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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 -- 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