9, 2020, Babak Naficy, Attorney filed an appeal on behalf of San
Luis Architectural Protection ("SLAP") and Save Our Downtown ("SOD") of the Planning
Commission's action on February 26, 2020; and
WHEREAS, the City Council of the City of San Luis Obispo conducted a public hearing
via webinaron June 2, 2020, pursuant to a proceeding instituted under APPL-0201-2020, Babak
Naficy, Attorney filed an appeal on behalf of San Luis Architectural Protection ("SLAP") and
Save Our Downtown ("SOD"), appellants; and
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Resolution No. (2020 Series) Page 2
WHEREAS, the City Council of the City of San Luis Obispo has duly considered all
evidence, including the testimony of the appellants, the applicant, interested parties, and evaluation
and recommendations by staff, presented at said hearing; and
WHEREAS, notices of said public hearings were made at the time and in the manner
required by law; and
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo
that the appeal of the Planning Commission's decision is denied pursuant to the following findings:
SECTION 1. Findings. Based upon all the evidence, the City Council makes the
following findings to deny the appeal (APPL-0201-2020) of the Planning Commission decision,
thereby granting final approval to the project (ARCH-0017-2019):
a) As conditioned, the project will not be detrimental to the health, safety, and welfare
of persons living or working at the site or in the vicinity because the project respects
site constraints and will be compatible with the scale and character of the
neighborhood.
b) The project is consistent with the Zoning Regulations, since the proposed building
design complies with all property development standards including height, setbacks,
coverage, floor area ratio, density, and parking for the Downtown -Commercial zone.
c) The project is consistent with the General Plan Land Use Element, because: the
proposed retail, hotel, and residential uses are consistent with uses intended for the
Downtown area (Land Use Element Policies 3.8.5, 4.1, and 4.2.1); as proposed and
conditioned the project incorporates landscaping, setbacks, and step -backs to provide
a protection of existing residential uses (Land Use Element Policy 4.2); and, the
project includes public gathering space, onsite walkways and paths, and connections
to sidewalks (Land Use Element Policies 4.4 and 4.5). As designed and conditioned,
the project is compatible with historically significant and other existing buildings in
the immediate neighborhood (Land Use Element Policies 4.16 and 4.20.4).
d) The project is consistent with General Plan Land Use Element Policy 2.2.7, because
the project is located within a half -mile of an existing transit stop, and is proximate to
bicycle routes, parks, open space, and commercial uses.
e) The project is consistent with the Zoning Regulations for Mixed -use Projects (Section
17.70.130) because the proposed building design complies with objective design
criteria and performance standards for mixed -use development.
f) The project is consistent with the Zoning Regulations for Rooftop Uses (Section
17.70.150) because the roof deck would be located at 40 feet, 6 inches in elevation,
which is below the maximum allowable building height for the structure (50 feet) and
would be in compliance with required performance standards related to lighting and
noise.
Packet Page 113
Item 12
Resolution No. (2020 Series) Page 3
g) The project design is consistent with the City's Community Design Guidelines
because the architectural design of the project is compatible with design and scale of
existing structures in the surrounding neighborhood, the project incorporates
articulation to minimize massing, visual linkages are provided through the use of
landscaping, and pedestrian walkways, the proposed design demonstrates use of
articulated facades by incorporating textured materials, balconies and decks, and a
variety of siding materials (brick and stucco) is proposed to provide texture, relief, and
visual interest consistent with the Downtown Design Guidelines and visual character
of the neighborhood.
h) The use of mechanical lift parking results in superior design and implementation of
City goals and policies for infill development, because it would allow for the provision
of parking spaces for proposed retail, hotel, and residential uses in a compact location
within an enclosed garage.
i) As the mechanical lift parking system would be located within an enclosed garage, it
will be adequately screened and compatible with the character of surrounding
development and the Community Design Guidelines.
j) As the mechanical lift parking system would be located within an enclosed garage, it
will comply with all development standards including but not limited to height and
setback requirements and parking and driveway standards, except for minimum
parking stall sizes, which are established by lift specifications.
k) As conditioned, there exists adequate agreement running with the land that mechanical
parking systems will be safely operated and maintained in continual operation except
for limited periods of maintenance.
1) There are no circumstances of the site or development or particular model or type of
mechanical lift system that could result in significant impacts to those living or
working on the site or in the vicinity.
m) The project is a "housing development project" subject to and as defined by the
Housing Accountability Act [Government Code 65589.5 (h)(2)(B)], as "housing
development projects" include mixed -use developments consisting of residential and
nonresidential uses with at least two-thirds of the square footage designated for
residential use, and does not require that the nonresidential use be located on the first
floor only. As such, the project meets this requirement.
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Item 12
Resolution No. (2020 Series) Page 4
SECTION 2. Environmental Review. The project is categorically exempt under Class 32,
In -Fill Development Projects; Section 15332 of the State California Environmental Quality Act
(CEQA) Guidelines, because the project is consistent with General Plan policies for the land use
designation and is consistent with the applicable zoning designation and applicable regulations.
The project site occurs on a property of no more than five acres, which is currently developed with
existing commercial and office uses and associated parking, is substantially surrounded by urban
uses, and has no value as habitat for endangered, rare or threatened species. The project would be
served by adequate required utilities and public services. The project has been reviewed by the
City Public Works Department, Transportation Division, and no significant traffic impacts were
identified, based on the size and location of the project. Based on the current use of the site, the
proposed project as designed, the location of the project, and compliance with existing Zoning and
Municipal Code Regulations including the City's Noise and Stormwater Regulations, the project
would not result in any significant effects related to noise, air quality, or water quality. Based on
the projects location within the Downtown Commercial zone, and the project's consistency with
the General Plan, Downtown Concept Plan, and Zoning Regulations, and presence of historic
resources throughout the Downtown and areas subject to the same policies and regulations, no
unusual circumstance exists in accordance with the Berkeley Hillside Preservation v. the City of
Berkeley, 60 Cal 4ffi 1086 (2015) case. Furthermore, based on the project's design, which
incorporates forms, step backs, setbacks, landscaping, and materials found to be consistent with
the General Plan and Community Design Guidelines, and the initial recommendations of the
historic assessment and the conclusion of the Historical Compatibility Letter, the project would
not result in a significant adverse impact or cumulative impact to historical resources as defined
by the California Environmental Quality Act.
Packet Page 115
Resolution No. (2020 Series)
Item 12
Page 5
SECTION 3. Action. Based on the foregoing findings and evidence in the record, the City
Council does hereby deny the appeal of the Planning Commission' s action to approve the design
of the proposed project thereby granting final approval of the application ARCH-0017-2019 for a
mixed -use project and the use of mechanical parking lifts for the proposed project at 454 Higuera
Street and 486 Marsh Street, as conditioned by the Planning Commission.
Upon motion of
and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted this
ATTEST:
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
J. Christine Dietrick
City Attorney
seconded by
day of
Mayor Heidi Harmon
2020.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, on
Teresa Purrington
City Clerk
Packet Page 116
Date Receive(]
RECEIVED
rif q
MAR 0 9 2020
,..= SLO CITY CLERK
Filing Fee
❑ Applicant: $ 1,65964
❑ Tree Appeal: $ 11999
For Office Use
✓❑ Non -applicant $ 66407
APPEAL TO THE CITY COUNCIL
Received by:�2t—
SECTION 1. APPELLANT INFORMATION
San Luis Architecturel Protection 1540 Marsh St, Suite 110, SLO, CA 93401
Name Mailing Address and Zip Code
805-593-0926 805-593-0946
Phone Fax
Babak Naficy, 1540 Marsh St, Suite 110, SLO, CA 93401
Representative's Name Mailing Address and Zip Code
attorney, (same as above)
Title Phone Fax
SECTION 2. SUBJECT OF APPEAL
1. In accordance with the procedures set forth in Title 1, Chapter 1.20 of the San Luis Obispo,
Municipal Code (copy attached), I hereby appeal the decision of the:
Planning Commission
(Name of Officer, Committee or Commission decision being appealed)
2. The date the decision being appealed was rendered: February 26, 2020
3. The application or project was entitled: Mixed -Use Project at 545 Higuera/486 Marsh Street
Mixed -Use Project at 545 Higuera/486 Marsh Street
4. 1 discussed the matter with the following City staff member:
on
(Staff Members Name and Department)
(Date)
5. Has this matter been the subject of a previous appeal? If so, when was it heard and by whom:
SECTION 3. REASON FOR APPEAL
Explain specifically what action/s you are appealing and why you believe the Council should consider
your appeal. Include what evidence you have that supports your appeal. You may attach additional
pages, if necessary. This form continues on the other side.
07/19 update Pa e
Packet Page a 11 7 of 3
Akta-ME12
Reason for Appeal continued
Please See Attachment
SECTION 4. APPELf-ANDS RESPONSIBILITY
The San Luis Obispo City Council values public participation in local government and
encourages all forms of citizen involvement. However, due to real costs associated with City
Council consideration of an appeal, including public notification, all appeals pertaining to a
planning application or project are subject to the following filing fee, which must accompany the
appeal form: Applicant = $ 1,659.64, Non -applicant = $ 664.07, Tree Appeal = $ 119.99.
Your right to exercise an appeal comes with certain responsibilities. If you file an appeal,
please: understand that it must be heard within 45 days from filing this form, except for matters
arising under Chapter 17.66 of the zoning code which shall be governed by that Chapter. You
will be notified in writing of the exact date your appeal will be heard before the Council, You or
your representative will be expected to attend the public hearing, and to be prepared to make
your case. Your testimony is Iimited to 10 minutes.
A continuance may be granted under certain and unusual circumstances. If you feel you
need to request a continuance, you must submit your request in writing to the City Clerk, Please be
advised that if your request for continuance is received after the appeal is noticed to the public, the
Council may not be able to grant the request for continuance_ Submitting a request for continuance
does not guarantee that it will be granted; that action is at the discretion of the City Council.
I hereby agree to appear andlor send a representative to appear on my behalf when
said appeal is scheduled for a public hearing before the City Council.
(Signature of Appellant) (Date)
This item is hereby calendared for
cc: City Attorney
City Manager
Department Head
Advisory Body Chairperson
Advisory Body Liaison
City Clerk (original)
07/19 update Packet Page 'I 16of 3
AtteMEU
Supplement to Appeal to the City Council
San Luis Architectural Protection ("SLAP") and Save Our Downtown ("SOD", collectively
"Appellants") appeal the Planning Commission's February 26, 2020 approval of a mixed -use
Project at 545 Higuera/486 Marsh Street ("the Project"), including the Planning Commission's
conclusion that the Project is exempt from review under the California Environmental Quality
Act ("CEQA"). This document supplements the City's Appeal form, which is currently filed
herewith.
By this reference, Appellants specifically incorporate February 26, 2020 written and oral
comments of Babak Naficy on behalf of SLAP, as well as the written and oral comments of
James Papp, PhD, Allan Cooper and Dan Krieger's at the Planning Commission hearings on
January 8, 2020 and February 26, 2020.
James Papp, PhD, is historian and architectural historian to the Secretary of Interior's
professional qualification standards and former chair of San Luis Obispo Cultural Heritage
Commission. Dr. Papp is a Cal Poly professor emeritus of architecture. Alan Cooper is former
Planning Commissioner and Cal Poly professor emeritus of history. Dan Kriege is a former chair
of the Cultural Heritage Commission. Owing to their extensive educational, teaching and
professional experience, these individual individually and collectively are experts on the issues
raised in this appeal.
Introduction
The Appellants' core objective is protection the historic and architectural integrity of the
historically mixed use, working-class neighborhood in which this Project is proposed. Appellans
are deeply concerned that owing to its mass, height and scale, this Project would have an
overwhelming effect on the affected historic resources and architectural and aesthetic integrity of
this neighborhood.
The Project consists of a two buildings, each 50 feet in height, sited on two connected parcels
located between Higuera and Marsh Streets. The Project will include retail space on the ground
floor, eight hotel units, and a mix of studios, and one and two -bedroom apartments on the upper
floors. A more detailed description of the Project is provided in the Planning Commission Staff
Report.
Argument
Appellants contend the Planning Commission's approval of the Project must be set aside for the
following reasons:
1. The Project is not consistent with San Luis Obispo Community Design Guidelines
("CDG"). In fact, the Staff Report prepared for the PC fails to adequately consider the
Project's consistency with CDG. For example, the Staff Report does not identify any
11 Appeal of Planning Commission's approval of 545 Higuera/486 Marsh Street Project
Packet Page 119
extenuating circumstances that could support the Project's failure to comply with the
provisions of the CDG, despite the City Council's November 6, 2007 amendments to the
CDG explaining that "should" language in the CDG must be complied with unless to do
so would be precluded owing to specific extenuating circumstances. The particular
provisions of the CDG with which the Project is inconsistent include the following:
5.3.A.1. Infill residential development should be compatible in scale, siting,
detailing, and overall character with adjacent buildings and those in the immediate
neighborhood.
At 50 feet in height, the Project is manifestly incompatible in scale and overall
character with the one and two-story adjacent historically significant buildings.
5.3.B. An infill residential structure should incorporate the traditional
architectural characteristics of existing houses in the neighborhood, including
window and door spacing, exterior materials, roof style and pitch, ornamentation,
and other details.
The Proposed structure does not incorporate or reflect the architectural
characteristics of the existing historic houses in the neighborhood.
5.3.C. The height of infill projects should be consistent with surrounding
residential structures. Where greater height is required, an infill structure should
set back upper floors from the edge of the first story to reduce impacts on smaller
adjacent homes, and to protect solar access.
The Project's height is inconsistent with the historic single -story residential
neighborhood, including mostly single -story historic houses.
5.4.A.1. Site planning for a multi -family ... housing project should ... consider
the existing character of the surrounding residential area. New development
should respect the privacy of adjacent residential uses through appropriate
building orientation and structure height, so that windows do not overlook and
impair the privacy of the indoor or outdoor living space of adjacent units.
The height of the proposed multi -family Project is inconsistent with the character
of the surrounding residential area, and the Project does not respect the privacy of
the adjacent historically significant houses.
5.4.A.3. Multi -family structures should be set back from adjacent public streets
consistent with the prevailing setback pattern of the immediate neighborhood.
The prevailing setback pattern of the immediate neighborhood is single cottages
or bungalows with front yards and open side parking areas for small businesses.
2.1 Appeal of Planning Commission's approval of 545 Higuera/486 Marsh Street Project
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5A.C.1. A structure with three or more attached units should incorporate
significant wall and roof articulation to reduce apparent scale.... Structures
exceeding 150 feet in length are discouraged.
The Project, designed as a single block almost 300 feet long, now consists of two
blocks slightly offset and separated, with large expanses of flat roof and flat wall,
and connected by a skybridge, presenting as a single building from most street
and neighbor vantage points, without reduction to its apparent scale.
5.4.C.2. Structures with greater height may require additional setbacks at the
ground floor level and/or upper levels (stepped down) along the street frontage so
they do not shade adjacent properties or visually dominate the neighborhood.
Large projects should be broken up into groups of structures, and large single
structures should be avoided.
The Project does not have setbacks at the ground floor level and has minimal
setbacks at the upper levels and manifestly visually dominates the neighborhood
with a large single structure on the two lots (543 and 545) facing Higuera Street
and another large single structure on the lot (586) facing Marsh Street and
presenting from most street and neighbor vantage points as an even larger single
structure.
1.4(A)(4)7 (5): (4) Design with consideration of the site context in terms of the
best nearby examples of massing, scale, and land uses when the site is located in a
notable area of the city (for example, the Downtown, Old Town) and (5) Protect
the scale and character of historic neighborhoods.
The Project design does not relate to and is inconsistent with the nearby examples
of massing and scale, and, the Project does not protect the scale and character of
this historic neighborhood.
2. Contrary to the Staffs suggestion and the Planning Commission's finding, the Project is
not exempt from CEQA. It should be noted that notwithstanding the fact the Planning
Commission adopted a finding that the Project is exempt from CEQA, according to the
Staff Report, the Planning Commission's purview is limited to reviewing the Project's
consistency with the applicable provisions of the General Plan, Zoning Regulations,
Community Design Guidelines, and applicable City development standards. See, Staff
Report, at P. 12. Moreover, the Planning Commissioners did not discuss the Project's
compliance with CEQA, and did not direct any questions in this regard towards the Staff
or the City Attorney.
• This Project is not exempt from CEQA because it may cause a substantial adverse
change in the significance of "historic resources". CEQA Guideline §15300.2(f).
Substantial evidence, including the April 2019 SWCA Environmental
Consultants' Historic Preservation Report ("Report"), and the comments of Dr.
James Papp, and other members of the public, supports a finding that the Project
31 Appeal of Planning Commission's approval of 545 Higuera/486 Marsh Street Project
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may cause significant impact on historically significant buildings — particularly
the Pollard House, Norcross House and Pinho House — in the Project's vicinity.
Owing to unusual circumstance, the Project is capable of causing a significant
adverse impact on historical resources. CEQA Guideline § I 5300.2(c).The
Project's circumstances are unusual because unlike a typical "infill project"
subject to the infill exemption, this Project is surrounded by historically
significant structures in a neighborhood that has a strong historic feel. Owing to
this unusual circumstance, the Project may cause a significant impact on historic
resources. Owing to these unusual circumstances, it can be fairly argued that the
Project may have a significant impact on historical resources, as set forth above
and in the SWCA Report.
• The Project is not subject to the "infill" exemption (or any exemption because the
Project is inconsistent with the CDG, as set forth above. CEQA Guideline
§I5332(a). The Project is also inconsistent with LUCE CR-2, 3.3.5 requirement
that "in evaluating new public or private development, the City should identify
andprotect neighborhoods or districts that have historical character due to the
colletive effect of Contributing or Master List historic properties."
• The Project is not subject to an exemption from CEQA because the Project was
required to incorporate mitigation measures in order to reduce the significance of
the Project's impacts and inconsistency with historical resources. Salmon
Protection and Watershed Network v. County of Mari n (2004) 125 Cal.App.4th
1098, 1102.
The Project is capable of causing a cumulatively significant impact on historical
resources. CEQA Guideline § 15300.2(b). The evidence shows that the City has
already approved multi -story multi -family, residential projects in the same
neighborhood. In fact, at the February 26, 2020 Planning Commission heraring,
Michael Codron, the City's Director of Community Development, emphasized
that the Commission will likely continue to see applications for similar multi-
story projects in this neighborhood. Yet, the Planning Commission and Staff
made no adequate effort to consider whether the cumulative impact of successive
projects of the same type in the same place could result in a cumulative aesthetic
and/or historic impacts. Accordingly, Appellants contend that there is a
"reasonable possibility" that this Project "will have a significant effect on the
environment due to unusual circumstances. CEQA Guideline § 15300.2(b
41
Appeal of Planning Commission's approval of 545 Higuera/486 Marsh Street Project
Packet Page 122
3. Contrary to the Staff Report's explanation, this Project is not a "housing development
project" subject to the Housing Accountability Act because it includes hotel rooms (i.e. a
commercial use) above the first floor of the building. See, Gov. Code § 65589.5, subd.
(h)(2)(B). Accordingly, the provisions and limitations of Gov. Code § 65589.50) do not
apply to this case and have no effect on the City's discretion.
4. The Staff incorrectly advised the Planning Commission that the Project would not cause a
significant impact on a historic resource because despite the Project's impacts, the
Pollard House, Norcross House and Pinho House would remain eligible for listing as a
historic resource. Losing eligibility for listing as a historic resource, however, is not the
only measure of the significance of project's impacts on a historic resource. According to
San Luis Obispo Historic Preservation Ordinance, for example, adverse impacts are
defined as "effects, impacts or actions that are detrimental or potentially detrimental to a
historic resource's condition, architectural or historical integrity." § 14.01.020(3). Comm.
to Save the Hollywoodland Specific Plan v. City of Los Angeles (2008) 161 Cal. App.
4th 1168, 1187 held that a project involving the building of a fence atop a historically
significant was not exempt from CEQA in part because the "wall will significantly
impact the environment by altering the historic resource, both as to its physical integrity
and its aesthetic appeal from the neighboring streets." Accordingly, the Staffs failure to
correctly advise the Planning Commission concerning the legal definition of an adverse
impact on historic resources undermined the Planning Commission's ability to assess the
significance of the Project or the finding that the Project is exempt from CEQA.
5. The City was required but failed to refer the Project to the Cultural Heritage Committee
for evaluation of the potential impact on historic resources. Pursuant to
§ 14.01.030(C)(7), "The Committee shall review and make recommendations to the
Director, Architectural Review Commission, Planning Commission or City Council on
applications and development review projects which include any of the following:.. .
Proposed actions of public agencies that may affect historic or cultural resources within
the City." The Planning Commission's approval of the Project constitutes a "proposed
action" of a public agency that may affect historic resources within the City. As such, the
Project should have been referred to the Cultural Resource Committee for review and
recommendations.
For all of the foregoing reasons, I urge you to grant this appeal and send the Project back
to the Planning Commission and the Cultural Heritage Committee for further
consideration and environmental review.
RegdS
Res ctfully,
Babak Naficy, for Appellants
S I Appeal of Planning Commission's approval of 545 Higuera/486 Marsh Street Project
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AtteMEIT2
1540 Marsh Street
Suite 110
San LuisObispo
California 93401
ph:805-593-0926
fax:805-593-0946
babaknaficy aisbcglobal.net
awOffices of Babak Naficy
February 26, 2020
Via Email
San Luis Obispo Planning Commission
Shawna Scott, Senior Planner
sscott(6slocitV. om
advisorybodies@slocity.org
Re: PC February 26, 2020 Meeting Item Number 2: 545 Higuera & 486 Marsh
Honorable Commissioners.
I submit these comments on behalf of San Luis Architectural Preservation (SLAP) in
connection with the Planning Commission's (PC) ongoing review of the 545 Higuera/484
Marsh Street Project ("Project"). As more fully explained below, SLAP contends the City
may not lawfully rely on a categorical exemption in this case because the Project will likely
cause a significant and substantial adverse impact on historically significant resources in the
Project's vicinity. CEQA exemptions do not apply to a discretionary project that could
potentially cause a significant impact and therefor requires mitigation. I urge you to
continue the hearing and direct Staff to undertake a more comprehensive and detailed
review of the Project's impacts and potentially feasible mitigation measures and
alternatives.
The Planning Department has proposed that this project is exempt from CEQA review as a
Class 32, in -fill development project. For reasons that are stated below, the Planning
Department's conclusion is wrong. This Project is not exempt because a number of
exceptions apply. To begin with, the Project does not come within the scope of the
exemption because it does not comply with all applicable rules and regulations. The Project
is not exempt also because it may cause a substantial adverse impact on one or more historic
resources. Moreover, owing to special circumstances, it can be fairly argued that this Project
would have a potentially significant impact on a historic resource. Finally, the Project is not
exempt because the proposed conditions of approval and required changes to the Project
amount to mitigation measures that are intended to lessen the severity of the Project's
adverse impacts on historic resources.
Cater-orical exemptions are not absolute
Categorical exemptions are not absolute. If there is any "reasonable possibility" that a
project or activity may have a significant effect on the environment, an exemption is
improper. Guideline §15300.2(c); Wildlife Alive v. Chickering, (1976) 18 Cal. 3d 190, 205-
06. Categorical exemptions must be strictly construed to ensure they are applied only to the
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classes of projects that have been determined not to have a significant impact on the
environment. Azusa Land Reclamation Co v. Main San Gabriel Basin Watermaster (1997) 52
cal.App.e 1165, 1192.
There are several "exceptions" to the application of a categorical exemption, three of which
apply here:
There is a reasonable possibility of a significant effect on the environment due to
unusual circumstances. Guideline §15300.2(c);
Significant cumulative impacts from projects of the same type will result. Guideline
§ 15300.2(b);
Historical Resources. A categorical exemption shall not be used for a project which
may cause a substantial adverse change in the significance of a historical resource.
Guideline § 15300.2(f).
A project is not exempt from CEQA where the agency's conclusion that the project would not
result in any potentially significant environmental impacts is based on consideration of
mitigation measures. In other words, if mitigation measures are needed to avoid or lessen
potentially significant impacts, then at a minimum, a mitigated negative declaration must be
prepared. See, Kostka and Zischke, Practice Under the California Environmental Quality Act
2nd Ed., at §5.75, citing Azusa Land Reclamation Co v. Main San Gabriel Basin Watermaster
(1997) 52 Cal.AppAth 1165, 1200.
The Project is not exempt from CEQA because it ma-y cause a substantial adverse chance in
the significance of historical resources
This Project subject is not exempt from CEQA because the Project may cause a substantial adverse
change in the significance of "historic resources" as the term is defined under CEQA. According to
the April 2019 SWCA Environmental Consultants' Historic Preservation Report ("Report"), a
number of historically significant buildings may be adversely affected and changed by the Project.
According to the Report: Five parcels in the immediate project area are occupied by seven
buildings and one cultural landscape included on the City' s Master List of Historic Resources and
one parcel by one building (the Wilkinson House) included on the Contributing List (Table 1). Of
these, one property- the Jack House- is also listed on the NRHP. One additional property within
the neighborhood- the c 1887 Pinho House- is also included as an example of early residential
development typical of the neighborhood. (Report p. 7). "Historic structures in the immediate
vicinity include the Pollard House (adjacent to the site, to the southwest), the Norcross House
across Higuera Street, to the north), and the Jack House and Gardens ( approximately 100 feet to
the east)." Consistent with the Report, the staff report correctly identifies the Project's vicinity as
containing a mosaic of historically significant buildings.
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The Report itself amounts to substantial evidence supporting a fair argument that the Project "may
cause a substantial adverse effect" on several historic resources.
Regarding the Pollard House, which is located immediately adjacent to the Project site, the Report
explains
The adjacency, height, mass, and design (and, to a lesser extent, the materials) of
the proposed development (especially of the building at 545 Higuera Street) would
completely dominate the neighboring Pollard House and would greatly impact its
integrity of setting, feeling, and association. (Report at p. 19).
Likewise, concerning the Norcoss House, the Report explains:
Along with the Pollard House, the Norcross House will bear the brunt of project
impacts to the integrity of setting, feeling, and association. Considering that the
Norcross House has already been subject to a slight loss of integrity of location
from being moved closer to Higuera Street) and a severe loss of integrity of design,
materials, workmanship, setting, feeling, and association from its own on -site
redevelopment project, the impacts from the proposed project will constitute
additional cumulative impacts. (Report at p. 20).
The report also points out cumulative impacts to the Pinho House, which, like the Norcross House,
has been relocated on its lot and altered in its fabric (e.g., with the addition of safety railing to the
Italianate porch) by development. The Jack House will also be affected by the Project, but not to
the same extent:
To the extent that these partial views [of the Project] introduce large- scale modern
elements at very close range to the NRHP- listed historical property, the visual
intrusion would constitute a loss of integrity probably only minor) to the Jack
House setting, feeling, and association but would not impair its integrity of location,
design, materials, or workmanship. (Report at p. 22).
In a September 3, 2019 letter to Shawna Scott, the Report's author, Paula Carr, addressed the
developer's response to the Report's recommended mitigation measures: "These clarifications go a
long way, in my mind, toward meeting my earlier recommendations for improving compatibility"
(italics added). Significantly, she did not conclude that the proposed mitigation measures would
reduce the Project's impact on historic resources to a less than significant level, as was claimed by
the City in your Jan. 8th hearing. In any event, as explained below, any evaluation of the adequacy
of any proposed mitigation measures would be inappropriate in the context of an exemption.
While the Report states the cultural resources in question would retain their eligibility for Master
List status, that is not CEQA's definition of significant impact, nor is that interpretation supported
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by case law. The only relevant issue is that the inclusion of recommended mitigations is a clear
indication that the Project impacts are significant. Accordingly, because individually and in the
aggregate, the Project as proposed may cause a substantial adverse change in the significance of
these historical resources, the Project cannot be exempt from CEQA review. Please also refer to
the comments of James Papp, PhD, concerning the adverse impacts of the Project on the historic
resources identified in the Report.
Owing to Special Circumstances, the Proiect may have a significant adverse impact on
historic resources.
In addition to the "Historic Resource" exception, the "unusual circumstances" exception also
precludes the City's reliance on a CEQA exemption for this Project. According to the unusual
circumstances exception, an agency may not approve a project in reliance on a categorical
exemption if, owing to special circumstances, it can be fairly argued the project would have one or
more significant impact on the environment. Here, the circumstances of this Project are highly
unusual in that the Project is located in the midst of a several historically significant resources
which the Project may adversely affect.
To prove that an exemption does not apply owing to the "unusual circumstances," a
"challenger must prove both unusual circumstances and a significant environmental effect that
is due to those circumstances. In this method of proof, the unusual circumstances relate to
some feature of the project that distinguishes the project from other features in the exempt
class." [] "Once an unusual circumstance is proved under this method, then the `party need
only show a reasonable possibility of a significant effect due to that unusual circumstance.'
Walters v. City of Redondo Beach (2016) 1 Cal.App.5th 809, 819-820 ("Walters"
The Project presents unusual circumstances because, as set forth above, the Report clearly
indicates that there are ten mandatory and presumptive historic resources in the immediate Project
area, including the NRHP Jack House and Wash House; the Master List Jack Garden and Carriage
House, Kaetzel House, Pollard House, Norcross House, and Golden State Creamery; the
Contributing List Wilkinson House; and the Pinho House. The proximity of such a large number of
historically significant resources that could potentially be adversely affected by the Project is an
unusual Project feature that is unlike any typical infill project to which the Class 32 exemption
would apply. There is no evidence to suggest a typical infill project would be located in the
vicinity of, and be capable of causing adverse impacts on a substantial number of historically
significant structures.
The Resource agency [the author of CEQA Regulations] cannot have intended to exempt infill
projects capable of causing substantial adverse impacts on nine historically significant structures
and one cultural landscape. Comm. to Save the Hollywoodland Specific Plan v. City of Los
An eles (2008) 161 Cal. App. 4th 1168, 1187(unusual circumstances exception applied where the
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project --consisting of the placement of a 42 inch fence on a unique and historic wall-- created an
environmental risk to a historic resource that does not exist for the general class of exempt
projects.) "A categorical exemption is based on a finding by the Resources Agency that a class or
category of projects does not have a significant effect on the environment." Davidon Homes v.
City of San Jose (1997) 54 Cal.AppAth 106, 115. Accordingly, the circumstances of the Project
must be considered "unusual" within the meaning of CEQA.
Moreover, as set forth above and in the Report, the Project may have a substantial adverse impact
on a number of historically significant buildings, particularly the Pollard House, the Norcross
House, the Pinho House, and the Jack House. Accordingly, the unusual exception applies because
it can be fairly argued that owing to special circumstances, the Project is capable of causing a
significant adverse environmental impact. See, also, expert comments of James Papp., Ph.D., filed
separately, regarding the Project's adverse and substantial impact on the significance of historic
resources.
The Proiect does not come within the scope of Class 32 exemption because it is not consistent
with all apWicable General Plan Policies and Guidelines.
To be eligible for a Class 32 exemption, the Project must be "consistent with the applicable
general plan designation and all applicable general plan policies as well as with applicable zoning
designation and regulations." Guidelines § 15332. Here, the evidence shows the Project is not
consistent with all applicable policies.
Of particular relevance to this Project is City Design Guideline 3.2.2., according to which "New
development should not sharply contrast with, significantly block public views of, or visually
detract from, the historic architectural character of historically designated structures located
adjacent to the property to be developed, or detract from the prevailing historic architectural
character of the historic district." The comments of Dr. James Papp, Ph.D., and the analysis in the
Report support a finding that the Project sharply contrasts with, and visually detracts from historic
resources, particularly the Pollard House and the Norcross House.
The Project is also inconsistent with Guideline 5.3.C., which directs that "The height of infill
projects should be consistent with surrounding residential structures. Where greater height is
required, an infill structure should set back upper floors from the edge of the first story to reduce
impacts on smaller adjacent homes, and to protect solar access." There is no question that the
height of this Project is inconsistent with surrounding residential structure, particularly the Pollard
House which is immediately adjacent to the Project.
The City may not rely on mitigation measures to conclude the Proiect is exempt, or one of
the exceptions do not apply
It is well -settled that an agency may not rely on mitigation measures to conclude a project is
Packet Page 128
categorically exempt, or that that an exception to the exemption does not apply. See, Kostka and
Zischke _Practice Under the California Environmental Quality Act, 2nd Ed., at §5.75, citing Salmon
Protection and Watershed Network v. County of Marin (2004) 125 Cal.AppAth 1098, 1102. See,
also, Azusa Land Reclamation Co. v. Main San Gabriel Basin Watermaster (1997) 52 Cal.AppAth
1165,1200. "In determining whether the significant effect exception to a categorical exemption
exists, "[i]t is the possibility of a significant effect ... which is at issue, not a determination of the
actual effect, which would be the subject of a negative declaration or an EIR. Appellants cannot
escape the law by taking a minor step in mitigation and then find themselves exempt from the
exception to the exemption."
"A mitigation measure, ..., involves "feasible changes in any or all activities involved in the
project in order to substantially lessen or avoid significant effects on the environment...." (CEQA
Guidelines, § 15041, subd. (a).)" Mission Bay All. v. Office of Cmty. Inv. & Infrastructure (2016)
6 Cal. App. 5th 160, 184. While the distinction between a mitigation measure and a project feature
may not always be crystal clear (Lotus v. De12't of Transportation (2014) 223 Cal. App. 4th 645,
656, fn 8), the general rule is that measures whose only function is to "reduce or eliminate" one or
more potentially significant impact on the environment are properly characterized as mitigation
measures and are not properly considered as project feature. Id.
The Report explains that "the incongruent height and massing of the building, which stretches the
full width of the block, is responsible for the incompatibility of the project as a whole." Report at
p. 34. The "incompatibility of the Project with these historic resources, therefore, is largely owed
to the Project's height and massing.
To address this incompatibility, the author of report proposes the following "recommendations:"
• Break up the solid mass of the building, which stretches the full width of the
block, into two (orthree) separate, offset elements that better reflect the surrounding
building scale and spatial relationships.
Relocate the 545 Higuera Street building to the opposite side ofthe driveway
to allow the Pollard House more space. Landscaping the currently proposed
location would provide screening and a beneficial buffer.
Confine the four-story set -back element to the middle of the block.
Report, at p. 35.
The PC, likewise, has suggested mitigation measures to reduce the Project's impact on the
surrounding historic resources. According to the Staff Report, at the January 8, 2020 meeting, the
PC provided the following direction to the applicant: "The exteriors of both buildings A and B
shall be redesigned to bring them into compatibility with adjacent and surrounding architectural
forms that reflect and preserve the historic character of the downtown area and equally important
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in size and scale." This appears to be a mistake as it appears that the PC actually directed the
applicant to consider setback. In any event, the fact remains that the PC directed the applicant to
come up with mitigation measures to reduce the Project's impacts on the adjacent neighborhoods.
According to the Staff Report, the applicant's "proposed revisions" are intended to "promote
improved neighborhood compatibility and preservation of the historic character of the downtown
area, and soften the overall appearance of the buildings include:..." These proposed revisions
must likewise be considered mitigation measures as they are clearly intended to reduce an adverse
impact, i.e., incompatibility with historic character of the neighborhood.
The foregoing demonstrates that the PC, staff and the applicant continue to struggle to find
mitigation measures to reduce the Project's impacts on historic resources. While SLAP comments
the PC and the applicant's efforts to improve the project, we must not lose site of the fact that
consideration of the efficacy and feasibility of mitigation measures must be governed by CEQA
standards that govern the preparation of negative declarations and EIRs.
Conclusion
This Project would cause particularly palpable and significant adverse impact on this historically
significant neighborhood because it is a "large-scale, multi -story pioneer in the neighborhood."
Report at p. 33. As such, this Project could set a new precedent in favor of large multi -story in this
neighborhood, making it nearly impossible for the City to deny any future large-scale projects on
the basis of incompatibility with the scale of the historic resources of the neighborhood. As such,
the law demands that the Project's impacts and any feasible mitigation measures and alternatives
be carefully and transparently considered in the regular course of environmental review. The infill
exemption was not intended to apply to such a Project. I therefore urge you not to approve the
Project at this time.
Sincerely,
LAW OFFICE OF BABAK NAFICY
Babak Naficy,
Counsel for SLAP
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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
Tomas 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, 41/s-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, 1B76 (detail).
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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/Butr6n, 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
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)
2
VI
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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 comprised
fifty percent of that area's buildings as of two years ago, 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 lack 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.
k]
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Craftsman duplex at 464 Marsh (left) and the Modern on Marsh (center)
The 36 new 2- to 41/z-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 E1R 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
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Akt-MEI12
Save Our Downtown
Seeking to protect and promote the historical character, design, livability and economic
success of downtown San Luis Obispo.
To: San Luis Obispo Planning Commission & Shawna Scott, Senior
Planner
Re: January 8, 2020 Meeting Item Number 2: 545 Higuera & 486 Marsh
From: Allan Cooper, Secretary Save Our Downtown
Date: January 6, 2020
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HIGUERA ST
Honorable Chair and Commissioners -
Permit us to quote an excerpt from a January 6, 2020 letter that you received from Mr. James
Papp.
"As you're aware, the CHC and ARC now report to the Planning Commission, whose role must
now include correcting any deficiencies in those bodies' quasi-judicial deliberations, including
any whose arbitrariness and capriciousness put the city in legal jeopardy."
We concur with Mr. Papp. And staff has stated the same under 1.0 "Commission's Purview" in
your staff report. Your new purview is no longer limited to consistency with the General Plan
and Zoning Regulations. You are now obligated to review the project for its consistency with
the Community Design Guidelines (CDG) and other applicable City development standards.
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Akt-ME12
Therefore, we are urging you to address this project's numerous inconsistencies with respect to
the City's Community Design Guidelines.
1) Overall design objectives for commercial projects includes the following: "Consider San
Luis Obispo's small town scale and demonstrate sensitivity to the design context of
the surrounding area." The architect has chosen a "contemporary" theme for these
buildings. However, there are very few examples of "contemporary" architecture in this
neighborhood (excepting of course the architect's two most recent additions - the cargo
container complex called Downtown Terraces and the condominium complex flanking
Gennaro's). Previous additions to this neighborhood, including the Manse and the Bank of
the Sierra, have tried with some success to work with more "historical" and "residential"
themes. The ARC made no reference to this concern.
2) Neighborhood compatibility guidelines include the following: "Proportional building scalel
size;" and "Appropriate building setbacks and and massing;" Even though the architect
made a tentative attempt to step down the massing to the height of the Pollard House,
previous ARC direction called for stepping back the third floor massing not only along
Higuera Street but also along Marsh. This, in addition to breaking up the street setbacks,
would be a more sympathetic response to the predominantly two-story Manse, the two-
story Bank of the Sierra and the one-story Pinho House. More variety in the color palette
along the horizontal dimension, particularly along the facades facing the parking lot, would
help to further break up the scale of the buildings. For example the "light bronze" color for
the storefront panels could change to a lighter or darker color halfway along the length of
either Buildings A or B.
3) Tall buildings (between 50 and 75 feet) shall be designed to achieve multiple policy
objectives, including design amenities, housing and retail land uses. Appropriate techniques
to assure that tall buildings respect the context of their setting and provide an appropriate
visual transition to adjacent structures include, but are not limited to: "On upper floors,
consider using windows or other architectural features that will reinforce the typical
rhythm of upper story windows found on traditional commercial buildings and provide
architectural interest on all four sides of the building;" Presently, the commercial scale of the
windows involve large expanses of glass facing both Marsh and Higuera Street. These jar in
both scale and proportion with the windows on the Bank of the Sierra (see below), with
those on the Norcross House and even with those on the architect's own Downtown
Terraces project. A simple solution would be to introduce into these recessed window bays
dimensional fins running in both the vertical and horizontal direction as these would help to
break down the scale. These fins would also provide much needed solar shading.
4) Another appropriate technique to assure that tall buildings respect the context of their
setting and provide an appropriate visual transition to adjacent structures is to "Reinforce
the established horizontal lines of facades in adjacent buildings;" In order to
accomplish this the Marsh Street facade should step back above the second floor in order
to respect the height of the Bank of the Sierra. Similarly, the Higuera Street facade should
step back above the first floor in order to respect the height of the Pollard House.
Thank you for your consideration.
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r� ��. �f� •L--f� '1 1 OItem #12
12. Review of an Appeal (filed by San Luis
Architectural Protection) of the Planning
Commission's decision to approve a four-
story Mixed -Use Project (545 Higuera Street,
486 Marsh Street, ARCH-0017-2019)
Staff Presentation By:
Michael Codron, Community Development Director
Shawna Scott, Senior Planner
545 Higuera Marsh
APPL-0201-2020
Appeal of a four-story mixed -use project consisting of
5,241 square feet of ground -floor commercial, 8 hotel suites, and
39 residential units, including a mechanical lift and fourth floor roof
deck, with a categorical exemption from environmental review
June 2, 2020
Applicant: Taylor Judkins, G3 Concepts
Representative: Jessie Skidmore, TenOver Studio
Recommendation and Purview
Recommendation: Adopt a resolution (Attachment A)
denying the appeal and upholding the
Commission's approval of the project.
Planning
Project Site - Two parcels (0.79 acre
Downtown Commercial Zone
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Project Description
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BUILDING A BUILDING B
3,198 sf of retail space (Higuera Street)
3 studio units (448 to 530 sf)
6 one -bedroom units (671 to 874 sf)
3 two -bedroom units (938 to 1,001 sf)
8 hotel suites (372 to 1,260 sf)
Wrap -around walkways and decks, private balconies
Long-term bicycle storage room
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2,043 sf of retail space (Marsh Street)
5 studio units (447 to 629 sf)
14 one -bedroom units (700 to 807 sf)
8 two -bedroom units (798 to 1,174 sf)
Wrap -around walkways and decks, private balconies
705-square foot roof deck on the fourth floor; private
balconies
Enclosed garage & three -level mechanical parking lift
Project Description
Site Plan
• Two buildings connected by 4t" floor
walkway
• Existing drive between Higuera and Marsh
to remain, crosswalks across drive
• 26 surface parking spaces
• 48-space mechanical lifts
• 21 short-term bicycle spaces
• 39-long term bicycle storage and space
within units
• Pedestrian walkways & patios
• Trees along southwest property boundary
and street frontage
• Public patio with seating and horizontal
wood screen fence
Site Plan — Landscaping
Background
• The Architectural Review Commission (ARC) reviewed the proposed
project on September 9, 2019 and October 21, 2019 for consistency
with the CDG and voted to recommend approval of the project with
additional direction for minor modifications (7-0).
• On January 8, 2020, the Planning Commission reviewed the proposed
project on January 8, 2020, and a motion passed (5-2) to continue the
item to a date uncertain with direction provided to the applicant, related
to consistency with the CDG.
• The applicant incorporated design changes to the project, which were
reviewed by the Planning Commission, resulting in the Planning
Commission's approval of the project on February 26, 2020 (4-2-1).
Appeal Item #1: Project not consistent with Community Design
Guidelines Chapter 5 (Residential Project Design) and 1.4
• Staff Analysis:
• Mixed -use Project is in the Downtown Commercial (C-D) zone;
CDG Chapter 5 does not apply
• Project is consistent with CDG 1.4(A)(4):
1.4 — Goals for Design Quality and Character
A. Keep San Luis Obispo architecturally distinctive, don't let
it become "anywhere USA."
4. Design with consideration of the site context in
terms of the best nearby examples of massing,
scale, and land uses when the site is located in
a notable area of the city (for example, the
Downtown, Old Town).
Community Design Guidelines Consistency
Materials and Colors
Limestone material is
replaced by brick, and
metal and wood siding
materials are replaced by
smooth -finished stucco
Lighter shades of tan,
particularly on the second
and third floors
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• Modification of balcony
railings from metal and
glass to all metal
Community Design Guidelines Consistency
Windows
Shape, size, orientation, Windows on all elevations will be
framing, and location of the
windows has been modified to
reflect existing vertically -
oriented windows on
neighboring buildings
consistent, and clear glass is
proposed
Larger window headers (light in color)
and a reduction in the metal and
glazing between windows
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Community Design Guidelines Consistency
Other Details
Bulkhead incorporated into the
stepped -back storefront (which also
reduces the size of the storefront
windows) on the north elevation of
Building B (Marsh Street)
Vertical rather than angular canopy
posts to better reflect linear posts
present on proximate buildings
V. -
Community Design Guidelines Consistency
Other Details
Overall massing is broken down with decks and balconies, additional
decks and balconies are shown on the second and third floors
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Proximity to Pollard House:
Building fagade lowered to two
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FIRST FLOOR �
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29-foot setback (43 feet from
Pollard House)
5-foot step -back (3rd floor)
5-foot step -back (4th floor)
Landscaping, trees
Historic analysis determined no
significant impact to historic
resources
Visual Transitions
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Appeal Item #2: Project not exempt from CEQA, would cause
substantial adverse change in the significance of historic
resources
15300.2 (Categorical Exemptions, Exceptions): A categorical exemption shall not be
used for a project which may cause a substantial adverse change in the significance
of a historical resource.
15064.5 (b) (Determining the Significance of Impacts to Archaeological and Historical
Resources): A project with an effect that may cause a substantial adverse change in
the significance of an historical resource is a project that may have a significant effect
on the environment.
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 an historical resource is materially impaired when a
project: 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, local register
of historical resources.
California Environmental Quality Act (CEQA)
SWCA Historic Preservation Report and Historical Compatibility Improvement Letter:
Does not identify a substantial adverse change as defined by CEQA
States that none of the adjacent historic properties and none of the more
distantly located historic properties will be subject to any indirect impacts that
threaten their eligibility as significant historical resources.
Appeal Item #3: Owing to unusual circumstances, project is
capable of causing significant adverse impact on historical
resources
Staff Analysis:
Project is consistent with the General Plan and meets the intent of the General
Plan for the Downtown
Project is consistent with the Downtown Concept Plan
A mixed -use project consistent with the Zoning Regulations for the C-D zone
The project's height, size, and scale are generally consistent with other buildings
in the Downtown
The presence of historic resources is not an unusual circumstance in the
Downtown and infill environments to which the exemption applies
Appeal Item #4: Project not subject to "infill" exemption or any
exemption because inconsistent with CDG and LUCE CR-2
3.3.5
Staff Analysis:
Conservation and Open Space Element Policy 3.3.5 (Historic districts and
neighborhoods) states that: "In evaluating new public or private development, the
City shall identify and protect neighborhoods or districts having historical
character due to the collective effect of Contributing or Master List historic
properties."
The project site is not located within an identified historic district or
neighborhood, and the project site is currently developed with commercial and
office development, and the General Plan and Downtown Concept Plan calls for
the type of development proposed in this location.
• The project incorporates features to provide separation and transition between
the site and the identified historic resource and would not affect the eligibility of
those resources to remain.
Appeal Item #5: Project not subject to exemption due to
incorporation of mitigation measures
Staff Analysis:
The proposed project's modifications through staff and advisory body review do
not constitute mitigation measures as defined by CEQA. No significant adverse
impact to historic resources was identified for the project as currently proposed.
Appeal Item #6: Project is capable of causing cumulatively
significant impact on historical resources
Staff Analysis:
While the combination of other projects in the vicinity have resulted in a
cumulative effect, none of the projects resulted in a significant effect and as
noted above, the proposed project would not have a significant effect on
historical resources as defined by the State CEQA Guidelines.
The project is consistent with the General Plan and Zoning Regulations, in
addition to the CDG, and would not have a project -specific or cumulative effect
on aesthetics.
Appeal Item #6: Project is capable of causing
cumulatively significant impact on historical resources
Land Use and Circulation Element (LUCE) EIR Aesthetic Cumulative Impacts Analysis
Section states the following:
"Overall, development under the General Plan would increase development
intensity within the city limits, as well as undeveloped areas to a more built
environment, thereby altering the fundamental character of these areas, and
increasing light and glare."
The General Plan and the Community Design Guidelines (CDG) "protect the
city's visual features through policies and plan review. Adherence to these
requirements would reduce any impacts from buildout... to a less than significant
level."
Project has been reviewed by the Architectural Review Commission (ARC) whose
purview consists of review of consistency with the CDG; the ARC recommended
approval of the project with previously -noted minor modifications.
Previously -approved projects in the neighborhood and vicinity were found to be
consistent with the General Plan and CDG.
• Therefore, no significant cumulative aesthetic impacts would occur.
Appeal Item #7: Project not a
Staff Analysis:
housing development project
Project is a mixed -use development consisting of 2/3 residential uses, meeting
the Government Code definition of a housing development project.
Appeal Item #8: Project would cause a significant impact on
historic resource as defined by the Historic Preservation
Ordinance
Staff Analysis:
The Historic Preservation Ordinance (HPO) identifies an adverse impact as
"effects, impacts or actions that are detrimental or potentially detrimental to a
historic resource's condition, architectural or historical integrity."
Historical Compatibility Letter concludes that none of the adjacent historic
properties and none of the more distantly located historic properties will be
subject to any indirect impacts that threaten their eligibility as significant historical
resources.
Appeal Item #9: Project was not evaluated by the Cultural
Heritage Committee
Staff Analysis:
The HPO, specifically section 14.01.030(C)(7) states that the Cultural Heritage
Committee (CHC) shall review and make recommendations ... on applications
and development review projects which include ... the following: Proposed actions
of public agencies that may affect historic or cultural resources within the City.
HPO Section 14.01.040 states that the Community Development Director is
responsible for interpreting and implementing this ordinance and helping the
CHC carry out its duties. Notwithstanding Section 14.01.030C 1-5 and 7 of this
ordinance, the Director may determine that CHC review is not required for
actions or projects that do not adversely affect historic resources.
As noted above, the project would not have an adverse effect on historic
resources; therefore, the project was not referred to the CHC.
Questions for staff?
Project Desc
Site Plan
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entrance & storage within units
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Project Description
E Rn F
• Height: 50 feet, 58-foot tall
elevator tower
- Materials: stucco, limestone,
concrete bulkhead, wood siding,
metal accents
V floor step -back: 5 feet (SW)
4t" floor step -back from 2nd floor:
- 5 feet (north)
- 5 to 7 feet (south)
- 5 to 12 feet (west)
- 10 to 15 feet (east)
Evaluation Summary
Project consistent with General Plan
Commercial and residential uses
Provides public gathering space and walkways
Design shows setbacks, step -backs, and landscaping, demonstrating
compatibility with proximate structures
Project complies with Zoning Regulations
Project complies with Mixed -use Design Standards and Criteria and
Performance Measures (as proposed and conditioned)
Visual study did not identify adverse impacts
No significant impacts to proximate historic resources
•
Item #12 (continued)
PUBLIC HEARING ITEM
545 Higuera & 486 Marsh
(ARCH-001 7-2019)
Appellant Team Presentation By:
Babak Naficy
James Papp
"It is the policy of this state to take all action
necessary to provide the people of this state
with clean air and water and enjoyment of
aesthetic, natural, scenic, and historic
environmental qualities"
California Environmental Quality Act, 1970
F owl46,
•
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Appeal of Planning Commission Approval of 545 Higuera-486 Marsh
San Luis Architectural Preservation! and Save Our Downtown
545 Higuera-486 Marsh is not consistent with the Community Design Guidelines
545 Higuera-486 Marsh is not eligible for an infill exemption or any other exemption from CEQA
environmental review because of
• the exception for substantial adverse change in the significance of historical resources
• the exception for significant effect on the environment due to unusual circumstances
• the exception for cumulative impact on the aesthetic and historical environment
• failure to apply earlier LUCE mitigation, including the Community Design Guidelines and the
Conservation and Open Space Element
• the requirement to incorporate mitigation measures
545 Higuera-486 Marsh is not a "housing development project" subject to the Housing
Accountability Act
Losing eligibility for historic resource listing is neither defined nor recognized under SLO's Historic
Preservation Ordinance or CEQA Statute, CEQA Guidelines, or CEQA case law as the criterion for
substantial adverse change in the significance of a historical resource
The Historic Preservation Ordinance requires evaluation of 545 Higuera-486 Marsh by the Cultural
Heritage Committee for "proposed actions of public agencies that may affect historic or cultural
resources within the City"
lI2.IS5I0I2 PLH,
In the 1950s. Kenneth Schwartz, then Planning; Commis
and Cal Poly Prolessor of Architecture, began work in s
the creation of "Mission I'lar_a". At that time, traffic on,A
Street passed near the Mission, resulting in an unkc•mp
blighted area.'rhrough Ken's vision, perseverance, an(
dedication, the creation of a community plaza in Irmil c
historic Mission was launched by voter approval in 19(
.. A "The Plaza is a people place and t hal
is what cities are all about - peol)le" saii
r Mayor5chwartzon the ltlth anniversar
of Mission Plaza.
Please enjoy your lime hi Mission Plaza
and the legacy of beloved San Luis
Obispo Mayor, Kennet Schwartz.
•
Item #12 (continued)
PUBLIC HEARING ITEM
545 Higuera & 486 Marsh
(ARCH-001 7-2019)
Applicant Team Presentation By:
Joel Snyder, Ten Over Studio
CITY OF SAN LUIS OBISPO - MAJOR GOALS
MOUSING: facilitate the production of housing with an update of the housing
elemenl, including an emphasis on affordable housing (including unhoused people)
and workforce housing through the lens of climate action and regionalism.
FISCAL SUSTAINABILITY AND RESPONSIBILITY: Continue to implement
the City's Fiscal Responsibility Philosophy with a focus on efficiencies, strategic
economic development, unfunded liabilities, and infrastructure financing (Funding
the Future).
SUSTAINABLE TRANSPORTATION: Enhance accessible regional transit,
bicycle, and pedestrian mobility to promote a transition to a car -free or shared -car
lifestyle and to reduce greenhouse gases.
CLIMATE ACTION: In response to the climate crisis, continue to update and
implement the Climate Action Plan for carbon neutrality, including preservation and
enhancement of our open space and urban forest and planning for resilience.
DOWNTOWN VITALITY: Support the economic and cultural heart of the City with
attention to safety, maintenance, infrastructure, and amenities.
PROJECT DETAILS
The project includes 39 RESIDENTIAL UNITS in a mix of studios,
1-bedroom, and 2-bedroom units: to MAXIMIZE DENSITY
Provides RETAIL AND RESTAURANT opportunities t( REVITALIZE
THE SOUTH END OF DOWNTOWN
Accomodates parking with CAR LIFTS. This allows for conversion
of this area to future retail use or residential amenities, should car
dependency decrease.
Provides a ONE-WAY VEHICULAR LOOP (in on Marsh, out on
Higuera) to mitigate traffic Downtown.
Utilizes only half of the allowable footprint and adds 27 NEW ON -SITE
TREES.
Provides a MID -BLOCK PEDESTRIAN CONNECTION trom Marsh to
Higuera.
Enhances the pedestrian experience with a LARGE PUBLIC ART
MURAL.
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(E) AGJACENT BUILBING
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SMALLER FOOTPRINT
BUILDABLE AREA
32,820 SF
PROPOSED BUILDING AREA
17,743 SF
DELTA = 15,077 SF
GARDENS, PATIOS, 5
PARKS
1. 29' SETBACK TO P.L.
ADJACENT TO POLLARD
HOUSE
2. SPLIT BUILDINGS INTO
TWO FOR CONTIGUOUS
PEDESTRIAN CONNECTION
3. EXTRA WIDE SIDEWALK
W/ TREES B BENCHES
ALONG PUBLIC ART MURAL
27 NEW ON -SITE TREES
PEDESTRIAN LINKS
MID -BLOCK CONNECTIONS
CONSISTENT WITH
DOWNTOWN CONCEPT PLAN
DOWNTOWN CONCEPT PLAN
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11
TRAFFIC FLOW
VEHICLES ENTER FROM
MARSH STREET & EXIT
TOWARDS HIGUERA STREET
AVOIDING DOWNTOWN CORE
PROMOTES FOOT 5 BICYCLE
TRAFFIC OVER CARS IN THE
DOWNTOWN
75'
�I is
fi 0'
5 0'
HIGUERA ST.
75'
ai iJ
60'
MARSH ST.
MASSING IN ELEVATION
ALLOWED HEIGHT = 50'
ALLOWED SETBACKS = 0'
60'/75' = ADDITIONAL
HEIGHTS ALLOWED THROUGH
CITY POLICY OBJECTIVES
J
60,
r, 50'
4TH STORY SETBACK
HIGUERA ST.
J� la
i I
4TH STORY SETBACK
MARSH ST.
MASSING IN ELEVATION
MASSING WITH DESIGN
GUIDELINE PRINCIPLES
APPLIED
1. LOWER HEIGHTS AT P.L.
2. SETBACK AT 4TH STORY
75'
�I is
HIGUERA ST.
MARSH ST.
MASSING IN ELEVATION
PROPOSED BUILDING IS
WITHIN HEIGHT LIMITS
PROPOSED BUILDING IS
WELL WITHIN WIDTH LIMITS
PROPOSED BUILDING STEPS
DOWN TO ONE AND TWO
STORY MASSING AT A
PORTION OF STREET FACADE
FOR VISUAL TRANSITION
TENOVER SDEMarshS EX,G4
San Uk Dhlspe, CA 545 HIGUERA MIXED -USE
805.5at.l ato 545 HIGUERA STREET. SAX LUI3 OBISPD. GA
intaQlenorersWtliacom DATE:I) /02/202D
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545 HIGUERA MIXED -USE
545 HIGUERA STREET. SAN LUIS OBIS, CA
BAT E:0 6/02/2020 EXoG5
APPELLANT'S ARGUMENT:
The project is not consistent with the Community Design Guidelines (CDG).
APPELLANT'S REFERENCES:
CHAPTER 1:
Introduction and Applicability: 1.4(A) (4), 7(5):
CHAPTER 3:
Commercial and Industrial Project Design: City Design Guideline 3.2
CHAPTER 5:
Residential Project Design: 5.3.A,1, 5.3.C, 5.4.A.1, 5.4.A.3, 5,4,C.1,and 5.4.C.2
APPELLANT'S ARGUMENT, [CONY]:
The project is not consistent with the Community Design Guidelines
CHAPTER 3 is applicable only to COMMERCIAL AREAS OUTSIDE OF THE DOWNTOWN.
CHAPTER 5 is relevant only for RESIDENTIAL NEIGHBORHOODS.
CHAPTER 1 is an overall summary of goals that is then broken down in to specific
chapters per zoning.
Our project is located in the C-0 DOWNTOWN COMMERCIAL, where the goals and
design guildelines are outlined in CHAPTER 4 - DOWNTOWN DESIGN GUIDELINES.
The guidelines under CHAPTER 3 5 5 ARE NOT APPLICABLE to this project.
The appeal does not contest our compliance with CHAPTER 4.
This project has been refined through 4 Entitlement hearings (2 ARC and 2 Planning
Commission) to land on the current APPROVED PROJECT REVIEWED UNDER CHAPTER
4 GUIDELINES AND REGULATIONS.
MARSH STREET ELEVATION - REFINEMENTS
1. Project proposes massing CONSISTENT WITH OTHER MIXED -USE PROJECTS
DOWNTOWN. Proposes step back after second or third floor and VARIETY ALONG THE
STREET FRONT to further break down massing)
2. Material change to BRICK AND STUCCO (from limestone, metal, and wood)
PREVIOUS
HIGUERA STREET ELEVATION- REFINEMENTS
1. Reduced the SIZE OF WINDOWS and added MORE DECKS.
2. Created a more regular,& traditional window pattern EMPHASIZING THE VERTICAL
over the horizontal, to tie into nearby architectural languages.
PREVIOUS
CURRENT
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