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Home My WebLink About9/29/2025 Item 4a, Papp James Papp < To:CityClerk Cc:Leveille, Brian Subject:Correspondence for CHC Hearing 29 Sep 2025, proposed HPO revisions, attched pdf Attachments:Papp comment on HPO revisions.pdf Sorry for the late hour; thanks for sharing it with the committee! James -- James Papp, PhD | Historian & Architectural Historian Call/text 805-470-0983 Sauer Adams Adobe 964 Chorro Street, San Luis Obispo, CA 93401 1 Papp Architectural History Sauer-Adams Adobe - 964 Chorro Street - San Luis Obispo, CA 93401 26 September 2025 Cultural Heritage Committee City of San Luis Obispo Dear Cultural Heritage Committee Members, As a local preservation professional, former member and chair of the CHC, and decade-long advocate of improvements to the city’s Historic Preservation Ordinance and Historic Resources Survey, I welcome the proposed revisions to the Historic Preservation Ordinance and commend the extensive thought and work that went into it . The changes are, however, complex, impactful, and in some cases either counterproductive or not productive of their desired effect and should not be rushed through without more than an evening’s consideration. As a general principle, new language should adhere as closely as possible to the wisdom and wording of the National Register Criteria for Evaluation and the Secretary of the Interior’s Standards, which are the gold standard and common national parlance for preservation, and to CEQA. The past tendency of San Luis Obispo to go it alone in establishing definitions, standards, and guidelines has only led to confusion and unintended consequences. There are many sections for which I will try to provide clearer and more common wording in correspondence with the CHC, but the major problem with the ordinance has always been the definition, distinction, and criteria of Contributing versus Master List resources, which in practice has simply led to the original Contributing List consisting predominantly of smaller buildings and the Master List predominantly of larger buildings, with buildings added to the Master List largely based on the savvyness, influen ce, or persistence of their owners. The proposed redesignation of Landmark, Local Register Resource, and Contributor regresses, because it gives no definition, distinction, or criteria at all: “‘Landmark’ is the highest level of individual local designation and may be applied to a historic resource which has been found significant at the local, state, or national level”; “‘Local Register Resource’ is an individual local designation that may be applied to [a] historic resource which has been found significant at the local level”; “‘Contributin g Resource’ means a property which is within the boundaries of and contributes to the significance of a Historic District.” Now the definition is simply significance (absent the integrity to convey significance) for all three. One solution would be to end the multi-tier system and open Mills Act to all listed resources. In practice, few current Master List resources are any more significance or have any more integrity to convey their significance than most Contributing resource, and in many cases less. Yet owners of Contributing properties are taught to have less pride and less concern for changes to integrity and receive no benefits to offset the costs of historic preservation. Currently, with approximately 200 Master List resou rces, there are only a couple of Mills Act applications per year, compared to the city’s limit of 10. Add the 500 or so current Contributing resources, and that might get up to 7 applications per year. Cull the 200 or so Master and Contributing properties that are either not sig nificant or do not have the integrity to communicate their significance, and Mills Act applications might be even lower. The alternative solution would be to follow the practice of the National Register, California Register, and other California CLGs in creating a two-tiered system based on local significance versus national or statewide significance. For example, the National Register is a national register of locally significant resources, just as the California Register is a state register of locally significant resources. In contrast, National Historic Landmarks are of national significance, with an impact on American history overall or associated with figures nationally significant in American history. California Historical Landmarks, similarly, are of statewide or regional significance. In architecture, a California Historical Landmark is “a prototype of, or an outstanding example of, a period, style, architectural movement or construction or is one of the more notable works or the best surviving work in a region of a pioneer architect, designer or master builder.” Other California CLGs that have multi-tiered historic designation programs , like Pasadena, base their higher designation on eligibility as state or national landmarks. Such a system of geographical significance obviates the slippery qualitative judgments that have bedeviled San Luis Obispo’s system and would bedevil it under the lack of written definition or distinction between Landmark, Local Register Resource, and Contributing Resource in the revised ordinance. Sincerely, James Papp Historian and Architectural Historian City & County of San Luis Obispo