t coR
OF CAU\i
CITY OF CORONADO
1825 Strand Way
Coronado, California 92118
(61e) s22-7320
Appeal Hearing Form
Appellant: Kathleen Ann Cohen, Co-Trustee
Mailing Address . 514 1st Street
Coronado, CA 92118
phone g.925-708-6023 Fax #:
Alt Phone #:
Email: [email protected]
Appellant's Rep.: Scott A. Moomjian, Esq
Mailing Address ,
5173 Waring Road , #145
San Diego, CA 92120
phone +, (619) 230-1770 Fax #:
Alt Phone #:
Email: [email protected]
Srgnature Signature:
. Historic Resource Commission This Appeal is relative to the action taken by the Date of Determination . 7117124
Mo/Day/Year
For the project known as:
Determination Of Historic Significance--514 1st Street
Board, Commission, Committee, or Department
Project Address:
514 1st Street, Coronado, CA 92118
For City Use:
Appeal Fee Paid Per Fee Schedule
Application Complete & Legible
Number of Copies of Materials Required
Receipt No.: Acct: 108-5400
Describe Supplemental Materials submitted:
Associated City Dept:
Associated Case No:
Wil
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Sept.2015 Page 1of2
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Attachment 7
Appellant's Interest in the Appealed Determination:
Appellant represents the property owner, the Schubert Survivors Trust 07-06-92 ("Schubert Trust"), which is also the real-party-in-interest.
Appellant's interest in pursuing the appeal of the historic designation is to protect the Schubert Trust's property rights, financial interests, and avoid regulatory encumbrances on the property resulting from such designation.
Explain each reason why the review is being requested, including the grounds for the appeal, and provide the supporting relevant code sections:
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AIT INCOMPLETE APPEAL SHALL BE RETURI\IED TO YOU AI\ID CONSIDERED TO BE INAPPROPRIATELY FILED. TTIE APPEAL PERIOD EXPIRES IO DAYS AFTER TI{E DETERMINATION AND CANNOT BE EXIEITDED TO ACCOMMODATE ADEQUATE COMPLETION OF TIIE APPEAL FILING.
ONLY MATERIALS SUBMITTED BY THE DEADLINE WILL BE CONSIDERED AT THE HEARING Sept. 2015 Page 2of 2
Attachment 7
CITY OF CORONADO
APPEAL HEARING FORM STATEMENT
514 I't STREET CORONADO cA92l18
Explain each reason why the review is being requested, including the grounds for the appeal, and provide the supporting relevant code sections
l. The Historic Resource Commission (HRC) erred in designating the Property under Historic Resource Designation Criterion C (Architecture), as a property which possesses distinctive characteristics of "the Spanish Colonial Revival style with influences of the Hacienda architectural st5/1e," without proper or substantial historic evidence, documentation, analysis, and/or evaluation, in violation of Coronado Municipal Code $84.10.030(C), and the Coronado Historic Designation Criteria Guidelines;
2. The HRC erred in designating the Property under Historic Resource Designation Criterion C (Architecture) pursuant to Coronado Municipal Code $84.10.030(C), and the Coronado Historic Designation Criteria Guidelines, as "substantial" alterations to the Properfy over the years, as detailed and demonstrated at the hearing, preclude designation under this Criterion;
3. The HRC erred in designating the Property under Historic Resource Designation Criterion D Q.Jotable Work Of A Professional), as an important or remarkable example of the notable work of builder (not designer), Paul Lawrence Hathaway, without substantial evidence, analysis, and/or evaluation in violation of Coronado Municipal Code $84.10.030(D), $84.10.020(0), and $84.10.040(8)(3), and the Coronado Historic Designation Criteria Guidelines;
4. The HRC erred in designating the Property under Historic Resource Designation Criterion D (Notable Work Of A Professional), as an important or remarkable example of the notable work of "professional" artisan, Paul Frederick Matthews, without substantial evidence, analysis, and/or evaluation in violation of Coronado Municipal Code $84.10.030(D), $84.10.020(0), and $84.10.040(BX3), and the Coronado Historic Designation Criteria Guidelines;
5. The HRC erred in designating the Property under Historic Resource Designation Criteria C & D, pursuant to Coronado Municipal Code $84.10.030(C) & 84.10.030(D), due to incorrect and/or inaccurate discussion, deliberation, and/or application of standards, guidelines, and/or considerations not contained within, and in violation of, the Coronado Historic Designation Criteria Guidelines. Such violations include, but are not limited to, discussion, deliberation, and/or application of the "visibility" of modifications and alterations to the Property from the public (street) right-of-woy, and whether such changes are consistent with the Secretary of the Interior's Standards.
Note that New, supplemental material and documentation in support of the Appeal, establishing the ineligibility of the Property under HRC Criteria C & D, will be provided to Council before, and/or at, the Council meetingfor this ltem.
Attachment 7