EXECUTIVE SUMMARY
The applicant has submitted an application (DR 22-310, D&K Dolores LLC) for the proposed relocation of the Northern California Savings and Loan Complex Community Room. In May 2021, the Historic Resources Board reviewed a proposal to demolish the Community Room, and determined the proposal to be inconsistent with the Secretary of the Interior’s Standards for Rehabilitation. This determination was appealed to the City Council, but the appeal was denied and the original decision was upheld. The applicant has returned with a new application that proposes the re-location of the Community Room on the east elevation of the current 7th & Dolores restaurant building.
Also being considered is whether to list the Complex on the Carmel Inventory of Historic Resources. While the Complex is eligible for listing on the California Register of Historic Resources (CRHR) and is a historic resources for the purposes of the California Environmental Quality Act (CEQA), the resource has not been listed on the local inventory.
Effectively, the HRB is being asked to make two decisions:
- Should the Complex be listed on the Carmel Inventory and Carmel Register of Historic Resources?
- Is moving the Community Room consistent with the Secretary of the Interior’s Standards for Rehabilitation?
BACKGROUND AND PROJECT DESCRIPTION
Background and Overview
The Northern California Savings and Loan Complex, consisting of a bank building and detached Community Room building (currently the 7th and Dolores Restaurant), 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 Northern California Savings and Loan Complex is characteristic of the Bay Region style of architecture, which is described in the Historic Context Statement, 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. This determination of Ineligibility for listing as a local resource was issued by the City Council following an appeal of the HRB decision at the time to add the property to the City’s Historic Inventory. This Determination of Ineligibility for listing expired on October 26, 2022 pursuant to City code, because the building turned 50 years old (refer to Attachment 6).
On October 4, 2022, an application was submitted for the proposed relocation of the Community Room from the south side of the original bank building, to the east side. On November 4, 2022, a Completeness Review letter was provided to the applicant which stated the application was incomplete, and listed additional application items required for application completeness. Included in the Completeness Review letter was direction to the applicant to submit for a Historic Evaluation consistent with CMC 17.32.050.B which states, “No application for property development shall be deemed complete unless it includes a determination that the property is either eligible or ineligible for the Carmel Inventory.”
While a previous determination of ineligibility for the Carmel Inventory had been made by City Council, (refer to Attachment 6), pursuant to City code, “Determinations of ineligibility shall be valid for a period of five years from the date of issuance except for properties developed less than 50 years prior to the determination, but more than 45 years prior to the determination, and which are ineligible for the Carmel Inventory primarily due to insufficient age. All such determinations of ineligibility shall be valid only until the building, structure or object reaches the age of 50 years” (CMC 17.32.060.D.4).
As the previous Determination of Ineligibility was issued when the building was less than 50 years old, but greater than 45 (issued at 48 years old), the previous Determination of Ineligibility is no longer valid and the building is required to be re-evaluated for the Carmel Inventory as the property has now reached sufficient age for listing on the inventory.
Notwithstanding the prior decision to not list the building on the 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).
Whether or not the Complex is listed on the local inventory, the complex is considered a historic resource for the purposes of CEQA and subject to the requirements of the city’s historic preservation ordinance (CMC 17.32) since the Complex has been determined to be eligible for listing on CRHR.
Project Structure
The California Environmental Quality Act (CEQA) defines a project as, “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.” As the term “project” refers to the whole of an action and to the underlying physical activity being approved, not to each government approval (CEQA Guidelines Section 15378(c)), even if the Lead Agency (the City) needs to grant more than one approval for a project, only one CEQA document should be prepared.
For the purposes of CEQA, the project being considered consists of multiple development applications, as described below.
Project Background
On January 8, 2021, an application for a Design Review Application, DR 20-395 (JB Pastor Building), was submitted to the Community Planning and Building Department that proposed the demolition of the Community Room to accommodate the construction of a new 16,891 square foot two story mixed use building located on Lots 6, 8, and 10 of Block 91. The development of the new mixed use building was dependent on the demolition of the Community Room to make space on the subject site (Lots 6, 8 and 10). As part of the project review, a Phase II Report was prepared by historian Margaret Clovis, one of the City’s historic consultants, evaluating the project’s consistency with the Secretary of the Interior’s Standards and Guidelines based on the preliminary project plans. The Phase II Report concluded the project, consisting of the demolition of the Community Room, would not have a significant impact on the bank building (which would remain) provided the project meets the applicable Secretary’s Standards for Rehabilitation and that the recommended conditions identified in the report are followed.
Staff recommended the HRB approve a determination of consistency based on the technical report prepared by Margaret Clovis. A Resolution was prepared for the issuance of a Determination of Consistency for the project which was considered at the April 19, 2021 HRB meeting (click here for staff report).
The Board did not concur with the determination of consistency prepared by Ms. Clovis, and the Board voted to continue the hearing with direction to staff to return with a revised resolution for adoption with a Finding of Noncompliance in accordance with CMC 17.32.160.B.1.b. In other words, the Board found that demolition of the Community Room was not consistent with the Secretary’s Standards for Rehabilitation. As directed, staff returned at the following hearing (May 17, 2021) with an amended resolution for adoption based on the findings made by the HRB (click here for staff report). The Board adopted a resolution with amended findings made at the hearing and issued a Finding of Noncompliance, citing that the proposed demolition was inconsistent with the Secretary’s Standards (refer to Attachment 7).
On May 19, 2021, a timely appeal was filed on behalf of Esperanza Commercial LLC of the HRB’s decision to the City Council. On August 3, 2021, the City Council considered the appeal of the Finding of Noncompliance and upheld the HRB’s decision (click here for staff report; refer to Attachment 7 for adopted Resolution).
On May 24, 2022, the applicant, Jason Diaz of International Design Group (IDG), submitted a second Design Review Application, DR 22-157 (Esperanza Carmel), on behalf of the property owner, for the construction of a similar mixed use building located on Lots 6, 8, and 10 of Block 91. However this time, rather than demolition, the applicant proposes to re-locate the Community Room from the southern side of the of the existing bank building to the eastern side, rather than demolishing it (refer to Attachment 9).
A preliminary review of the application at a public hearing was scheduled on August 15, 2022 to allow the HRB to review the scope of work and provide direction and preliminary feedback as to whether the board would be supportive of the relocation of the structure on the same site (click here for staff report). This application included the scope of a larger project on the three adjacent lots to the south, and only referenced the relocation of the Community Room but did not provide any specifics regarding the actual relocation of the building. The HRB did not provide specific feedback but requested plans be submitted so they could review an actual development proposal.
On October 3, 2022, IDG submitted a third Design Review Application, DR 22-310 (D&K Dolores LLC), on behalf of the property owner, for the relocation of the Community Room to Lot 4 from Lot 6 of Block 91, associated with the proposed improved shown as part of the application, DR 22-157 (Esperanza Carmel).
In summary, the currently proposed project is the construction of a new two story mixed use building on lots 6, 8, and 10. The project include the relocation of the Community Room from Lot 6 to Lot 4 of Block 91 to allow for the construction of the new mixed use building which is proposed to occupy lot 6, and will include associated improvement to Lot 4 as part of the relocation of the building to be considered at a later date.
The element of the project being considered by the Historic Resourced Board at this hearing is a Determination of Consistency with the Secretary’s Standard’s for the proposed relocation of the Community Room. This determination is required for all major alterations to historic resources as well as the listing of the Complex on the Carmel Inventory of Historic Resources and Carmel Register of Historic Resources.
Project Site Composition
Project site consists of Lots 2, 4, 6, 8, and 10 located on Block 91. The Northern California Savings and Loan Complex (Complex) consists of lots 2, 4, 6, and 8 with the Bank Building primarily located on lots 2 and 4, with a small sliver of the southern end of the building as well of the southern roof overhangs located on lot 6 (refer to Attachment 8, Last Sheet, Topographic Survey Dated September 2017 prepared by Rasmussen Land Surveying, INC). The Community Room is attached to the bank building via an elevated covered walkway between lots 4 and 6 with the Community Room sited on lot 6. Lot 8 consists primarily of the parking lot which continues to the east portion of 6. The eastern portions of lots 2 and 4 were also historically used as part of the parking lot/driveway, however, have since been replaced with an outdoor dining area for the currently existing restaurant which occupies the site.
Lots 2 and 4 of the Complex are under the ownership of D&K Dolores LLC; Lots 6 & 8 are owned by Esperanza Carmel Commercial (refer to Figure 1, below). The ownership of the Complex was divided from a single parcel under a single ownership to its current configuration following the issuance of a Certificate of Compliance issued in 2018 (COC 18-389 (CPines7 LLC)) to the previous owner of the Complex.
Figure 1. Project Site Composition.
STAFF ANALYSIS
HRB Decision #1 - Evaluation for Listing on the Carmel Inventory and Register of Historic Resources
As noted above, CMC 17.32.050.B states that “No application for property development shall be deemed complete unless it includes a determination that the property is either eligible or ineligible for the Carmel Inventory.” The city’s historic preservation ordinance (CMC 17.32) outlines the process for establishing eligibility for the Carmel inventory.
As outlined in the historic preservation ordinance, “If the property appears to meet the criteria for the inventory, the Department shall order that an intensive survey of the property be conducted. All intensive surveys shall be performed by a qualified professional under contract to the City.” The city contracted with PAST Consultant, LLC (PAST) to prepare the intensive survey.
PAST completed a site visit, conditions assessment, historic research and report preparation during December 2022, as outlined in Attachment 3. The ultimate conclusion of the survey was that the Complex meets the criteria for listing on the local inventory. This analysis and conclusion is explained in greater detail throughout the following section.
As described in CMC 17.32.040, in order to be included in the Carmel Inventory, the property A) should be representative of at least one theme included in the Historic Context Statement; B) shall retain substantial integrity; C) should be a minimum of 50 years of age; and D) shall meet at least one of the following four criteria for listing as a primary or local resource:
Criteria 1: Is associated with events that have made a significant contribution to the broad patterns of local or regional history or the cultural heritage of California or the United States;
Criteria 2: Is associated with the lives of persons important to local, California or national history;
Criteria 3: Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, an important creative individual, or possesses high artistic values; OR
Criteria 4: Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California or the nation.
To qualify under Criteria 3, the resource should:
- Have been designed and/or constructed by an architect, designer/builder or contractor whose work has contributed to the unique sense of time and place recognized as significant in the Historic Context Statement; or
- Have been designed and/or constructed by a previously unrecognized architect, designer/builder or contractor if there is substantial, factual evidence that the architect, designer/builder or contractor contributed to one or more of the historic contexts of the City to an extent consistent with other architects, designer/builders or contractors identified within the Historic Context Statement; or
- Be a good example of an architectural style or type of construction recognized as significant in the Historic Context Statement; or
- Display a rare style or type for which special consideration should be given. Properties that display particularly rare architectural styles and vernacular/utilitarian types shall be given special consideration due to their particularly unusual qualities. Such rare examples, which contribute to diversity in the community, need not have been designed by known architects, designer/builders or contractors. Rather, rare styles and types that contribute to Carmel’s unique sense of time and place shall be deemed significant.
Based on the intensive review, PAST concluded that the property, A) is representative of Theme 5: Architectural Development in Carmel in the Context Statement; B) retains all of its original character-defining features and has retained a high degree of integrity; C) is greater than 50 years old; and, D) meets Criteria 3 as an intact Bay Region Modern style complex designed by prominent local architects Walter Burde & Associates and Will Shaw & Associates.
In addition to meeting the criteria for listing on the local inventory, the Phase I elevation (Attachment 3) provides an analysis that the Complex is also eligible for the California Register of Historic Resources (CRHR) eligible under Criterion 3, “Embodies the distinctive characteristics of a type, period, region or method of construction or represents the work of a master or possesses high artistic values.”
Prior to the Intensive Survey prepared by PAST, an Intensive Survey prepared by Richard Janick, Architectural Historian, in 2001 also concluded that the subject site was eligible for listing for the CRHR (refer to Attachment 5) under Criterion 3. This conclusion was reaffirmed by Margret Clovis in an Evaluation of Significance and Phase Two Report dated October 3, 2019 (refer to Attachment 6).
In accordance with CMC 17.32.230, a historic resource eligible for listing in the California Register due to its national or statewide significance shall be considered a primary historic resource. “All primary resources are included in the Carmel included in the Carmel Inventory and the Carmel Register of Historic Resources.”
Staff Analysis of Intensive Survey Findings:
As a primary resource, the resource is included in both the Carmel Inventory and Carmel Register (CMC 17.32.230). Notwithstanding this code requirement, the following is an analysis of the findings from the intensive survey and its conclusion that this property meets the eligibility criteria for listing in the Carmel Inventory:
- Should be representative of at least one theme included in the Historic Context Statement.
Staff Response: The Historic Context Statement is organized by themes, derived from a broad set of associated events that helped shape the history of Carmel. The development of Carmel-by-the-Sea can be organized into five broad themes: Prehistory and Hispanic Settlement; Economic Development; Government, Civic and Social Institutions; Architectural Development; and the Development of Arts and Culture.
The Northern California Savings and Loan Complex represents the theme of Architectural Development. As outlined in the context statement, commercial properties meeting the following criteria may be found to be representative of the theme of architectural development: “Nearly every commercial building on Ocean and Dolores contributes to the character of the historic business district. Other commercial properties in the city may also be eligible for listing if they were constructed more than 50 years ago.”
As described in the Intensive Survey (Attachment 3) prepared by PAST, “Completed in 1972, the subject bank complex supports the theme, Architectural Development in Carmel, as a commercial property type constructed in the Bay Region Modern style, a significant architectural style noted in the Carmel Historic Context Statement.”
Staff concurs with the conclusion of the intensive survey that the subject residence is representative of at least one theme in the Historic Context Statement.
- Shall retain substantial integrity.
Staff Response: As stated in National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, Integrity is defined as the ability of a property to convey its significance. There are seven aspects of integrity: Location, Design, Setting, Materials, Workmanship, Feeling, and Association. To retain historic integrity a property must retain several, if not most of the aspects.
As described in the Intensive Survey (Attachment 3):
With the exception of entrance-door modifications and selective window glazing replacement, the exterior of the bank complex is essentially intact, with no square footage additions to the original footprints of both the bank building and the Community Room. Interior alterations in 1978, 2013 and 2018 have removed the original bank infrastructure and finishes. The following is the historic integrity assessment:
- Location. The bank complex is in its original location and maintains integrity of location.
- Design. The bank complex maintains integrity of design with the presence of all of its exterior character-defining features.
- Setting. The setting within the shopping district of downtown Carmel-by-the-Sea remains intact.
- Workmanship. Integrity of workmanship is retained and highlighted by the dramatic expression of structural elements, the exterior wall cladding and the wide expanses of glass of the bank building and Community Room.
- Materials. Original materials of steel, glass, wood structural elements and wood wall cladding remain on the building, giving it integrity of materials.
- Feeling. The building complex maintains integrity of feeling as a commercial building complex designed in the Bay Region Modern style, as reflected by its intact design elements and retention of character defining features.
- Association. The building complex maintains integrity of association as a commercial building complex designed in the Bay Region Modern style, as reflected by its intact design elements and retention of character defining features.
The bank complex maintains all seven aspects of historic integrity.
Staff concurs with the conclusion of the intensive survey that the Complex retains substantial integrity.
- Should be a minimum of 50 years old.
Staff Response: The Complex was constructed in 1972 and is 50 years old. The previous Determination of Ineligibility for the Complex expired on October 26, 2022 when the Complex reached 50 years old.
- Shall meet at least one of the following four criteria for listing as a primary or local resource.
Staff Response: The residence meets criteria #3, “Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, an important creative individual, or possesses high artistic values.” To qualify under Criteria 3, the resource also should (CMC 17.32.040.D.):
- Have been designed and/or constructed by an architect, designer/builder or contractor whose work has contributed to the unique sense of time and place recognized as significant in the Historic Context Statement; or
- Have been designed and/or constructed by a previously unrecognized architect, designer/builder or contractor if there is substantial, factual evidence that the architect, designer/builder or contractor contributed to one or more of the historic contexts of the City to an extent consistent with other architects, designer/builders or contractors identified within the Historic Context Statement; or
- Be a good example of an architectural style or type of construction recognized as significant in the Historic Context Statement; or
- Display a rare style or type for which special consideration should be given. Properties that display particularly rare architectural styles and vernacular/utilitarian types shall be given special consideration due to their particularly unusual qualities. Such rare examples, which contribute to diversity in the community, need not have been designed by known architects, designer/builders or contractors. Rather, rare styles and types that contribute to Carmel’s unique sense of time and place shall be deemed significant.
According to the intensive survey, the subject property is eligible under criteria #1 because it was designed and executed by the partnership of Walter Burde, AIA and Will Shaw, AIA, both of whom are listed as significant architects in the Carmel Historic Context Statement. In addition, the bank complex represents one of the few intact examples of a commercial building complex constructed in downtown Carmel-by-the- Sea in the Bay Region Modern style. It is also eligible under California Register Criteria 3, in the area of architecture, as an outstanding example of Modernist design by a significant team of California architects.
Staff concurs with the conclusion of the Intensive Survey that the property is eligible under criteria #3 as the architectural style of the residence is related to Carmel’s architectural chronology as presented in the Historic Context Statement, as well as being a good example of an architectural style or type of construction recognized as significant in the Historic Context Statement (qualifier #3).
Alternatives: Should the HRB determine the project is ineligible for listing, the board would be required to adopt specific findings identifying why the site is ineligible for listing. The findings should also identify the specific basis for the determination to be included in the Determination of Ineligibility.
HRB Decision #2 - Determination of Project Consistency With Secretary of Interior Standards
As outlined in the city’s Historic Preservation Ordinance, “All major and minor alterations to historic resources shall require a determination of consistency with the Secretary’s Standards. The Department shall make consistency determinations for minor alterations. Staff may retain a qualified professional, when necessary, to assist in making the determination. Consistency determinations for major alterations shall require an evaluation by a qualified professional and review and approval by the Historic Resources Board.”
The scope of work proposed under DR 22-310 and part of DR 22-157 includes the relocation of the Northern California Savings and Loan Complex Community from lot 6 to lot 4 of the Complex site. CMC 17.32.160.A includes “Relocation on the same site and with the same setting or context” as a major alteration.
As required by CMC 17.32.160, Determinations of consistency for major alterations shall be prepared by a qualified professional and shall be supported by written documentation that (1) identifies which of the Secretary’s Standards are applicable to the project, (2) reviews the proposed project, and (3) explains the basis of the determination. If an evaluation concludes that a proposed alteration is not consistent with the Secretary’s Standards, the report shall list aspects of the project that are not consistent along with guidance for modifying the project to comply with the Secretary’s Standards.
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.
PAST evaluated the project for consistency with the Secretary of the Interior's Ten Standards for Rehabilitation (Attachment 4). PAST found that Standards #1, 2, 3, 5, 6, 7, 9 and 10 are applicable to the project. The evaluation concluded that the project as proposed is not consistent with Standards #2, 5, 9, and 10 and is not consistent with the Secretary’s Standards.
An analysis of the project components which do not comply with the Secretary’s Standards are outlined below. A discussion on the standards that are met, or are not applicable, are included in the Phase II Report, included as Attachment 4.
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 original spatial relationship between the bank building and the Community Room is a primary character-defining feature of the site. The bank building and the Community Room were designed as an integrated unit, carefully sited to place the Community Room in a prominent position facing Dolores Street. The proposed project to relocate the Community Room removes this vital and original spatial relationship.
The Community Room was a programmatic requirement specifically requested by the bank officials who tasked the architects to design a separate building away from the bank’s regular operations to serve as a meeting space for the local community. This feature was considered a critical element of the bank complex’s design as it was intended to foster greater connection with the bank and the surrounding community, thereby improving public relations and increasing the bank’s community exposure. The Burde/Shaw design team’s solution was to separate the two buildings, yet design the Community Room with the same character-defining features as the bank, including a dramatic shed roofed volume clad with copper sheets, Redwood siding boards that match the bank building and the use of large plate-glass window walls, to integrate the Community Room within its environment.
When viewed from the south on Dolores Street, the Community Room’s massing and placement within the site present a south elevation that integrates the Community Room within the complex’s overall design, allowing the two building masses to appear as if they were composed as a single building. Relocating the Community Room from its original location would substantially alter the south elevation of the building complex as it appears today.
The Community Room uses the same character defining elements, materials and construction details of the bank building and maintains all seven aspects of historic integrity, including integrity of its original location south of the bank building, and linked by the elevated walkway.
In addition, the proposed Community Room’s relocation removes another important character defining feature: the elevated walkway connecting the bank building to the Community Room.
For these reasons, the proposed project is not in conformance with this Standard.
Standard 5: Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.
Phase II Response: The proposed relocation of the Community Room removes a primary character-defining feature of the original Burde/Shaw design concept: the spatial relationship between the bank building and the Community Room. In addition, the proposed project will remove the elevated walkway, which is another distinctive character-defining feature of the building complex’s design. The proposed project is not in conformance with this Standard.
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 proposed relocation of the Community Room removes the original spatial relationship between the bank building and the Community Room, a primary character-defining feature of the site.
In addition, the proposed relocation of the Community Room destroys the historic materials of the covered walkway, removes the original landscape walls and raised pavement areas surrounding the Community Room and alters the original Burde/Shaw design concept by relocating the Community Room elsewhere on the site. The proposed project is not in conformance with this Standard, particularly due to the removal of critical spatial relationships that characterize the property.
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: The relocation of the Community Room will likely not be reversible, as the intent of the relocation is to develop the lots immediately south of the bank building. In addition, relocation of the Community Room will destroy the integrity of setting of the historic resource. The proposed project is not in conformance with this Standard.
In addition, the proposed relocation of the Community Room destroys the historic materials of the covered walkway, removes the original landscape walls and raised pavement areas surrounding the Community Room and alters the original Burde/Shaw design concept by relocating the Community Room elsewhere on the site. The proposed project is not in conformance with this Standard, particularly due to the removal of critical spatial relationships that characterize the property.
Staff Response: Staff concurs with the conclusions of the Phase II evaluation outlined above. In addition to the conclusions reached in the Phase II evaluation, the Historic Resources Board previously adopted a Resolution, 2021-03-HRB, Attachment 10, issuing a Finding of Noncompliance for the demolition of the Community Room in which substantially similar findings where made when considering application DR 20-395, including findings specific to the importance of the existing spatial relationship between the Bank Building and Community Room. This decision was appealed to the City Council who at a De Novo hearing denied the appeal and issued the Finding of Noncompliance (Resolution 2021-043; Attachment 10) as found by the HRB.
While relocating, as opposed to demolishing, the Community Room maintains the physical structure, the character defining spatial relationships of the between the two buildings would not be retained nor preserved. Additionally, the relocation of the structure to a new location on the site would alter the remaining portions of the site and the original concept of the Complex would be lost. The visual appearance of the site would be altered from both the Dolores Street and 7th Avenue elevations as a result of the loss in the Community Room when viewed from Dolores, and the building being visible from 7th Avenue. Neither of these outcomes were part of the original architect’s design intent.
Project Alternatives:
CMC 17.32.160.C states that If an evaluation concludes that a proposed alteration is not consistent with the Secretary’s Standards, the report shall list aspects of the project that are not consistent along with guidance for modifying the project to comply with the Secretary’s Standards.
The Phase II report concludes:
The project under consideration proposes the relocation of a primary character-defining feature of the building complex’s original design: the spatial relationship between the bank building and the Community Room. To maintain the integrity of the subject historic site and its environment, this report respectfully recommends a new design approach that allows the original Burde/Shaw design and the building complex’s corresponding character-defining features to remain in place.
If the HRB disagrees with the conclusions of this evaluation, the HRB should direct staff to obtain a second option and have a second Phase II Evaluation prepared. Once prepared, staff would then return to the HRB for review of the second Phase II Evaluation.
Public Correspondence:
At the time of writing this report, staff has received one communication regarding the project. The letter that was received has been included as Attachment 10 and includes an email correspondence as well as attachments that were included in the email.
Environmental Review:
Listing on Carmel Inventory and Register
Staff recommends that the listing of the subject property on the Carmel Inventory and Register be found to be “not a project” pursuant to section 15378 of the CEQA Guidelines. Listing the subject property on the Carmel Inventory does not grant any permits or entitlements approving a project that would result in a direct or indirect physical change in the environment.
Community Room Relocation
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. Consistent with CMC 17.32.160.C and CEQA, if the modifications are found to be inconsistent, and the applicant does not choose to modify the proposed alteration to comply with the Secretary’s Standards, the Department shall require preparation of environmental review documents to further analyze and mitigate any impacts to the historic resource. These CEQA documents would be required prior to issuance of any discretionary permits for the project, and could include up to an Environmental Impact Report (EIR).
If the applicant chooses to work to modify the proposed project to comply with the Secretary’s Standards, the Department may require that the applicant withdraw the current permit application and resubmit the revised project as a new application. If the Board issues a determination of consistency, the Director shall determine whether the project is eligible for a categorical exemption consistent with the CEQA Guidelines. Further environmental review may still be required to address other aspects of the project and the Department shall cause to be prepared the appropriate environmental documentation for the project, and shall cause the processing of the permit application to continue pursuant to standard City practices.