HomeMy WebLinkAbout10/22/2025 Item 4a, Papp
James Papp <papp.architectural.history@gmail.com>
Sent:Tuesday, October
To:CityClerk; Leveille, Brian
Subject:Correspondence attached to Planning Commission regarding 4a review of HPO
Attachments:Papp letter to Planning Commission on HPO revisions.pdf
Please forward the attached PDF correspondence to members of the Planning Commission. Thanks!
James
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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
21 October 2025
Planning Commission, City of San Luis Obispo
Dear Planning Commission Members:
Writing as a former chair of the Cultural Heritage Committee who was the Dirst to champion
rationalization of the Historic Preservation Ordinance, I Dind much to commend in these
revisions and two fatal Dlaws to the logic of historic preservation and the interests of both
the city and its historic property owners: the calciDication of an unjustiDied and ill-deDined
multi-tier designation system that was originally created unintentionally, and the
restriction of historic preservation incentives to a single tier.
The HPO as previously adopted created two distinct types of historic resource recognition:
the Contributing List of properties that contribute to historic districts, plus a Master List of
“the most unique and important historic properties.” Among the 62 CLGs in California—
Certified Local Governments that have adopted historic preservation best practices under
the Department of the Interior—it is quite common to have Contributors inside historic
districts and individual landmarks outside. But in San Luis Obispo, two important
anomalies happened: (1) Contributing List properties ended up outside historic districts
when the city lost interest midway in the process of creating new historic districts, and (2)
Mills Act tax incentives for restoration and maintenance of historic properties were
reserved for the Master List, possibly from a fear they would be too popular. (They were
not: from the limit of 10 Mills Act applications per year, the city receives generally about 2.)
This limiting of the Mills Act is an extreme anomaly. Of the 62 municipal CLGs in
California—Certified Local Governments that have adopted historic preservation best
practices under the Department of the Interior—12 (20 percent) have no Mills Act, but of
the remaining 50, all but 3 (or 94 percent) make Mills Act available to all historic district
contributors and all levels of individually designated historic resources.
In contrast, the result in San Luis Obispo is an invidious system where the roughly 500
Contributing List properties are seen as second-rate in terms of recognition and purely a
burden in terms of ownership, having all the restrictions but none of the incentives of the
200 Master List properties. No one boasts about being on the Contributing List. The city
does not promote the Contributing List. As a historian and architectural historian, much of
my business is getting people on the Master List and off the Contributing List. No one wants
vice versa.
But also as a historian and architectural historian, I have statistically analyzed the Master
List and Contributing List by a variety of metrics—age, architecture, significance, integrity
to convey significance—and the only consistent distinguishers between the Master and
Contributing Lists are size and location. Master List buildings are bigger (overwhelmingly
two stories to Contributing List one) and in more desirable neighborhoods. The effect is
that the Master List is the celebration of overwhelmingly white upper-class privilege aand
Mills Act tax incentives are reserved for the wealthiest property owners.
Now the HPO revisions want to preserve the anomaly of outside-of-district non–Master
Listings as “Local Register Resources” and maintain the exclusion of Mills Act from these
and historic district Contributors: sticks without carrots, restrictions without incentives,
except for the wealthiest. If Mills Act were extended to all 500 currently Contributing List
properties instead of the 200 Master List properties, the city might, arithmetically, expect 7
applications a year instead of 2. If more, it can still maintain its limit of 10. The Mills Act
envisions all curators of historic resources needing assistance and encouragement, not just
the richest. This is important to maintain any popularity for historic preservation.
As for introducing a two-tier system of individual property designation, of the 62 municipal
CLGs in California—Certified Local Governments that have adopted historic preservation
best practices under the Department of the Interior—a third (21) have multi-tier systems
such as Landmarks and Structures of Merit (Berkeley, Campbell, Davis, Riverside, San Jose,
Santa Barbara, and Santa Monica) or lettered system (Oakland, Truckee, and Tustin). Two-
thirds of CLGs, however, maintain a unitary system to no ill effect, with designated historic
resources inside and outside districts (e.g., San Diego, with 1,031 in all, from Mid-Century
Modern suburban houses to the Mission San Diego de Alcala).
The most successful multi-tier systems are those that clearly define and limit the higher
tier, much like National Historic Landmarks (of national importance) compared to the
National Register of Historic Places (a national register of locally significant resources). For
instance, Palo Alto’s Exceptional Building category refers to national or state importance,
Major Building to regional importance, and Contributing Building to good local example of
an architectural style. Such systems usually have only a few dozen landmarks of the the
highest tier in even the largest cities. In contrast, the City of Napa has 1,840 listed resources
and 577 Local Landmarks, and, as with San Luis Obispo, the Local Landmarks are largely
just bigger.
Unfortunately, the new deDinition of a San Luis Obispo Landmark—“a historic resource that
has been found signiDicant at the local, state, or national level”—and Local Register
Resource—“a historic resource that has been found signiDicant at the local level”—is
functionally the same. Contributor is not deDined at all. The result will be that, as with
Master and Contributing resources now, Landmarks won’t be more signiDicant than Local
Register Resources or Contributors, just bigger, belonging to richer and savvier owners, and
less taxed.
Sincerely,
James Papp
Historian and Architectural Historian
City & County of San Luis Obispo