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Home My WebLink About6/1/2021 Item 6a, Ulz Wilbanks, Megan From:Pease, Andy Sent:Monday, May 31, 2021 4:56 PM To:E-mail Council Website; Eva Ulz Cc:Shannon@greatbeer.us Subject: in Favor of an Updated Historic Resources Survey Attachments:Eva's Arguments in Favor of Updating Historic Resources Survey.pdf For distribution to council, re: June 1, 2021 item 6a Financial Plan. Eva – Thanks for the follow up on the CHC priority for updating the city’s Historic Resources Survey. I’m copying to council and staff. I’ll also share your earlier remarks about process: Eva: I think there is good reason to consider a staged approach to updating the survey, as Shannon \[Larrabee\] has wisely championed in our recent CHC meetings. And there is no reason that we couldn't incorporate a considerable volunteer component to both save some money AND raise public awareness/involvement with the city's historic preservation programs. But I feel pretty strongly that we ultimately need to hire a knowledgeable consultant to plan and oversee the project. We've heard case studies about consultant/volunteer collaborations to conduct surveys using some pretty cool digital app technology in other cities at past California Preservation Program conferences. I believe Sacramento recently completed theirs. Andy Andy Pease pronouns she/her/hers Council Member Office of the City Council 990 Palm, San Luis Obispo, CA 93401-3249 E apease@slocity.org slocity.org Stay connected with the City by signing up for e-notifications For updates on COVID-19 and how to access City services during COVID, visit slocity.org/covid19 From: Eva Ulz < Sent: Monday, May 31, 2021 1:04 PM To: Pease, Andy <apease@slocity.org>; Shannon Larrabee < Subject: Outline of Arguments in Favor of an Updated Historic Resources Survey 1 This message is from an External Source. Use caution when deciding to open attachments, click links, or respond. Hey there, I've attached a PDF with my thought outline on why we need to update the survey sooner rather than later and how it will benefit the City. Let me know if you have trouble opening the file. I think there is both a duty to update under Certified Local Government requirements, plus it will save the City a lot of time, money, legal risk, and general heartache in the long run. What I don't have immediate info available on is what it might cost and what a project might look like that uses a consultant for planning/reporting the survey and volunteers to carry it out on the ground. I'm sure we could easily get some quotes from consulting firms, or perhaps even better, Brian (or I'm happy to do it if Michael and Brian feels it's appropriate) could reach out to his counterpart in one of the cities that presented on a similar project at the 2019 California Preservation Conference. I'm sure we could get a list of the cities/consultants that ran that workshop pretty easily. Again, thank you both for looking into this and advocating for it! Whatever it costs, I think it would be a great investment and quickly realize returns for the City in streamlining the development and permitting processes. Happy Memorial Day, Eva 2 ARGUMENTS FOR THE CITY’S HISTORIC RESOURCES SURVEY UPDATE  Historic Resource Surveys serve an important local planning purpose, by proactively identifying properties that the City wishes to preserve. o “To make effective use of historic resources, to respect their value and extend their lives, it is necessary to integrate historic preservation into community planning. This is the immediate reason for undertaking a local historic resources survey: to gather the information needed to plan for the wise use of a community's resources.” National Register Bulletin 24: Guidelines for Local Surveys: A Basis for Preservation Planning (Recommended guidance from CA State Historic Preservation Officer (CA SHPO).) o The practical effect of the recent decision in Friends of Willow Glen Trestle v. City of San Jose is that it is now much more difficult to protect historic resources that aren’t already identified as historical by the lead agency or the state commission at the time a project that might impact them is proposed. This means that the City’s preservation efforts need to become proactive, rather than reactive.  An accurate and up‐to‐date Historic Resource Survey provides residents and developers with reasonable and reliable expectations about which projects could have potential impacts on historic resources. o Lead agencies like SLO have considerable deference in determining whether a resource is historical or not. Recent case law has set the standard of review for such decisions as “substantial evidence” rather than “fair argument.” This means that once the City has considered and made a decision about the historicity of a particular site, that decision cannot be easily disturbed and is therefore reliable. o On the other hand, many of the contributing list buildings, especially those identified in passing during the 1983 and 1992 surveys, lack any substantial evidence to justify their inclusion in the City’s Historic Resources Inventory. This is another legal battleground that CHC already deals with on a regular basis. It unfairly burdens residents and developers and adds unnecessary time and costs to the permitting process.  Under California Office of Historic Preservation (OHP) Guidelines for Certified Local Governments (CLG), Cities like SLO must regularly update their historic resources surveys, ideally every five years: o The State’s Certified Local Government (CLG) Requirements establish an affirmative duty to “Maintain a system for the survey and inventory of historic properties . . . procedural requirements must allow for periodic update of survey results as buildings gain maturity and as new areas are incorporated or annexed by the CLG.” o “While an existing survey over five years old can provide valuable information, it is appropriate to update the survey to ensure that local planning and preservation decisions are based on the most current information available.” – CA OHP website o “Surveys should be updated regularly to consider properties that may have achieved significance since the survey was originally conducted and to incorporate resources that were initially overlooked. Updating an existing survey offers an opportunity to identify and document physical changes that have occurred to a property and its surroundings since the last survey, and to identify sites where historic properties have since been moved or demolished. Finally, as architectural values were often the only criterion for significance in older surveys and resources were frequently only evaluated for the National Register, a survey update should provide for reevaluating properties within broader historic contexts using local, California, and National Register criteria.” – CA OHP website o The City’s last historic resource survey was conducted nearly 30 years ago in 1992, and the entire City has never been surveyed. There are two‐decades worth of buildings that have now aged into eligibility. On the other hand, there are also a number of buildings that were identified as historic by the original 1983 and 1992 surveys with no substantial evidence in the City’s records to support that determination.  SLO’s Historic Resources Surveys (nearly 40 and 30 years old respectively)—and to a lesser extent the nearly decade old Historic Context Statement completed in 2013, do not meet modern standards for diversity and inclusion. o The Historic Resources Surveys were completed during an era when preservation was focused solely on architecture and “founding father” type criteria for inclusion. Very few sites honoring minorities have been identified, even though there are plenty of extant resources that could be added to the City’s Master List, etc., e.g. St. Luke’s Missionary Baptist Church (one of the City’s historic African‐American churches) which sits within an area that could easily become a historic district honoring Japanese Americans. o The 2013 Historic Context Statement is better, but it still includes themes of ethnic minorities as a sidebar, rather than weaving them throughout, and makes no mention whatsoever of other diverse themes, e.g. LGBTQ history, that are now considered vital aspects of equitable and inclusive local history programs. o New types of historical resources, e.g. cultural landscapes, are becoming the standard in the preservation field. These new tools go a long way to broaden and redefine how localities think about historic resources in order to include more diversity.  SLO has a duty to participate with Federal and California preservation programs, by identifying and nominating especially significant historical resources to the State and National Registers. An updated historic resource survey would provide the opportunity to do this—and increase the opportunity for collaboration with the community around preservation issues. o Support for this proposition is scattered throughout federal and state legislation and guidelines, but I don’t have anything queued up – let me know if you need more info and I can dig it out.