Re: Agenda item 6.1
Mayor Kamei & City Councilmembers,
On behalf of Mountain View YIMBY, I am writing to express several concerns about the current direction of the Historic Preservation Ordinance and Historic Register Update. Our goal is to ensure that Mountain View’s approach to historic preservation prioritizes the preservation of genuinely unique historic resources while ensuring that we respect Mountain View’s history of being a vibrant, diverse, and continually changing city that welcomes new neighbors, stays affordable for current residents, and allows architectural innovation.
As such, we appreciate that a reason for the Update is to facilitate CEQA by having a prepared list of known historic resources. We also appreciate the desire to assist people with properties on the Historic Registry to make changes that do not impact the historically notable aspects of their property. However, implementation matters immensely to effectiveness.
Our concerns center largely around the overly broad definition of a “historic resource,” with nothing to distinguish properties worthy of substantial protection from those simply old enough with no significant changes. For instance, 251 Chiquita Ave’s eligibility for the registry is based on it being “a good local example of a Craftsman bungalow built during a period of increased housing development for local employees of the Pacific Press Association.” (Page 129, ATT 5).
The report includes the photo below, with notes that most of the external-facing architectural elements would be considered “character-defining features,” including the roofing, cladding, windows, porch, eaves, and vents.
The justification for most properties on this list appears to be similar, with similar sets of things included in the “character-defining features.” Combined with staff’s recommendation for a far more onerous opt-out process, essentially any 50+ year old building in Mountain View without substantial alterations would face onerous permitting procedures for any changes (whether seismic retrofits, fire safety, or accessibility fixes). While procedures would exist for many of these things, whether via the California Historic Building Code or via city-administered exemptions, we have consistently seen that extra procedural barriers & approvals meaningfully increase the cost of making such improvements, and thus lead to lower-quality, less-accessible, and less-safe housing for residents.
With these things in mind, we would suggest the City:
- Maintain clear & objective criteria that it will use when it needs to perform CEQA analysis, and endeavor to identify properties meeting those criteria in advance. This does appear to be the current direction of the project, we hope that it continues so that CEQA analysis can be performed expeditiously when needed.
- Separate properties significantly critical enough to preserve from those less so
- For significantly critical properties, the city should work with the property owners to determine the long-term cost of maintaining the historically notable features and ensure that the burden for doing so falls on the city making the designation and not on the property owners, who now or later may have neither the money nor the interest to maintain. In extraordinary cases, the city may choose to take direct ownership, as is the case for the Rengstorff House and the Adobe Building.
- For less significant cases, the city should continue to allow property owners to opt-out. As seen in the public comment in Attachment 8, some property owners are excited about preserving the historic nature of their own property, but do need the Mills Act compensation to afford it. Allowing this to continue for less-significant properties is appropriate, but we should not be forcing these property owners to participate in the Historic Registry.
- Not to introduce historic districts. It is not clear what the purpose of local historic districts is. At this time, there is no area in Mountain View where every property should be automatically considered worthy of government-designated preservation, unless the district were defined so narrowly to be individual buildings. If the city is to create a process for this, however, it should require a far higher threshold than 50% of property owners approving. While 50% may be appropriate for a petition to consider creating a district, the city should also require a super-majority (e.g., 75%) of property owners or residents to formally approve of the district.
- Provide explicit exemptions for accessibility and safety-related improvements to designated properties.
Mountain View YIMBY does acknowledge the work of staff and the consultant in compiling the comprehensive history used in the draft survey. It is important to note that the physical preservation of building facades is not the only way to preserve and teach our history. We would love to see some of the work that has already been done preserved and collated into a more approachable form so that more people can learn about Mountain View’s history through architecture. However, if we are to truly respect Mountain View’s history, we cannot forget that it is the people, not the buildings, that make Mountain View the city that it is.
Thank you for the opportunity to comment,
James Kuszmaul, on behalf of MV YIMBY