planning commissioner fong. hillis. johnson. moore. and we do expect commissioners melgar and richards to arrive shortly. commissioner koppel may be absent today. you have two items on your calendar. item one, the communication between commissions. >> good afternoon, commissioners, department staff. welcome to this first joint hearing of 2019. and i wanted to make a few comments to you before you dive into your calendar. first of all the calendar was structured based on comments

that we received by your commission officers and we've done our best to draft those as best as possible to allow for an engaging dialogue over this morning. but it takes no small effort to pull all of this together. so i wanted to make sure that you were all familiar with the planners that are joining us for your technical questions and any comments that you may have this morning. we have lisa gibson and a allis, and anne marie rogers and in the back row pilar ralilali, and justin greving and desiree smith. and monica jacamoche. and they were integral in putting together your packet and is here to answer any technical questions around the historic preservation program of the

department. so with that i'll hand it over to you and we'll have two short presentations today related to your items. naturally, we're here to answer any comments or questions that you may have throughout the morning. thanks. >> clerk: i think we have a staff presentation on item one. >> good morning, commissioners. i'm department staff. this is just a short presentation that has been put together to provide a general overview of the historical review process, and with the following discussion that your commissioners want to have between the historic preservation commission and the planning commission. to point out that the department would be happy to provide additional information on the process generally and historic review process more specifically to either commission in the future. so the historic review process by the planning department preservation staff typically

involves one or more of the following steps. the first is a proposed project meets the scopes of work in the checklist. is the property an historic resource? is the proposed project going to impact the historic resource? what is the level of the impact? can mitigation reduce the impacts? is it unavoidable? and then it requires e.i.r. and planning will be developed. and to include the categorical checklist, there's a variety of scopes of work. this is included in your packet under steps 4 and steps 5. these works -- if the project can fall under the scopes of work in these steps then no additional historical review is needed. these scopes of work that the department has determined is not

to cause an impact on the historic resource. and if the projects don't meet the scope of work then the review that i'm about to discuss will be required. for information purposes, there's the san francisco properties into one of three categories, categories, a, b and c. and a particular category is not a definitive assessment of its status and the properties can change categories during historic review process. and note that these are not sequenced categories. category a properties are historic resources under ceqa and include the properties either listed and/or formally determined to be eligible for the california register of historic resources or the national register of historic places. and they are listed in like article 10 or 11. or determined to appear eligible for the california register either through survey evaluations or through staff review through the environmental review process. more detailed information about

these categories can be found in preservation bulletin 16. and as the, voliation of the property is needed, then e.p. preservation staff reviews and determines if the property is a historic resource. properties not previously evaluated and are determined to meet the definition will be evaluated using the california research criteria. the e.p. staff will determine if the property is an individual resource and if it's within a district, if it contributes to that district. and if a property is determined to be significant, then e.p. preservation staff will determine if the property retaining its historical integrity and will identify the features. a property can be determined significant but not have historic integrity and not considered a historical resource. and a property can be in good condition but lack significance. >> thank you. can you speak a little slower.

we're not familiar with the in betweens. i appreciate that. >> the variety of documents that are produced to help staff to determine whether or not a property is historic resource, technical studies can be submitted by the project sponsor which is the historic resource determination supplemental application. this does not require a qualified consultant to prepare. and there's evaluation report which is -- does require qualified consultant to prepare and has an evaluation of the resource. and the supplemental just gives background information and both are used by the planning department staff to help to inform their determination. and then the planning department staff records their determination and the historic resource response part one, or a preservation team review form. e.p. preservation staff then

determine whether the proposed project would impact a historic resource of the subject property. if it would impact the historic resource status of the historic district in which the property is located or any adjacent properties. >> remember, you were going to slow down. [laughter] if i could interject. >> it's going to be a very quick fast presentation to focus on your discussion. but, okay. >> maybe not to distract you from your presentation, but we thought that it was important to get basic context on what goes into the process and the evaluation and i'm wondering is there any slide, if we could just pause and see if there's any questions from -- we're very -- most of us are quite familiar with it. but if you are not, maybe just take a pause at each slide. >> all right, you want to start over? not from the beginning but -- >> any questions up to now?

>> the one thing that i thought might be helpful to clarify is that up to now what we're talking about with historic resources, then there's a further refinement of that and that's what is under article 10 and article 11. >> right. and so just to clarify this presentation is very much focused on the ceqa review process and not sort of the entitlement or the other roles of the h.p.c. or the planning commission. so this was very much to be focused on the historic preservation process under ceqa and it's to be a very brief presentation and then staff assumes that we will be giving additional presentations to either commissions based on the outcomes of the conversations today. >> so maybe -- i would like to just offer some guidance. maybe go back to the determinations slide after the three categories. that might be the -- a good place to pick up.

the first slide under "determination of historic resource." following the categories, a, b and c. and i think that this is some of the areas that the planning commission may benefit from our knowledge and that is integrity, significance, and condition. and the character defining features, yes. >> are there any additional questions or clarifications on that? and one of the points that i was trying to make in the slide is that you can have a building that is in good condition but it might not have significance. and you can have a building that appears to be not in good condition but does have significance and still can retain a historical integrity. any questions on preservation documents? all right.

so for preservation documents for project impacts, consultant will repair the evaluation report when requested by the department. this should include either a secretary of interior analysis of the property or a compa compatibility analysis and we're doing this more in-house with staff. and a response part two would determine whether or not the project would cause a significant and unavoidable impact on an individual resource. if it is compatible with the district. if there is a district present. and often this can require multiple rounds of design revisions with project sponsors if we're trying to get a project to meet the secretary of interior standards. we also work with design staff to see whether or not we can get the project to meet the

standards and the design guidelines of the department. and then finally since there's questions about this, there's the preservation review team form. which is a document that allows for streamlining of the review by the historic staff but it has the same function as h.p.c. part one or part two. and it's used when we're relying on the h.r.a. for most of that documentation but it serves the same role as those other documents. and if there's a determination by staff there's no impact to the historical resource and no other ceqa impacts they can issue a p.t.r. form or the hrer attached and then these are distributed to the public who requested them and also posted on the department's website. and if there is an impact to the historic resource identified, then we attempt to see if we can mitigate those impacts to a less

than significant level if possible. so mitigation measures reduce the significant impacts and then if they are feasible they'll be adopted. common preservation mitigation measures are documentation, interpretation, oral history, salvage programs and vibration monitoring protection plans. there's various documents that can be prepared if there's a significant impact on a historic resource or other topics under ceqa. and a negative impact can be mitigated to a less than significant level. and environmental impact reports are where a significant impact is not reduced to less than a significant level. we have community plan evaluations but i was going to only get into that if there's specific questions about it.

>> maybe i can interject. i think that at this point in the evaluation process is where the project -- if it's article 10 or 11, it may come before us for a c.o.a. and if not it's only before us if the impacts are not mitigated. i think that is one of the areas in the draft e e.r. that our two commissions were thinking is why we had one of the reasons that we had the meeting today is to look at ways that we can improve the communication in the draft e.i.r. when the impacts that resources are not mitigated. that's the only time that non-level 10 and 11 project comes before our commission. does that make sense? >> and preservation alternative. >> excuse me. we have a commissioner richards. >> so one of the issues -- we have two richards.

>> oh. i'm sorry. >> one of the questions that i have is the -- some of the e.i.r.s and the alternatives that have been done raise questions in my mind. we have one that is like 150, eureka street that looked like an honest assessment, the project program could actually fit in a preservation alternative. and then you have these other ones that i'd say they're less than -- fully baked. and the reason that i say it is, what they do is there's one that i'm -- i can't say now because it's still in the pipeline, but it looks like when you look at the alternatives they have alternative a through h, and it looks like some of the historic targets are not feesible because they have a certain height limit. but in the other more feasible ones they have height limits at

different levels. so it's not apples to apples. that's what really concerns me, is that projects have the demoing as their primary thing and they're cooking the books to actually to make it look like they can't do their program in anything but a demolition. now that concerns me. i am not sure that all the e.r.s are true. and the only ones that i really trust are the peer review ones. >> okay. >> lisa gibson environmental review officer. i'd like to respond to that, please. i want to assure you that it is, indeed, a very robust analysis that we conduct and it is -- it is not at all directed by the project sponsor and at the same time i want to know -- i share that i do hear your concern about this. but the process is that the planning department does direct the development of preservation

alternatives and all alternatives and the process is collaborative. we work with the project sponsor and we start with their project objectives. and under ceqa we're required to develop alternatives that meet most of the basic objectives of the project and then that also lessens or avoids the significant impacts of the project. and we have to have a reasonable range of alternatives. it is not, you know, a clear bright line for our development of alternatives, so there is some judgment that we apply. and in terms of the objectivity, it is very much an effort that we strive towards objectivity and really genuinely working -- there's a lot of time that we spend working with our staff and the consultants and the project sponsor. and there's a lot of tension. because, indeed, a project sponsor comes in with a project that they are seeking approval for. they want that. and many of them are not

thrilled with the ceqa alternative development process. but it is a requirement under state law and it's one that we take very seriously. and with regard to different variations that you'll see in different e.i.r.s, whether one al turntivalternative requires t decrease and the other doesn't, we have alternatives to be creative to, again, to avoid the significant impacts of the project while achieving the sponsor's basic project objectives. you know, that results in -- every project is different, different sites. so it can result in different variations on the theme. >> great. under no circumstances am i accusing the department of cutting corners or anything. it just raises eyebrows when this one works because it's 65 feet but it doesn't work when this one is 40 feet. the second question -- the only time that i have seen a peer review with a historic project

was on 4050farrell. and do they put it out for peer review when the historic resource will be destroyed? >> so i understand your question to be, is there a peer review process for the analysis of an historic resource when the project would involve demolition of a historic resource? >> right. >> so there is a consultant that works with the project sponsor to prepare their -- to develop that project. and generally when we're doing a project that involves demolition of a historic resource, they usually have a preservation consultant that works with them to develop their project. we have a separate consultant that works with us in preparing the environmental impact report and developing alternatives. and in that regard there is a separation because we want to ensure that there isn't a subject -- there isn't a bias in

developing the alternatives because, obviously, the sponsor and their consultants have a vested interest in the project. >> so is 4050 ferrell an outlier? because you understood that the total demolition is the only way to build the housing? >> i'm not familiar with the peer review that you're speaking of so i'll stop and ask, if the attorney would like to comment on that. >> i have a clarification and that may be helpful. what i think that you're talking to, commissioner richards, is the cost estimate that was peer reviewed and not the historic preservation alternatives. we always hear projects don't pencil and we're like show us, right? >> got it. that question relates to not the environmental impact analysis, but the approvals process. and when the lead agency, the decisionmaker, is approving a

project that would have a significant effect on the environment and there's an alternative that would avoid that significant effect, and the project -- and the project sponsor is saying that it's not financially feasible for them, we need to have documentation to subsaint arsubstantiate that cl. so we require an economic feasibility analysis that evaluates and substantiates that claim. we do ask that we -- we want to have a second party to review that and verify that -- the basic assumptions in that are correct. so that we are doing that now in all cases when we are -- when an alternative is being rejected on the basis of financial feasability. >> fantastic. >> can i ask a question relative to that? you know, it seems like the developer comes in with

objectives and then the department is required then based on those objectives. do you spend time ferreting out the objectives and i am a developer and saying i will put up a 60 story building and there's no way that it would work relative to the historic resource. >> yes, that's a really great question. and that is, indeed, an important part of the environmental review process when we prepare an e.i.r. and we start with the alternative development process, we start and review those in the planning department and with our city attorneys to ensure that they are not so narrowly construed as to only allow for the project that's proposed to meet those objectives. so they can't be so narrow. they have to be more broad. so we're often editing and providing feedback on those so that they are suitable for the purpose of environmental review.

so, you know, they can't just say that we want a project with x number of units. you know, it needs to allow for some flexibility. so that is -- there's a back and forth process on that. >> if i could interject, i think that commissioner moore wants to speak as well. but if i could interject as well. in the process the preservation alternatives first come -- well, at one point they come before the a.r.c. of the committee, the architectural review committee. and we help to guide those alternatives and communicate with the staff and project sponsor what the improvements that we think that the a.r.c. can make. and then it comes before the full h.p.c. and sometimes that happens the day before it comes before the planning commission. and what we really want to kind of delve into -- i think that this is a really good topic, it's going to take a lot longer than i think that we have time today to actually understand a-z on it, but it's our

communication what happens at the a.r.c. and the h.p.c. and how that information is communicated and understood by the planning commissioners. so -- >> the summary that is in -- you know, from the staff -- is limited relative to the conversation that we've actually had. >> right. >> so there's a lot less information that the planning commissioners are getting relative to why we think that these are appropriate or not appropriate, relative to the alternative. >> so we'll come back to this. commissioner moore? >> i would like to briefly mention with commissioner richards had previously mentioned, the largest dichotomy is understand the developer objectives is that the two values by which both parties approach a subject matter are noncompatible and they're non-linkable. is the objectives of a developer are yielded and translating into money and it's mostly basically expressing yield and there's no connection to the basic value of

what the historic preservation is tasked to bring forward. there's never that. and in the majority of cases the alternatives that we see could be for historic purposes in support of your mission and do not meet these objectives. they are all basically complete demolition and unavoidable impact and a plaque. that's mostly what we get and there's no in between and there's no contemporary architecture which can really bridge that particular gap either because in the many discussions that we have, particularly with heritage weighing in, the alternatives that you are probably helping to carefully craft are unacceptable in the larger objective of historic preservation. and we find ourselves basically only on the receiving end where we have to accept what you're

mitigating as acceptable. and that may not meet our objectives. because we still have the public basically speaking to us that what we're doing is not responsible preservation or supporting responsible preservation. >> a lot of that is just the time. it comes to us one day and goes to you the next day. >> we only hear you about you in the meet chicago is basically void of any informed and critical dialogue of how we could together perhaps steer the ship in a slightly different direction. i assume that the environmental reviewer does what they can, but they do not help us to make a critical decision. >> commissioner richards? excuse me, a point of order, please. can you request to speak so i know that you're wanting to speak? >> i'm sorry. sorry. okay. oh, yeah. i didn't realize that our speaking order was -- >> on the roster. >> sometimes we go for hours and

hours. >> i don't have a -- >> okay. >> i don't have a monitor. so that's the problem. i just want -- my point of order is about the staff making a presentation but i think all of us -- including myself -- have a particular interest in what we want to accomplish at this meeting. and this particular topic on preservation alternatives, i would like to state for the record for everyone here that i think that what we're really interested in establishing is a closer connection of encouraging the planning commission to encourage project sponsors to incullpate the preservation value into their projects and how we can work together to get there. so i think we want to spend more time on that and if we let allison finish her presentation,

then we can get into it. and maybe go around and each of us state what we want to accomplish by the end of the meeting. i think that would be good. >> that's a great idea. is that okay? >> and specific to the e.i.r. process and our communication as well. sorry. >> okay, so preservation alternatives. so ceqa needs a range of project alternatives. [laughter] i'm just going through this. okay, so when significant impacts to historical resources cannot be mitigated to a less than significant level, as part of the e.i.r. process the department and the project team develop project alternatives. in 2015, the historic preservation commission adopted resolution number 746 to clarify expectations for the evaluation of significant impacts to

historical resources and the preparation of alternatives and impact reports. it requires the development of an alternative and alternatives are also presented to the h.p.c. for their review and this is a recent change. preservation alternatives were being brought to just the a.r.c. and we will now, starting in march, bring them to the full historic preservation commission. probably to address some of the concerns that just came up. and we're also thinking that those would come earlier in the process, rather than having a fully developed alternative come to the a.r.c. and we would really have sort of more schematic alternatives that would be brought the scoping to the full h.p.c. and then one of the conversations that could come up later on in the hearing could be on the communication between h.p.c. and planning commission on alternatives.

all right. the press verration alternatives are analyzed in the draft e.i.r. and the e.i.r. is brought to the planning commission for review and comments. and here we are in the comment period. and the comment letter from the h.p.c. on the e.u.r. is sent to the e.r.o. and given to the planning commission, usually due the comment on the draft e.i.r. any clarifications on that poi point? in regard to ceqa findings and statements of overriding considerations, no h.p.c. approval is required, and then the planning commission can make ceqa findings and consider the project approval. and then do we want to get any details on findings or any overriding considerations?

any conversations about that? and the statement of overriding consideration is required when a project results in a significant and unavoidable impact. and so for statements specific economics, legal, social, technological or other benefits that outweigh the project's unavoidable impacts. there's a point on if the financial requirements that are leading to significant and unavoidable impacts and rejection of alternatives, then we are looking at peer reviews of those economic studies that we just discussed. and the statement of overriding consideration is drafted by the project sponsor with the city attorney's office.

okay, so ceqa is required for... for all projects, even those with no other hearings before commission and the ceqa document must be completed before a project approval hearing can be held. and in 2017 and 2018, the department issued approximately 6,000 categorical exemptions, about 30 community plan evaluations, and 11 mitigated, and about nine e.i.r.s. >> so was that the statistics that i was requesting as far as like how many -- >> those are how many are issued and those aren't including whether or not historic resources were reviewed necessarily. does that make sense? >> do you know how many -- i mean, the specific question was

how many ceqa evaluations as regard to historic preservation projects didn't require an e.i.r. assessment for the historic resources because the project mitigated them to less than significant? >> so that we'll have to get into more details with numbers and we'll get back to you on that specific question. but -- so, yeah, there's nine e.i.r.s in that period and then the onings that would have been brought to you are the ones that would have had a significant and unavoidable impact on a historic resource. yeah. so those that didn't do that or mitigated to less than significant wouldn't have been brought, either for alternatives because alternatives wouldn't have preservation a alternatives if there wasn't the unavoidable impact to the historic resource. so those wouldn't have come to h.p.c. for review and comment or for alternatives. >> and those nine might be

e.i.r.s that didn't relate to historic resources? >> yeah, they wouldn't have been brought to the h.p.c. but would have come to the planning commission. and mitigated and categorial exemptions are not brought due to the ceqa portions of that. so if they have an article 10 or 11 they would have been brought to the h.p.c. as part of the project entitlements. >> commissioner richards? >> so i think that it's appropriate to ask the question right now because we're talking about expanded roles. i personally would like to see more expanded role for your commission as it communicates its expertise to us. we would normally get the night before some type of letter that we kind of look at and go what does this mean because it says that you certify the e.i.r. was actually done and complete. but i don't see the back and forth that you had and i sat here recently for a hearing completely unrelated. i came and heard one about a project coming before us in two weeks. and, you know, the project sponsor just has us come out to the site and they say blah,

blah, blah, and we don't have the benefit of the discussion that you've had. and now that i have actually sat through that and i'll go to visit the project site and i remember all of that. it really, really helps me to understand who's right and what the shades of gray are. so here's what i'm thinking, and i'm thinking along the lines of how do we get you folks to have expanded responsibility to review category, ceqa category a, but not articles 10 and 11? and the national register districts -- because we have demoed three buildings in the tenderloin registered district and we had no idea what the significance of it was in the context of the district. so there's 450 buildings in the district and we demoed three and we're kind of like, we could probably demo 100 more because there would still be 300. we don't have the expertise that would say, you know, this is one that you wouldn't want to demo though it's one out of so many.

and that context, i keep lacking that context. because, you know, we're the death squad of the building and we do the overriding considerations and the building comes down and it's because of us. and i want to take it a little bit more seriously. so that's -- >> i think that is hopefully a larger goal for our entire discussion today. so we'll come back to that. if that's okay. >> can i respond to that? >> commissioner perlman. >> those known resources, category a, don't even come to us. so it seems that the responsibility is in the staff's review. because the staff is making the final decision. you know, like i've had projects that i worked with the staff and one of them was in the uptown tenderloin district and it was torn down, but the determination from the staff is that it wasn't significant to the district. and, you know, it was a crappy building, in bad shape, and it didn't relate to the specifics of the district. but it was a category a because

it was in the district. so the responsibility can't fall to the h.p.c. if we never even see it. so, i mean, there's some level of the responsibility of the staff which should be in the staff report, i would assume, about why, you know, that isn't considered an important building or its historic qualities. it should be in the description of the staff. >> it is. it almost always is. >> yeah, so part of that would be in the determination of -- if it's just a district contributor and not an individual resource, if that was previously determined. if it wasn't, staff would look at it and determine if it's an individual resource as well as a contributor to the national register district. >> i'm sorry. if that was not the case it would not be an "a." >> it will actually be an "a", even if it's a non-contributor to the district, and we want to flag that to make sure that it goes through preservation review to make sure that the new construction is compatible.

so that's why you can have a parking lot in a district that is still a category a. because we want to make sure that the staff looks at that and makes sure that the new construction will not cause an impact. so for those ones that didn't come to the h.p.c. that are demoed, that would have to do with the fact that they weren't individual resources and it was determined to be a less than significant impact on the district. >> lisa gibson. i'd like to add a clarification with regard to category a. when we talk about a district, the district itself is the resource. contributors, individual properties, may be a contributor and they do need to be reviewed to determine whether the project would have a significant effect on the district. but a demolition of a contributor is not automatically a significant impact under ceqa. so the question is, would the project materially impair the historic district due to the demolition or authorization of that contributor?

and that question is one that is very important and is evaluated as part of the historic review process. and the question of, you know, the numbers of contributors that may be lost over time is something that we look at as part of our cumulative impact analysis. >> please continue. >> so the role of the h.p.c. and ceqa, for the comments on the preservation alternatives, comments on the e.i.r. for projects that affect the historical resources, and for projects outside of article 10 and 11 that do not have an impact on historical resource, they are generally not brought to the h.p.c. but for the h.p.c. charter, for proposed projects that may have an impact on historic or cultural resources, then the h.p.c. has the authority to review and comment on the environmental documents.

and then instead of the planning commission, the planning commission hears appeals on preliminary mitigated, and on the draft e.i.r.s are held at the planning commission and they certified e.i.r.s as accurate and prepared requiring to ceqa. and this concludes my overview presentation on ceqa and the historic resources. and the staff is here to answer any questions that you may have. great. so why don't we do this, why don't we open the mikes up for the commissioners to state hopefully what they're looking to get out of today's hearing and the improvements that we're trying to seek between what the -- with the communication between the two commissions. >> there may be public comment that you may want to take. >> yeah. why don't we hold off on that, if that's okay and we'll come back to that. so first comments, and we'll do commissioner comments and then public comment and come back for

a dialogue. okay? sure. so as i have viewed our relationships, as we are primarily an advisory group, giving you folks information that you would find useful in exercising your death squad activities... [laughter] in some cases or in making the decisions that you're going to make. so one thing that has always concerned me is are we providing useful information to you? are we providing it in a timely manner? and are we providing it in a form which is easy for you to use? if we're not doing any of those

things, then i would really like to know so that our time can be spent in a more effective way that's being helpful. so that's really what i hope to get out of the meeting. >> can i interject? thank you. ellen johnck, nice to see everybody. i'm one of the people since i have been on the commission to encourage this joint meeting. i also have been interested in having a joint meeting with rec and park commissions as well and maybe even the three of us at some point would be great. and -- but i think that where i have seen the need for closer communication and segueing off what commissioner johnson said between our two commissions, is in the arena of the e.i.r.s at the ceqa level and where we originally -- when i first came

on the commission 10 years ago or so -- we were receiving -- asking for public comment on the draft e.i.r., where preservation hadn't even been considered yet and the project sponsor would come into us and talk about what a wonderful project it was. and i'm sure that it was a wonderful project. except that there was -- and i was kind of saying, well, to myself -- do they know who they're talking to? this is the preservation commission and we're interested in what a preservation solution was or is, particularly if there's demolition involved. so at that point we agreed among the commissioners that we wanted to see the project sponsor come up with preservational alternatives early on before we received the opportunity to comment on the draft e.i.r. and so that has been helpful. and we've received more of those. now, are you getting some of that information? but where we're asked to comment

then are the preservation alternatives adequate? well, so far we're getting some more expansive -- not just one or two, but getting five or six, which is also good -- but we also have ideas about which ones we think that are better than others. and so we want to make sure, at least i do, that those views are best communicated to you and that somehow they are factored into your consideration and you have a better opportunity to do that. and so that -- my goal is to have some kind of resolution about where we're headed in that arena by the end of this meeting. and the other broader topic that i have is very much involving the port of san francisco and a lot of my consulting business as well as overall community support. i have been on a lot of advisory groups for the port. there's some very basic historic issues that are coming up with the renovation of the seawall

that i just think that maybe another type of -- where we have major planning discussions around major infrastructure in our city that involves historic preservation, i think that might be worthy of a separate meeting to get some ideas about how we're looking at major projects that would come before you. so that's another idea that i have for having another type of joint meeting on major planning discussions. thank you. >> chairman perlman. >> hi, everybody, jonathan perlman. what i would like to figure out and maybe have some forum to do is just what we were talking about with commissioner richards with conversations about design. i don't know if that's a workshop where we're not sitting in this kind of setting, where it's more informal and maybe it's, you know, the a.r.c. of the h.p.c. and two or three commissioners. some way to talk about design. because that's what seems to get

missed. when the preservation alternatives come to us basically our job is to say are these adequate. and for the most part they're adequate. i mean, there's been one or two that we have asked the project sponsor to go back and review and/or change things. but that's not a lot of latitude to talk about the impact, you know, to the design of the area relative to the historic building. whether it's a complete demolition or not. and the one that was put up on the screen, the one that is at the old honda dealer at the corner of market and van ness is very complicated. and we have no middle ground to determine if it is about a cultural event or, you know, or is there an architectural reason to save a building and not demo a building. but, you know, we don't have a lot of room for that conversation. so i would really love to see if there is some way and i am certainly willing to put in more time, more of my personal time,

you know, if that's something that would benefit the entire process because ultimately i think that makes a much better city if we're talking to each other and really talking about the impact of each of those. you know, we could discuss the impact of each of those particular alternatives. and so if there's a way to talk about design relative to historic buildings, i think that would be quite useful. >> kate black. i concur -- i concur with my colleagues. i think that there's a timing problem here. i think that the idea of the sub-committee, a blended sub-committee, is an excellent one that could be pursued. i'm sorry to say that i had never read the h.p.c. charter until this morning. but the language here is quite broad. it does not proclude us from

giving opinions beyond adequacy on the e.i.r.s. and i don't know if there shouldn't be code reasons why we can't do that. or guideline reasons. because, you know, the charter is the founding document. so i think that is something that we could talk about developing. where we do give better direction to the planning commission on which of the alternatives we think are preferable and why. if that would be helpful to you. because i don't see that it's procluded here. >> i concur with the other commissioners. and the planning commissioners and the response, especially commissioner johnck's question on what would be more helpful. >> me too. >> okay. >> so, you know, this is a little bit unusual for us because we usually hear from the

public first before we like weigh in. would my fellow commissioners rather do that? and then we can address everything. >> sure, we can do that. >> so with that we will take public comment. anybody want to weigh in before, you know, we respond to the issues that have been raised? >> good morning. my name is georgia schoutis and i'm focusing on what i call the venacular san francisco residential architecture. i think that a lot of the people in the neighborhoods are confused somewhat by the rankings that you see in the categorical exemptions. and before i say that, i don't want to say one thing about the numbers. and they also show occupants. i know that two that i can cite where the occupants were not listed. i don't know if would have changed the outcome but i think it would have been information

that was important for the staff and the commission to have. and one is the carl jebson building. there was a 90-year-old man that lived in this building for 50 years as an occupant. that's on the developer. but, you know, the staff learned that from the neighborhood. and the other one is a d.r. that i was involved in where they did not list the occupant and she was a former airport commissioner and an executive at the b of a and her family had lived in this building and owned it since 1927. barrel front mediterranean revival. and one of the relatives lived there and her half-brother was the founder of skyline realty with mr. l mirch by. whether that rises to the level of historic importance, it's certainly very interesting and it's information that should be in the cat x since i found it on the internet after an hour or two. anyway, with regards to the a, b and c. i think that b needs to have

more input. here's some things that i would like to show you if i could have the overhead, please. >> can we have the overhead. >> that has a major alteration. in the middle of a major alteration that is probably really a demo. this is also at c. that's gone now. this is a c. it's in the middle -- and this is a c. this is the one that i was talking about. (indiscernible) and it's very important in the mary brown study. but then some of them maintain their b, like this one, having a major alteration, it's still a b. and here is another c.

which the commission is familiar with, clayton street. and here's a b. here major alterations, but they're preserving the facade. and now here's an a. and here's another a. right here. that's an a. it still has its a rating. so i guess that my point is that -- i'm running out of time -- i would like to emphasize the importance of san francisco venacular architecture and the information and the cat x and how (indiscernible) thank you. >> thank you. any other public comment on this item? okay. commissioners? >> we could just go down the line. >> go ahead, commissioner. >> so i've got several things on

my list. one comment that i would love to see -- it's just a comment -- and it might not be lawful. but on the alternatives as a finance guy i'd love to see the profit margin and to measure each alternative against a reasonable rate of return. maybe it's not something that we can do or not but it really helps me, hey, this combination of office retail and hotel and residential is 8%, but this partial preservation is 7.5% and expects a rate of return at 6%. and so we're making decisions a little bit in a vacuum. and i want to keep wanting to understand the financial hit that the project sponsor is taking, measured against keeping some of the building or doing a preservation alternative. just to comment. and i like what miss schoutis also said and i think that we're really confused up here about a,

b, c. and 137 clayton was a classic example. it wasn't in any district and there was no context statement. it had a seven elements of integrity all perfect, i mean, nothing was ever done to the building since it was constructed and yet it was given a "c." and no famous person lived there and no famous event happened there and the architecture was beautiful, but it just didn't rise to the occasion that it was exceptional or whatever. and that really underscores i think some of the things for me as we struggle with that one. and why are we concerned about this? two reasons, at least personally. san francisco is a unique city in the world. and we have a housing shortage. and we have state mandate coming. and that's one of the things that i really want to get into and get these commissions to look in the mirror. and with the housing accountability act and with the density bonus and the waivers and concessions that we're

giving, we're putting a lot of development pressure on the existing resources. whether they're a, b or c. and we have built out the city. so i don't know if the plan is to demo noa valley and i see a structure like one of those victorians, every one that we lose out of the roughly 13,000 or 14,000 that we have takes another piece of san francisco away. people don't come to san francisco just for the sourdough bread. i have two people wandering around my neighborhood because they go this is like no other place on earth. so with the intersection of the housing startage and the state mandates that we'll have a hearing on next week, i'm really worried about what i'm seeing there and what is not going to be around in the future. i know that this city was built and the population expanded because we kept going towards the ocean. we have reached the ocean. and now some of those one story shacks are gone and we have buildings in their place.

i'm not saying that we shrink wrap the city as it is today but we need to be more careful and think about what we'll end up with. i don't think that we realize what we'll end up with. an example for me is toronto. i used to go to toronto and it was -- it was a great city. it had a mix of everything. and basically what the city did was that the state stepped in or the province stepped in under this o.m.b., which is kind of what we're going to be experiencing here if the state steps in. and the only piece that was really preserved was cabbagetown, i don't know if you know toronto or not but people go to cabbagetown and, wow this is what the neighborhood looked like. and the buildings from the 1860s and all of those brownstones, they're gone, absolutely gone. so i think that is what we're looking at the mirror and staring ourselves into a future that i'm not sure that we can really fully appreciate what's going to happen. i think that to commissioner johnson -- that's one thing to understand the state mandates and how they intersect with where we're going here.

whether things need to be on the register to be exempt from some of these laws. whether they're eligible. i'm really worried about why we have any buildings in 2019 that are still ca category b. we should have the city fully surveyed and the developer should know what is an a and a c and there's certainty. and everything is not a fight and we uncover a rock, oh, there's a resource here. that seems like we're kind of henning and pecking it, you know? so i really want to understand the budget and the work program and get the city surveyed in light of s.p.50 and all of the other things that are going to come down the line. so to commissioner johnck's point, are we getting enough information? no, absolutely not. we get this letter the night before or it's handed over the rail and the alternative are adequate and we go, what does that mean? the rich discussion that you have around the buchanan street project which we'll be hearing in two weeks is really informing me of kind of, wow, they said --

the public says, and the neighborhood says that it's this but the experts say that it's that. so we have like a chief building inspector come and represent the building inspection department. and we have a question about what happened to a building in the past in terms of permitting and work that's been done and work exceeded. but we don't get that kind of a report from you. so if one of you could stand up in front of us and say we debated this buchanan street project and this antique store and the public comment was this and this is what we determined -- it really informs us. so that's going to be my litmus test. so it will come to us. what i'll get is a letter that is saying that it's adequate but i have to start the conversation as i sit in that seat over there. so i don't think that we have enough information from you folks. and the other thing is in terms of the charter of the h.p.c., i'm a little bit confused. you're right, i think that you should be commenting on more, especially as it's ceqa a

categories but why did we draw a line at article 10 and 11, when we did the prop and why didn't it allow you to comment or say you're responsible for ceqa category a structures and national register districts? i'm confused as to why that is. because historical preservation is historic preservation. so that's another one. and my last comment is in the five years that i have been up here, the death squad has been pretty active, right? my effectiveness of the entire process in the lawful -- in the lawful context is how many preservation alternatives have actually been chosen and used and built? i'm aware of only one that's been chosen and i'm not aware of any other ones that have been elbraced by the developer as a good project that can meet the project objectives. so that's something that we're doing all of the due dill jens, preservation staff and e.i.r. and the environmental review staff -- world class, absolutely. but i just feel that we're on a

little bit of -- you know, it's a check the box item because nothing ever seems to get saved. >> commissioner fong. >> thank you. and speaking about cabbagetown and versus sourdough bread... certainly, it's unique. i just want to make a broad comment. this is incredibly for me sitting here technical information and i can't help but to hear these comments and share a bit of confusion. to a developer whether it's a sophisticated developer or someone trying to do a home remodel, it's got to be very, very daunting to figure this out. and i know that is the whole goal of this conversation, this joint meeting, which i think is great, but overall from both planning as well as h.p.c., we've got to do a better job i think of public outreach and information to take the mystery out of what we can out of it. so that when job comes in and the expectation level of what they are required to go through

is a little bit better understood. i think that it would make everybody, including folks here who deep dive into it, to have a better understanding and confidence. i'm not sure that we'll get to it, but i have more questions about the legacy business program. maybe just a little background of some of the benefits. but we can get to that later. >> commissioner hillis. >> sure. thank you for the comment. i mean, i agree with commissioner black, i think that you're not limited necessarily to the ceqa analysis. and i would take that -- because that's where i think that we struggle or perhaps a project -- and i go back to 450 farrell and the eventual demolition of that building. i actually believe that we made the right decision in that to demo that building and to allow for a significant housing project to be built there. and i get that that is open for debate. there maybe may have been fols