HomeMy WebLinkAbout3/4/2025 Item 6a, Rizzo
Saro Rizzo <
To:E-mail Council Website; Dietrick, Christine
Subject:3-4-2025 Appeal Of Waterman Village Project
Attachments:2-28-2025 Letter To City of SLO.pdf
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Dear City Clerk:
Please distribute the attached letter to members of the SLO City Council and other interested City of SLO
parties. It regards a matter on the March 4, 2025, agenda.
Thank you,
Saro Rizzo
Attorney at Law
1457 Marsh St., Suite 100
San Luis Obispo, CA 93401
1
Saro G. Rizzo
Attorney At Law
1457 Marsh Street, Suite 100
San Luis Obispo, Ca. 93401
Tel (805) 783-1735 Fax (805) 858-9505
Sgrizzo3@gmail.com
February 28, 2025
Via Email
City of San Luis Obispo
Attn: Mayor and City Council
990 Palm Street
San Luis Obispo, CA 93401
SUBJECT: Appeal of Planning Commission decision to approve the Waterman
Village Project at 466 Dana Street, proposing the construction of 20 low-
to very-low-income homes at the historic Rosa Burton Adobe.
Dear Mayor and City Council:
My office represents appellant San Luis Obispo Property and Business Owners
Association (SLOPBOA) which filed the appeal of the Planning Commission’s decision
to approve the Waterman Village project at 466 Dana Street. The appeal will be before
the San Luis Obispo City Council on 3/4/2025.
I have reviewed the Council Agenda Report from the Community Development Director
and strongly disagree with the conclusion that the case Save the Wellwood Murray
Memorial Library Com. v. City Council (1989) 215 Cal.App.3d 1003 (Wellwood) is not
applicable to the facts of the present appeal. To the contrary, it is exactly on point and the
City of San Luis Obispo (City) cannot escape the legal impact of its holding on this
proposed project which mandates that the City reverse the Planning Commission’s
decision approving the Waterman Village Project.
Wellwood was a legal dispute centered on efforts to protect the Wellwood Murray
Memorial Library, a historic public library in Palm Springs, California, from actions by
the City of Palm Springs (Palm Springs) that threatened its preservation. The library,
located on city-owned property, was donated to Palm Springs in 1938 via two grant
deeds. These deeds included the condition that the property was to be used perpetually as
a free public library, named the "Wellwood Murray Memorial Library." The conflict
arose when Palm Springs entered into a series of agreements with a private developer to
redevelop the library property. Save the Wellwood Murray Memorial Library
Committee filed a lawsuit against Palm Springs. The published case involved the third
participation agreement Palm Springs had with the developer. It provided for the granting
of an easement to the developer over the library property for any purpose related to the
adjoining commercial development, including the placement of dining tables, chairs and
related equipment, the remodeling of the library property in accordance with plans and
specifications to be approved by Palm Springs at some later date, and the razing of
approximately four feet of the library building's southern side. The case was
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about preserving the library’s status as a public resource and ensuring Palm Springs
adhered to the legal conditions of the original land grant.
Palm Springs argued that the proposed use of the library (for dining tables, chairs, and
related equipment, and providing an open area for pedestrian traffic from the nearby
streets to the commercial development) was consistent with library purposes in the grant
deed and, in fact, would contribute to the use of the property for such purposes. However,
the Court of Appeal did not agree with this and ruled that applicable test is not whether a
proposed use is “consistent” with the dedicated purpose, or whether it will “contribute” to
such purpose, but whether the proposed use will “directly contribute” to the
dedicated purpose. The Court of Appeal held that to meet the rule, Palm Spring’s
proposed use must directly contribute to the use and enjoyment of the property for library
purposes: e.g., the proposed use must directly facilitate the acquisition, retention, storage
and use of books, manuscripts and similar materials. It held that the use proposed by
Palm Springs in no way would directly contribute to those purposes, and that, in at least
one way, it would be antithetical to such purposes because the proposed use would
destroy parts of the building where books are stored and used. The ruling protected the
library from redevelopment that would have altered its historic purpose and structure,
reinforcing the importance of public oversight in municipal decisions involving dedicated
public assets.
Here, the City of San Luis Obispo is making the same arguments that Palm Springs made
in Wellwood which were rejected by the Court. The proposed Draft Resolution entitled,
“A Resolution of the City Council of the City of San Luis Obispo, California, denying an
Appeal of the Planning Commission’s decision approving the Waterman Village Project
(ARCH-0329-2022, EID-0637-2022)” attached to the Council Agenda Report makes the
finding to the proposed project is “consistent” with the dedicated purpose of the Grant
Deed that property be used as a park or for recreational uses. Finding 1 states “[t]he
project is consistent with the enforceable covenants found in the Grant Deed from Mary
Gail Black to the City dated July 26, 1989 as well as the Resolution of Acceptance
executed by Council in Resolution No. 6512 dated October 4, 1988.1 As stated above,
this is not the test and making such a finding provides the City no legal support. The
correct question here is whether proposed project will “directly contribute” to the use and
1 There is no question on the legality of the restrictive covenants that run with the
property that was gifted to the City for public purposes. On page 2 of the City’s March 6,
2020, “Request for Information - Community Partnership - Rosa Butron de Canet
Adobe” the City unequivocally states:
It is clear in the Grant Deed from Ms. Black to the City and in the City
Council’s Resolution of Acceptance that the donation agreement includes
provisions for “the adobe and two adjoining wings that make up the old house,
and the trees on that property be maintained by the city for park or recreational
purposes, and that Mildred Waterman’s name be included in any name that the
city give this park area,” and “the City of San Luis Obispo assumes certain
maintenance responsibility for the grounds and premises as a condition of this
grant.”
(Emphasis added.)
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enjoyment of the property for park or for recreational purposes. Any objective analysis of
what is being proposed shows that it will not. In fact, what is being proposed, just like in
Wellwood, is antithetical to such purposes because it would make public use of the
property for park or for recreational purposes impossible.
Smart Share Housing Solutions is proposing the construction of 20 prefabricated homes
for low to very low-income housing ranging in size from 220 to 264 square feet on the
property. (See Attachment D in the Council Agenda Report, Project Plans). The
proposed new units are to be clustered around the historic adobe and will utilize raised
pier foundations to accommodate the 100-year flood plain requirements with each unit
being accessible via a raised boardwalk with ramps and stairs. It’s proposed that the
historic adobe will be used as a community gathering space as well as office and
administrative space for the on-site manager. The project scope includes the demolition
of non-historic additions at the rear of the adobe, as well as removal of 12 historic trees
on the property. The picture below of the site plan clearly shows that there is no possible
way that the proposed project will “directly contribute” to the public’s use and
enjoyment of the property as called for in the Grant Deed. In fact, the buildout with 20
prefabricated homes would be directly contrary to these purposes because it would leave
no room for them.
Further, a public trust is created when property is held by a public entity for the benefit of
the general public. (See Big Sur Properties v. Mott (1976) 62 Cal.App.3d 99, 89 C.J.S.
Trusts, § 19.) Here, title to the historic Rosa Burton Adobe property is held by City to be
used by City for the benefit of the general public for park or recreational purposes. Any
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attempt to divert the use of the property from its dedicated purposes or uses incidental
thereto would constitute an ultra vires act which can be enjoined by the courts. (Big Sur
Properties v. Mott, supra, 62 Cal.App.3d at p. 99.)
For all the above reasons, the City must reverse the Planning Commission’s decision
approving the Waterman Village Project.
Respectfully,
____________________________
Saro Rizzo
Attorney for SLOPBOA
Respectfully,
______________
Saro Rizzo
4Waterman Village Project Appeal