The project site is located on Dolores 2 southeast of 7th on a 12,000 square foot lot comprised of three lots of record (Block: 91, Lots: 6, 8, 10). The applicant is proposing to demolish all improvements across the three lots and construct a 16,898 square foot two story mixed-use development with a 11,371 square foot basement garage. Two-thirds of the project site (lots 6 & 8) are located on part of the Palo Alto Savings and Loan Bank complex which currently occupies Lots 2, 4, 6, and 8 of Block 91.
The Palo Alto Savings and Loan Bank complex, consisting of a bank building and detached community room building, was constructed in 1972 and was designed by noted architects, Walter Burde and William Shaw, both of whom are listed in the City’s Historic Context Statement. While the Palo Alto Savings and Loan buildings are characteristic of the Second Bay Region Tradition of architecture, and designed by noted architects, the complex was deemed ineligible for listing on the City’s Historic Inventory as well as the National Register. In 2019, a Determination of Ineligibility (Attachment 3) was issued for the property by the City Council following the appeal of the Historic Resources Board’s decision to add the property to the City’s Historic Inventory; the Determination of Ineligibility will expire on October 26, 2022. The associated Determination of Ineligibility (Attachment 3) included a Phase II Report for an unrelated project that was previously submitted and withdrawn on May 1, 2020, although the report does provide background and history relevant to the project site. This original determination did not distinguish between the bank building and the community room, but rather analyzed the complex as a whole. While the complex is not eligible for listing on the nation or local inventory, it was previously determined that the site is eligible for listing on the California Register of Historic Resources (CRHR) and the complex, as a whole, is a historic resource for the purposes of the California Environmental Quality Act (CEQA).
According to the Phase II Evaluation attached to the Determination of Ineligibility for the site (Attachment 3), “In November 2001 Richard Janick assessed the building again using California Office of Historic Preservation DPR 523a and b forms. This second evaluation was no doubt initiated by a proposal filed in September 2001 to demolish the Palo Alto Savings and Loan complex and construct a new commercial property. Janick’s evaluation of the building concluded that it was eligible for listing on the California Register under Criterion 3 (architecture), “as a significant example of Second Bay Region Style by local architect Will Shaw and Associates with design assistance by former partner Walter Burde.” In accordance with CEQA Guideline §15064.5(a)(1), a structure must be treated as a historic resource if it is listed in, or determined to be eligible for listing in, the California Register of Historic Resources.
While the complex is eligible for listing on the CRHR, an Addendum to the Evaluation of Historical Significance for Palo Alto-Salinas Savings and Loan Complex was prepared by a Qualified Professional Historian, Margaret Clovis, evaluating the significance of the community room as an individual resource (Attachment 4). The evaluation concluded:
The Palo Alto-Salinas Savings and Loan complex consists of two buildings, a bank building and a community room. By definition they are a historically related unit and as a unit they have been determined eligible for listing on the California Register of Historic Resources. The primary building within the complex is the bank, and the property’s historical significance is predicated on the bank. The community room is an ancillary structure that does not contribute to the overall significance of the complex. In addition, the community room was evaluated for eligibility for listing in the California Register of Historic Resources based on its merits alone. The community room does not meet the criteria for listing as an individual resource.
In other words, while the bank building and the community room are historically related, the bank building is the primary significant structure on site, and the community room is an ancillary structure that on its own is not historically significant. An illustrative comparison may be, for example, a historic home with a detached garage. While the site may be historically significant, the primary residence would typically be the historically significant structure on site and the garage would be a related accessory building that on its own would not be historically significant.
On January 8, 2021, an application for a Design Review was submitted to the Community Planning and Building Department that proposed the demolition of the community room as part of the subject Esperanza Carmel project. As part of the project review, a Phase II Report (Attachment 4) was prepared by Margaret Clovis evaluating the project’s consistency with the Secretary of the Interior’s Standards and Guidelines based on preliminary plans. The Phase II Report concludes the project will not have a significant impact on the historic bank building provided the project meets the applicable Secretary’s Standards for Rehabilitation and that the recommended conditions identified in the report are followed (discussed below).
In accordance with CMC 17.32.160.B.1, “If the Board concurs with the evaluation [prepared by the qualified professional], the Board shall issue a determination of consistency and adopt any appropriate conditions of approval. Any finding of compliance by the Board shall be supported by substantial evidence. If the Board does not concur, the Board may request additional information prior to issuance of a determination of consistency, or may issue a finding of noncompliance with the Secretary’s Standards. Any finding of noncompliance by the Board shall be supported by substantial evidence.”
The scope of this review shall be limited to the discussion regarding the proposed demolition of the community room and determining whether the demolition is consistent with the applicable Secretary of the Interior’s Standards.
STAFF ANALYSIS
Secretary of the Interior’s Standards: The Secretary of the Interior’s Standards for the Treatment of Historic Properties (Standards) provides the framework for evaluating the impacts of additions and alterations to historic buildings. The Standards describe four treatment approaches: preservation, rehabilitation, restoration and reconstruction. The Standards require that the treatment approach be determined first, as a different set of standards apply to each approach. For the proposed project, the treatment approach is rehabilitation.
Margaret Clovis evaluated the project for consistency with the Secretary of the Interior's Ten Standards for Rehabilitation (Attachment 4). Ms. Clovis found that Standards #1, 2, 5, 6, 8, 9 and 10 are applicable to the project. The evaluation concluded that the project as proposed is consistent with the applicable standards on the condition that recommendations in this report are carried out.
Standard 1: A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.
Phase II Response: “The bank building has been used as a bank, retail store and most recently as a restaurant. These different uses have required minimal change to its distinctive materials, features, spaces, and spatial relationships. The community room is separated from the main bank building by a walkway. Sheet A1.0 indicates that the proposed adjacent construction will be separated from the bank building by a new walkway. The new walkway will help to maintain spatial relationships between the buildings however that spatial relationship should be maintained from the ground level to the roof by a setback of the north elevation from the bank building. It is also recommended that the proposed walkway be the same width as the current walkway.”
Staff Response: Following completion of the Phase II Report, Staff met with Ms. Clovis, and the applicant to discuss the spatial relationship between the bank building and proposed development. It was discussed at the meeting that the proposed development may be located closer to the adjacent bank building than initially outlined in the report provided the spatial relationship be maintained. While the recommendation outlined in the Phase II report states the northern wall of the community room should be used as the setback line, Staff is in agreement that a lesser setback could be considered provided adequate separation between the buildings is maintained.
The existing separation between the bank building and community room is 8’4” at the nearest point, as dimensioned in the field by staff. As shown on the preliminary project plans (Attachment 8, Sheet A1.0), the proposed closest setback between the buildings is 7’. While Staff is supportive of allowing for some relief from the initially recommended setback line (northern building wall of the community room), Staff recommends the proposed building not be permitted to extend more than one foot beyond the existing northern wall of the community room.
In the same meeting referenced above with the applicant and Ms. Clovis, the applicant has requested a small portion of the of the building to further encroach into this setback area to accommodate a staircase –in its current configuration, this project would be setback 5 feet from the bank building. Staff is supportive of this projection as it is relatively minor and setback approximately 51’7” from the property line fronting Dolores Street, therefore does not impact the feeling of separation when viewed from the street.
Staff has included Recommended Condition of Approval #1 stating, “to maintain the spatial relationship between buildings, the proposed building shall not extend more than one foot beyond the existing northern wall of the community room with the exception of a stairway project which shall be located no closer than 5’ from the bank building.”
Standard 2: The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize the property will be avoided.
Phase II Response: “The historic character of the bank building will not be altered. No distinctive materials will be removed. Features, and spaces will not be altered. The spatial relationship between the bank and the community room which has been established by the walkway separating the two should be maintained as part of the new construction. The Secretary of the Interior’s Guidelines for Rehabilitation recommend that any new construction adjacent to a historic structure should be placed away from or at the side or rear of a historic building and must avoid obscuring, damaging, or destroying character-defining features of the building. It appears from the Site Plan that the bulk of the new building will be located behind the bank and set back from Seventh Street. The proposed work appears to be consistent with Standard Two.”
Staff Response: See Staff Response under Standard 1 for discussion regarding maintaining the separation between the two buildings. In the Service Commercial (SC) Zoning District, buildings are required to be constructed to within 2’6” of the front property line for at least 70% of the street frontage (CMC 17.14.130). As viewed from Dolores Street, the project would be constructed to the required “build-to” line however would be slightly setback from the bank building along Dolores. As viewed from 7th Avenue, the building would be setback over 80’ from the 7th Avenue sidewalk. Staff concurs that the proposed work appears to be consistent with Standard 2.
Standard 5: Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.
Phase II Response: “The community room will be demolished as part of this project. It is connected to the main bank building at the second-floor level by an elevated walkway. When the community room is demolished a gap will be created in the exterior wall of the bank building. The wall should be repaired by matching the original wall in design, color, texture, and if possible, materials. If this is clearly indicated on the construction plans, then the work will be consistent with Standard Five.
It is important that a historic structure be protected during adjacent construction. Demolition activities and construction on neighboring sites can cause immediate harm to the physical integrity of a historic building through concentrations of dust, fire, vibration, and more. The National Park Service provides guidance for the temporary protection of historic structures in Preservation Tech Note Number 35 [Refer to Attachment 5]. Providing adequate protection involves the following steps:
- Consultation between the historic building owner and development team to identify potential risks, negotiate changes and agree upon protective measures.
- Documentation of the condition of the historic building prior to adjacent work.
- Implementation of protective measures at both the construction site and the historic site.
- Regular monitoring during construction to identify damage, to evaluate the efficacy of protective measures already in place, and to identify and implement additional corrective steps.
Work will be consistent with Standard Five if a protection plan is submitted to the HRB for review and approval prior to the commencement of any work on the proposed project.”
Staff Response: The applicant has submitted a written Protection and Monitoring Plan (Attachment 6) outlining the steps proposed to be taken to protect the adjacent bank building during the proposed demolition of the community room and during the proposed construction of the subject project. In addition to the written plan, the applicant has also provided a protection plan included in the preliminary project plans (Attachment 8, Sheet A1.1) that identify the proposed protection measures during construction, and are outlined in the “Historic Building Protection Plan Key Notes.”
Staff has included Recommended Condition of Approval #2 stating, “The written Protection and Monitoring Plan and Historic Building Protection Plan indicated in the project plans, collectively known as the “Protection Plan,” (Attachment 6) shall be adhered to prior to and during construction. Protective measures installed on-site or on the adjacent site shall be inspected by the Planning Department and Building Inspector prior to the issuance of a demolition or building permit. Modifications to the Protection Plan shall require approval by the Historic Resources Board.”
Standard 6: Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.
Phase II Response: “No work will be done on the historic bank building except for the repair of the wall juncture between the community room and bank. As stated in Standard Five, the repair of the bank wall should match the original wall in design, color, texture, and where possible, materials. Construction plans should clearly indicate how the wall will be repaired in order to be consistent with Standards Five and Six.”
Staff Response: An application for repairs to the bank building necessitated as a result of the portion of wall being removed by the proposed project is forthcoming. To ensure the associated repairs to the bank building are addressed, Staff has included Recommended Condition of Approval #3 stating, “Prior to the issuance of a demolition or building permit, an application for repairs to the bank building necessitated by the removal of the wall juncture between the community room and bank shall be submitted to the Community Planning and Building Department.”
Standard 8: Archeological resources will be protected and preserved in place.
Phase II Response: The current parking lot will be demolished, and a [11,371] square foot basement area will be excavated which will serve as a parking garage, gym, and support services for the new building. Because there will be major ground disturbance, an archeological report should be prepared to evaluate whether any resources are present. If resources are discovered, appropriate mitigation measures should be implemented. The proposed work will be consistent with Standard Eight once an archaeological report is completed.
Staff Response: An Archaeological Report was previously prepared for Lot 10 in 2019 and an additional Archaeological Report was prepared for Lots 6 and 8 in 2021 following the submittal of the subject application (refer to Attachment 7); both reports were prepared by Susan Morley, M.A.
Both reports maintain the same conclusion that state, “Archaeological reconnaissance did not reveal any of the indicators expected of a prehistoric archaeological or historical resource in this region; there are no culturally modified soils present; no shell fragments, bone fragments, or culturally modified lithic materials were noted in the soils of the project parcel. No granitic or other bedrock outcrops were present that may possibly have contained bedrock mortars or cupules… Based upon these negative findings, there is no reason to delay the project parcel due to archaeological concerns.”
However, staff included Recommended Condition of Approval #4 and #5 stating, “In the event that unexpected traces of historic or prehistoric materials, i.e., human remains, concentrations of shell or heat altered rock or historic trash pits are encountered during grading or other future development all construction activity shall immediately cease, and the applicant shall notified the Community Planning and Building Department within 24 hours and a qualified archaeologist shall be retained for appropriate archaeological mitigation,” and “If any human remains are exposed, the Health and Safety Code § 7050.5 requires that no further excavation or disturbance occurs in the area and that the county coroner is called so that the coroner can verify that the remains are not subject to medical jurisprudence. Within 24 hours of notification, the coroner calls the Native American Heritage Commission if the remains are known or thought to be Native American.”
Standard 9: New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale, and proportion, and massing to protect the integrity of the property and its environment.
Phase II Response: The new construction will demolish the parking lot, community room, and garden wall which are part of the bank complex however they are not significant in their own right. These features supported the bank’s former function but do not support its eligibility under Criterion Three (Architecture). They are not considered character-defining features. The pathway separating the community room and the bank creates an important spatial relationship that should be preserved, as discussed under Standards One and Two. The proposed work appears to be consistent with Standard Nine.
Staff Response: Staff concurs with the Phase II Response, above.
Standard 10: New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
Phase II Response: If removed in the future, the proposed new construction adjacent to the historic bank building will not impair the historic property and environment only if care is taken to remove the building following the guidance provided in Preservation Tech Note Number 3 and described under Standard Five.
Staff Response: Staff concurs with the Phase II Response, above.
Historic Evaluation Summary: The California Environmental Quality Act (CEQA) requires environmental review for alterations to historic resources that are not consistent with the Secretary of the Interior’s Standards. The proposed demolition of the Palo Alto Savings and Loan Community Room was reviewed by the City’s Historic Preservation Consultant and a Phase II Historic Assessment was prepared for the project (refer to Attachment 4). The Assessment includes an analysis of the proposed changes based on the Secretary of the Interior’s Standards for the Treatment of Historic Properties. The Assessment concludes that the project meets the Secretary of the Interior’s Standards for rehabilitation. The proposed demolition of the Palo Alto Savings and Loan Community Room does not impact the remaining character-defining features or overall historic integrity of the Palo Alto Savings and Loan Bank Building.