HomeMy WebLinkAbout6/26/2024 Item 4a, Terry, W.
Wayne Terry <
To:Advisory Bodies
Subject:Appeal of ARCH-0448-2022
Attachments:Correspondence forward to PC re ARCH-0448-2022 appeal.pdf
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Hello,
I'd like to request my attached correspondence be forwarded to the Planning Commision in anticipation
of the scheduled meeting on 6/26/24.
Sincerely,
Wayne Terry
1902 Chorro St.
San Luis Obsipo
1
June 20, 2024
Planning Commission
City of San Luis Obispo
990 Palm Street, San Luis Obispo
Re: Appeal of ARCH-0448-2022
1925 Santa Barbara – Mixed Use Development
Dear Planning Commissioners,
In anticipation of next week’s meeting, I am forwarding to you copies of relevant correspondence
regarding the project above, including:
• The text included as part of my appeal application
• Correspondence provided to the Community Development Director prior to her decision
• Response from city staff regarding the Community Development Director’s decision
Thank you for your time.
Sincerely,
Wayne Terry
1902 Chorro Street
San Luis Obispo
I believe my appeal should be considered based on the following:
My right to public comment was hindered by the clerk at the Cultural Heritage Committee. They
refused to allow me to show my power point presentation (in pdf form). I was told that such
presentations had to be submitted by noon the day of a meeting. Neither the city’s website nor the
language on the meeting agenda indicated this deadline. Failure to show the CHC images of
buildings on Santa Barbara (to demonstrate spacing, coverage, setbacks etc.) as well as relevant
language from relevant section of the Railroad District plan seriously impacted my ability to provide
the committees information to make a sound recommendation.
The Cultural Heritage Committee’s process to form their recommendation was inadequate and
inappropriate, which in turn hampered the ability of the Director to make an informed decision.
The CHC failed to consider key elements of the Railroad District Plan, did little to no deliberation
regarding the pattern of development on the west side of Santa Barbara (including height,
coverage, setbacks etc.) including references to such in the city’s historical preservation
guidelines. The applicant was absent from the CHC meeting and rather than continue the item so
the applicant / their agent could answer questions, the CHC continued deliberations. These
deliberations were further encouraged by the chairman’s confidence in the project’s architect
(whom he has a 40+ year working relationship with which was not shared). The chairman
confirmed the project’s zoning, but not aspects of the historic preservation guidelines under the
committee’s purview. The chair mentioned a discussion with the applicant’s architect which
potentially should have been held publicly and in front of the CHC.
I understand from planning staff that the planning department has noted a north and south side of
Santa Barbara Street with a delineation of Upham Street dividing this part of the Railroad District
into two patterns of development. It was shared with me that each area is subject to different
standards for height, coverage, setbacks and so on. I do not see this delineation referenced in the
Railroad District Plan, however, if indeed this is the case I would note that on the west side of Santa
Barbara between it’s intersection with Broad and up to Upham – the predominant building type is
commercial, the predominant height is single story and the pattern exhibited by massing and
spacing is significantly different than the proposed project. In addition, commercial properties in
this area which have developed with a residential component, the highest elevations are on the
east side of the development adjacent to Santa Barbara and there are wide setbacks to the low
density development to the west (on Chorro Street). Mimicking this type of development adjacent
to Master List historical resources would be more appropriate and consistent with the area.
I believe that placing three story multifamily residential units (with a partially undergrounded 1st
story) at the minimum setbacks from low density Master List Historical resources does in fact
negatively impact these resources. According to the City’s Context Statement, such resources are
significant not only because of the building themselves but because of the story they tell and how
they contribute to the community. The proposed development is neither consistent with the
established pattern nor in accordance with the Historical Preservation ordinance and guidelines.
4/5/2024 4/11/24 (updated)
To:Walter Oetzell and the Community Development Director
Re:1925 Santa Barbara Ave (ARCH-0448-2022)
My name is Wayne Terry and I (along with my wife Leslie)own 1902 Chorro Street.We acquired our
property in 1999 and have painstakingly restored the property into a lovely addition to our
neighborhood.Our home is a Master List historical property.Our home is historically significant to
the City of SLO as it is the only single story gambrel roof home in the city and it retains much of its
integrity (both interior and exterior)due to the survival and protection of the materials and
workmanship dating back to its original construction.We take pride in our efforts to maintain a 110+
year old home and believe that it does contribute to the community’s “sense of place”and agree with
language found in the City’s Historic Preservation Guidelines that maintenance and preservation of
historic structures is important to the community.Every December visitors from around the county
come to our home for our Christmas lights,adults and children marvel at our show and always
comment on our sweet little home and the neighborhood where it is located.Many of our neighbors
also own and maintain Master List homes.
At this time I am requesting the Community Development Director return the application identified
above to the applicant for further revisions and study.This is based on concerns regarding the CEQA
determination and the Cultural Heritage Committee (CHC)inadequately considering important details
found in City’s Historic Preservation Guidelines,Chapter 14.01 –The Historic Preservation Ordinance,
and the Railroad District Plan.I also have concerns regarding the project meeting the spirit of some
sections of Chapter 17 of the San Luis Obispo Municipal Code.Specifics follow.
CEQA Determination
The project was found to be Categorically Exempt from CEQA due to it being considered infill.
Despite the infill designation,I believe that an exception to the exemption does apply.The project is
located on a C-S zoned parcel and is one of three like properties (121,125 and 129 Santa Barbara
Streets).It is reasonable to expect that should 125 Santa Barbara develop as currently designed,that
in the near future,the parcels at 121 and 129 Santa Barbara would develop in a similar way.The
CHC noted at the March 25,2024 meeting that similar projects for these parcels would be forthcoming
and I would agree that this is a reasonable expectation.Because of the cumulative effect of
successive projects of the same type in the same place,over time could be significant,an
environmental review should take place.A re-evaluation of the project’s consistency with the
applicable general plan designation and all applicable general plan policies as well as the applicable
zoning designation regulations (2019 CEQA Statute &Guidelines 15332(a))should take place as they
may impact the exemption.
A CEQA review would provide the city with important information that is currently lacking.The project
includes a total of 7 parking places for the proposed on-site uses.SLO Municipal Code 17.72.030
allows:.75 space per bedroom (no less than 1 space per dwelling unit)for Multi-Unit Residential,2
parking spaces for the first 4 bedrooms for Single-Unit Dwellings,Detached and for Commercial Uses
somewhere between 1 space per 100 sf to 1 space per 300 sf.I assume that even though the project
includes a “Single-Unit Dwelling,Detached”that this unit is being considered part of the Multi-Unit
Residential.Depending on use,the Commercial business could require (on the low end)2 spaces,on
the high end 5.Assuming a low commercial parking need and none of the site users qualify for the
accessible space,all 6 spaces will be needed.Should the commercial space be a use that requires
more spaces (or should the “Single-Unit Detached”more appropriately have 2 spaces)the site may
be under-parked.The two-story detached home is referred to as an “Accessible Living Unit”and it has
been assumed as such that the resident of said unit would use that handicap parking.This unit is two
stories with a full flight of stairs to the second unit,so I’m not sure that in reality it will function as an
“accessible unit”(but it certainly sounds nice).I understand from staff that there is no parking
requirement for guests,however I assume there will be no limitations on residents actually having
visitors.Santa Barbara street has no street parking.Presumably guests will park on the streets in the
neighboring areas (the parking lot across the street is either designated for Amtrak users or spaces
have been designated (although not marked)for adjacent businesses and residences (Del Monte,
Café Roma,Channel Commercial Company,1880 Santa Barbara etc.).The nearby neighborhood
(Upham,Chorro,Garden)has multiple Multi-Unit Residential properties (including a fraternity)and
currently suffers from a parking shortage due to residents,guests,overflow Amtrak users etc.It is not
uncommon for our guests to park on Garden Street due to no available parking closer to our home.
Assuming the current project residents have a reasonable number of guests,and assuming future
like-development,it would not be uncommon or unexpected that a significant number of cars would be
looking for nearby parking.The block of Upham between Santa Barbara and Chorro Streets can
accommodate approximately 13 cars per side (and these locations are consistently occupied).Adding
vehicles would have a trickledown effect impacting residents and commercial businesses on Garden,
High,Morro,Broad Streets etc.The cumulative impact (of the current and future development)on
parking should be evaluated.
Related to parking are traffic safety concerns.The current project is a high-density development.
The tight parking configuration combined with no street parking means that delivery services (UPS,
Fedex,GrubHub etc.)will likely pull into the property for delivery and then will need to back out of the
property onto Santa Barbara.Santa Barbara is a major traffic corridor for residents,commercial
vehicles and first responders.Exiting the property forward facing will be challenging at certain times
of the day (just after 5pm,traffic from the light at Santa Barbara and Broad backs up to Upham).
Backing out of the project site will present dangers to the driver,sidewalk users,the bike lane traffic
and the road traffic.Visibility to traffic approaching from the north may be inadequate due to the
elevation change and slight curve of the road.
A CEQA review would allow the city to assess the project’s compliance with 15064.5 Determining the
significance of Impacts to Archaeological and Historical Resources,specifically impacts to
surrounding historic resources.
The Cultural Heritage Committee’s recommendation to the Community Development Director
primarily included direction regarding paint colors.Unfortunately,they neglected to include
consideration of important language found City’s Historic Preservation Guidelines including:
3.2 Construction in Historic Districts
3.2.1 Architecturally compatible development within Historic Districts.New structures in
historic districts shall be designed to be architecturally compatible with the district’s prevailing
historic character as measured by their consistency with the scale,massing,rhythm,signature
architectural elements,exterior materials,siting and street yard setbacks of the district’s
historic structures,as described in Figures 2 and 3.New structures are not required to copy or
imitate historic structures,or seek to create the illusion that the new building is historic.
And
3.2.2 Architectural compatibility.The CHC reviews development in historic districts for
architectural compatibility with nearby historic resources,and for consistency with applicable
design and preservation policies,standards and historic district descriptions in Section 5.2.
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.
And
3.3 Historic Resources outside Historic Districts
3.3.1 Historic Resources outside Historic Districts.Listed Historic Resources located
outside of historic districts shall be subject to the same protection and regulations applicable to
historic resources within historic districts.
And
And
5.2.5 Railroad Historic District
Architectural Character (pg.52)–Predominant architectural details include
A.One-and two-story buildings predominate
The proposed project is clearly not consistent with the scale,massing,and rhythm of the district.In
addition,the siting of the development (the commercial unit +the detached residential unit +the
triplex)is not consistent with mixed use developments which have occurred on the west side of Santa
Barbara since the adoption of the railroad district plan.One can clearly see in aerial imagery that in
between the mixed-use units at 1957,1965 and 1977 Santa Barbara that the developer placed a
significant space between the structures and the residential neighbors to the west.The commercial
unit at 2033 Santa Barbara did the same.The use of “shall''not “should”in the city’s guidelines leads
me to believe that there is little room for discretion regarding compliance.I bring up the westside of
Santa Barbara because the Railroad District Plan,page 67,3.2 C reads:(Property owners should)
Preserve the scale,pattern and spacing of the existing buildings along the westside of Santa Barbara
Street.Page 82 of the Railroad District Plan echoes this language under the Architectural Guidelines,
noting new residential buildings should generally maintain the prevailing spacing,scale,setbacks and
character of older houses and apartments along Osos,Santa Barbara and Church Streets.One can
travel down Santa Barbara from its intersection with Broad to its intersection with Leff to see the
proposed project is horribly inconsistent with the scale,massing and rhythm of the existing buildings in
the district.Just north of the project site is one of the city’s oldest and most important buildings –the
Tribune Republic Building which is on the National Register of Historic Spaces.The development on
the west side of Santa Barbara is consistent with the development one sees on Osos and Church
Streets.Properties have low density to moderately dense development which typically feature
generous spacing between structures and property lines,there are trees and gardens,access to
natural light etc.There is no ultra high density development like the current project.The proposed
project’s out-of-scale three story triplex adjacent to Master List homes (one of which is significant
because it is a single-story)is seriously not compliant with the city's Historic plans and guidelines.
The applicant proposes below grade parking,and is describing the triplex as two story,however,the
reality is the west end of said parking (closest to the historic resources)is only a few feet below the
natural grade.The triplex will tower above the neighborhood to the west.
The project also conflicts with San Luis Obispo Municipal Code,Chapter 14.01 Historic Preservation
Ordinance.Section 14.01.080 B 4 (pg.13)says the purpose of a historic district is to Enhance and
preserve the setting of historic resources so that surrounding land uses and structures to no detract
from the historic or architectural integrity of designated historic resources and districts.The proposed
project neither enhances nor preserves the setting of historic resources.Page 12 discusses Integrity
in the final paragraph and continues onto page 13 by saying that integrity includes the degree to
which a resource (historical)has retained its setting.Placing a 3-story structure adjacent to and
towering over Master List historic homes will change their setting and will negatively impact their
integrity.Page 3 echoes this under the definition of “Adverse effects”means effects,impact or actions
that are detrimental or potentially detrimental to a historic resource’s condition or architectural or
historical integrity.
My concerns beyond CEQA and considerations missed by the CHC extend to the project’s
non-compliance with San Luis Obispo Municipal code,section 17.70.130 Mixed-use development,
specifically:
A.Purpose.This section provides standards for the design of mixed-use projects to be
compatible with existing and planned development on the site and adjacent and nearby
properties.
The project is not compatible with the historic homes to the west,nor is it compatible with the current
residential development to the north or south.
E.Design Standards.A mixed-use project shall be designed to achieve the following
objectives:
3.The design of the mixed-use project shall take into consideration potential impacts
on adjacent properties and shall include specific design features to minimize potential
impacts
6.Site planning and building design shall be compatible with and enhance the adjacent
surrounding build environment in terms of scale,building design,color,exterior
materials,roof styles,lighting,landscaping,and signage.
The project does not take into consideration impacts on adjacent properties.The single family homes
to the north and south will be significantly impacted.I understand the zoning has changed since these
homes were built,but it would have been reasonable for the applicant to contact these homes and be
considerate of the current use.There is no consideration of impacts to the historic homes to the west.
The project places a three-story multifamily unit towering over and looking down into single family
historic homes.This is not a compatible use nor does it enhance the adjacent built environment.
I’d like to conclude that we are in no way opposed to development on this property –we were well
aware in 1999 when we purchased our home,that to the east of us were commercially zoned parcels.
We anticipated future development and expected we would perhaps see projects that provide services
for Amtrak users,or perhaps businesses that enhance the neighborhood.We are not deaf to the need
for city housing –our children are in their 20’s and they would like to continue to live in SLO and it is a
struggle for them.We live in the downtown area because we appreciate the mix of uses and enjoy
walking to many businesses.Unfortunately,the project before you is not the appropriate project for
the site.It conflicts with the City’s Municipal Code,the Historic Preservation Ordinance,the Historic
Preservation Guidelines and the Railroad District
Plan.In addition,it will negatively impact
important historic resources in which the
California State Advisory Council on Historic
Preservation (ACHP):ADVISORY COUNCIL ON
HISTORIC PRESERVATION HOUSING AND
HISTORIC PRESERVATION POLICY
STATEMENT to consider the potential adverse
effects to historic properties must be carefully
addressed,whether they be physical or visual
impacts to historic properties from new housing
construction or effects to the historic qualities of
historic buildings.It will likely set precedent for
future development on parcels to the north and
south,further negatively impacting important historic resources.
I understand the architect has struggled to maximize development on this small lot (it’s the same size
as ours and the same size as the mixed-use projects to the south).I do believe the applicant can
propose a project which provides housing,a small commercial use and which will be complementary
to the adjacent neighborhood and historic district.Thank you for reading,I know this was a lot.
From: Oetzell, Walter <woetzell@slocity.org>
Date: Wed, Apr 24, 2024 at 12:59 PM
Subject: Architectural Review Application ARCH-0448-2022 (1925 Santa Barbara)
To: Wayne Terry <
Cc:
Hello Mr. Terry,
I write to inform you that on April 22nd the Community Development Director approved
the Architectural Review application regarding development of the property at 1925
Santa Barbara with a mixed-use project. Any interested party may appeal the Director’s
decision within 10 days of the decision (by May 2nd), as provided by Zoning Regulations
Chapter 17.126 (Appeals).
In reaching a decision on this application the Director considered the recommendation
provided by the Cultural Heritage Committee, who found the project to be consistent
with the City’s historical preservation policies, standards, and guidelines, and the
correspondence received from interested parties. In your correspondence you raised
concern regarding the potential cumulative effects on the physical environment that
might be posed by the project, parking requirements, safe exiting from the site,
architectural consistency, and potential for significant impacts to nearby historical
resources.
Potential cumulative impacts of development permitted throughout the City were
considered during adoption of the Land Use Element of the City’s General Plan, most
recently updated in 2014. This project is consistent with land use limitations and
development standards (including height, coverage, and residential density) applicable
within a Services and Manufacturing area and Service Commercial (C-S) Zone. As
such, it does not present any additional potential for cumulative impacts beyond what
has already been considered during adoption of the current Land Use Element.
The mixed-use project is comprised of a non-residential component for which parking
has been provided at a ratio of one space for every 300 square feet of floor area, which
will accommodate nearly every non-residential land use which could be established at
this site. A land use could not be established on the property unless its parking
requirement can be satisfied. As to the residential component, the land use
classification is “Mult-Unit Dwellings,” defined in Zoning Regulations (§17.156.028) to
include “two or more dwelling units attached or detached, on a site or lot.” By definition
(see Zoning Regs. §17.156.038) “Single-Unit Dwelling” as a Land Use Definition
excludes dwellings “attached to or located on a lot with commercial uses or other
dwelling units.” We also note that the parking provided for this development includes
one “extra” space beyond the minimum requirement.
The project design is not seen to present a traffic hazard, including any related to
delivery activity related to the site. The parking area is subject to minimum standards for
the width of parking bays and access aisles such that exiting in a forward direction is not
precluded. Delivery companies are expected to conduct their activities in a safe manner,
including finding suitable locations from which to stage their deliveries, including safe
delivery to sites on this block. It’s also highly unlikely that their business practices would
permit backing out of a driveway onto an arterial road where such a maneuver could not
be safely accomplished.
As to architectural consistency (i.e., Historical Preservation Program Guidelines §3.2),
we note that this was explicitly addressed in the staff report to the Committee. In
understanding the pattern exhibited by the massing and spacing of buildings on the
west side of Santa Barbara Avenue, it should be recognized that the pattern north of
Upham differs from that south of Upham, and development in each area is subject to
different standards for height, coverage, setbacks, and so on.
To the north is a medium-high density residential zone, characterized largely by older
houses and apartment buildings. South of Upham, in the vicinity of the subject site, is a
services and manufacturing area (Service-Commercial Zone) within which the extant
single-family dwellings (which are not listed historical resources) do not establish the
pattern. The pattern exhibited by the siting and massing of buildings between Broad and
Upham is highly varied, including buildings of a height and size similar to those
proposed with this project, and building sited directly adjacent to property lines, in
addition to those providing significant setbacks.
The buildings proposed with this project are not seen to be inconsistent with the varied
pattern exhibited on the west side of Santa Barbara Avenue, in the vicinity of the project
site, or with the type of development anticipated in this portion of the Railroad District
Plan area. The development was found to incorporate architectural elements
encouraged by the Architectural Guidelines set out in the Railroad District Plan.
Additionally, this project provides an increased setback (Edge Conditions) from the
adjacent residential zone to the west, a standard specifically intended to protect lower-
density residential zones adjacent to higher-density or non-residential zones.
Neither the Cultural Heritage Committee nor the Director found that the proposed
project would cause any adverse change in the significance of any historical resource.
The significance of adjacent resources lies primarily in their architectural style and
character, which remains unaffected by the proposed project. The project is contained
wholly within the subject site. The site does not contain any historical resources that
could be affected by the project, nor does it contain landscape features, furnishings,
fixtures, adjacent open space, views, visual relationships, or other such elements that
are of importance to the significance of any neighboring resource. New construction that
conforms to applicable development standards and that is consistent with the
architectural character of the historic district is not seen to materially impair the
significance of those resources. Insofar as the new construction would alter the
immediate surroundings of historic resources, the changes would not constitute
“substantial adverse change” to the significance of those resources, as described in
CEQA Guidelines (§15064.5(b)).
I hope this addresses, to some degree, the concerns you have raised to the Director
about the proposed project. Please feel free to contact me if I can be of further
assistance with this.
Walter Oetzell
Assistant Planner
Community Development
Development Review
919 Palm Street, San Luis Obispo, CA 93401-3218
E woetzell@slocity.org
T 805.781.7593
slocity.org
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