CITY COUNCIL STAFF REPORT
December 3, 2024 {{section.number}}{{item.number}}
PUBLIC HEARING: PROVIDE DIRECTION REGARDING AMENDMENTS TO THE
CORONADO HISTORIC PRESERVATION PROGRAM, CONSIDER CERTIFICATION OF A
PROGRAM ENVIRONMENTAL IMPACT REPORT (PEIR) AND ADOPTION OF ASSOCIATED
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) FINDINGS
RECOMMENDATION:
Provide direction regarding Amendments to the Coronado Historic Preservation Program, certify the Program Environmental Impact Report (PEIR), and adopt the associated California Environmental Quality Act (CEQA) findings.
BACKGROUND:
The effort to prepare a Historic Context Statement and Citywide Survey began in late 2018, resulting from recommendations by a City Council subcommittee consisting of Councilmembers Donovan and Downey. At that time, the City Council directed staff to move forward with a Context Statement and Citywide Survey that would guide the preservation of the City’s architecturally significant properties as well as provide increased certainty to property owners with regard to modifications on their property. The City Council directed staff to move forward with an architectural survey of properties built through 1970, which is in line with the California Register, National Register, and California Environmental Quality Act (CEQA) best practice of a 50-year threshold for potential historic significance. In the meantime, the City would retain the existing threshold of 75 years for required Determination of Historic Significance review and revisit the idea of changing the age threshold upon adoption of the Context and Survey document.
On November 21, 2023, the City Council reviewed the Draft Historic Context Statement and Citywide Survey and directed staff to maintain the established 75-year threshold for Determination of Historic Significance Review as the preferred project evaluated by the EIR, notify property owners in all tiers of their status, to provide an additional public comment period of sixty (60) days, and to proceed with required environmental review. Comments received from the public during this extended review period were provided to City Council on September 17, 2024.
In April of 2024, the City contracted with Project Design Consultants (PDC) and RECON to prepare the EIR and associated technical documents. The scope of analysis for this PEIR was determined by the preparation of an Initial Study which was used to identify potentially significant environmental issues. Additional consideration was given to agency and public comments received in response to the Notice of Preparation (NOP) circulated June 12, 2024, and a scoping meeting held on June 27, 2024. Through these scoping activities, the project was determined to have the potential to result in significant environmental impacts to Cultural Resources (Historical Resources) and Land Use (Conflicts with Plans and Policies). All other environmental issue areas were found to result in a “Less than Significant Impact” or “No Impact” as determined in the Initial Study, which was circulated for public review with the NOP.
Following public scoping period, a Draft Program Environmental Impact Report was prepared, and a public review period for the document ran from August 23 to October 6, 2024. A Final Program Environmental Impact Report (PEIR) has now been completed, consistent with CEQA Guidelines, the purpose of which is to provide decision makers and the public with information about the potentially significant effects of the project and possible ways to minimize significant effects, and to evaluate project alternatives. The Final PEIR also includes comments received during the public review period, and responses to those comments.
The Final PEIR, as well as the full Draft Historic Context Statement and Citywide Survey can be accessed at this link:
https://www.projectcoronado.org/citywide-historic-resource-survey ANALYSIS:
The project evaluated by the PEIR would amend the Coronado Municipal Code (CMC), Chapter
84.10, Historic Resource Code, to streamline the historic review process. A Historic Context Statement and Historic Resources Inventory was prepared which evaluated over 2,000 properties built before 1970 to identify properties the that appear to have architectural significance, and classified them into tiers:
Tier 1 - Unaltered or minimally altered from historic condition and potentially eligible for City designation under Criterion C.
Tier 2 - Recognizable as a particular architectural style but based on observation and/or construction history are more than “unaltered or minimally altered” from historic condition and do not appear to be eligible for historic designation under Criterion C.
Tier 3 - Substantially altered properties that retain little to no elements of a particular architectural style and, based on observation and/or construction history, are not eligible for historic designation under Criterion C.
With the project, Tier 3 properties that are 75 or more years old, built in 1949 or earlier would not require further historic review in the event of future renovations or demolition. The Historic Property Survey identified a total of 1,667 Tier 3 properties, with 1,007 structures built in 1949 or earlier and another 660 structures built between 1950 to1970.
Impacts Analysis
The EIR includes an evaluation of the project consistent with CEQA Guidelines (California code of Regulations Sections 15000-15387), Appendix G. Two areas were determined to have significant and unavoidable impacts as a result of the project: Historical Resources and Land Use and Planning.
Regarding Historical Resources, the Coronado Municipal Code requires that a property must meet two or more of the adopted Historic Designation Criterions. Although 90.2% of the City’s Historic Resource determinations have relied on Criterion C, it is possible that there could be resources that would qualify for a historic designation based on Criteria A, B or D which focus on significance relative to people, places, and/or events. Due to the scope of the historic survey, it was not reasonable to evaluate the significance of every structure and resource within the City against those criteria due to those criteria involving substantial site-specific research into building records and historic documents. Direct impacts to historical resources would be significant due to the potential loss of resources that may qualify as historic due to their association with people, places, or events. Indirect impacts would not be anticipated as the loss of potentially historic Tier 3 resources would not contribute architecturally to other surrounding resources or districts. No feasible mitigation has been identified and impacts to historical resources within the project area would be significant and unavoidable.
Regarding Land Use, a number of policies were identified that are relevant to historic resources including the City’s Historic Preservation Element of the General Plan, and policies in the Local Coastal Program that encourage historic preservation and adaptive reuse. The project would not conflict with most policies because the amendments to the CMC would not deter or discourage preservation of historic or architecturally significant structures. Individual residents and property owners could continue to pursue historic designation and the City would continue to encourage preservation of historic structures. However, because the proposed amendments to the CMC could result in certain potentially historic resources not being required to undergo historic review, these potentially historic resources could be lost. No feasible mitigation has been identified and impacts to land use plans and policies would be significant and unavoidable.
Project Alternatives
In developing the alternatives to be addressed in this section, consideration was given to their ability to meet the basic objectives of the project and eliminate or substantially reduce significant environmental impacts. Project objectives identified for the Preferred Project include streamlining the Coronado Historic Preservation Program review process to provide consistency to preservation planning efforts; further guide the preservation of historically significant properties; provide certainty to property owners regarding the known historical significance of structures.
Three project alternatives were evaluated: No Project, a 50 Year Threshold, and a Project plus a 50 Year Threshold.
The No Project Alternative has the potential to result in significant impacts to historical resources less than 75 years old that would not require historic review under the existing regulations.
However, under the No Project Alternative, elimination of Tier 3 properties from further historic review would not occur; therefore, significant impacts to historical resources could occur to a lesser extent than the project because all Tier 3 structures would continue to be evaluated.
Impacts related to land use plans or policies would be less than significant and less than the project; however, the No Project Alternative would not meet the project objectives.
The 50-Year Threshold Alternative would not have the potential to result in significant impacts to historical resources, as this amendment would increase the level of historic review to include structures between 50 and 75 years old. Additional properties 50 to 75 years old would be reviewed for their potential to qualify as a historic resource and would require an in-depth historical review. Impacts of this alternative would be less than significant as the changes would increase regulatory protections for potentially historic properties. However, the 50-Year Threshold Alternative would not meet the project objectives.
The Project Plus 50-Year Threshold Alternative would include amending Title 84 of the CMC to modify the current determination of historic significance review age threshold from 75 to 50 years and would adopt the Historic Property Survey which would exclude Tier 3 properties from further historic review. Like the project, impacts of this alternative would be significant due to the potential for some Tier 3 properties to be potentially historic under one or more of the other City criteria.
However, impacts would be slightly reduced compared to the project because additional properties between 50 to 75 years would be reviewed for their potential to qualify as a historic resource and would require an in-depth historical review. Therefore, the Project Plus 50-Year Threshold Alternative was identified as the Environmentally Superior Alternative as required by CEQA. Nonetheless, this alternative would still result in significant impacts to historic resources, but to a lesser extent than the project, and this alternative would not meet the project objectives.
Next Steps
If the City Council decides to amend the Historic Preservation Ordinance, staff will return with a draft Ordinance Amendment based on Council direction for a first reading in early 2025.
FISCAL IMPACT:
The City Council authorized a contract with Dudek for the completion of the Historic Context Statement and Citywide Survey in amount of $120,780 and has authorized a contract with Project Design Consultants in the amount of $122,205 for completion of the Program Environmental Impact Report. Both contracts are within budget.
ALTERNATIVE:
The City Council could decide not to certify the PEIR and provide direction to conduct additional environmental review, or provide alternate direction on the project as a whole.
CALIFORNIA ENVIRONMENTAL QUALITY ACT:
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15121, the purpose of this PEIR is to provide public agency decision-makers and members of the public with general information about the potentially significant environmental effects of the project, possible ways to minimize its significant effects, and reasonable alternatives that would reduce or avoid any identified significant effects. Alternatives to the project are presented to evaluate alternative land use scenarios, policies, and/or regulations that would further reduce or avoid significant impacts associated with the project. The PEIR has been prepared by the City as lead agency, in compliance with the criteria, standards, and procedures of the CEQA of 1970 as amended (Public Resources Code, Section 21000 et seq.), and the CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.). The City is the lead agency for the project, pursuant to Article 4 (Sections 15050 and 15051) of the CEQA Guidelines. The lead agency, as defined by CEQA Guidelines Section 15367, is the public agency that has the principal responsibility and authority for carrying out or approving a proposed project. As lead agency, the City of Coronado Community Development Department conducted a preliminary review of the project and determined that a PEIR was required. The analysis and findings in this PEIR reflect the independent, impartial conclusions of the City. This EIR has been prepared as a PEIR, as defined the CEQA Guidelines Section 15168 a PEIR is the appropriate CEQA document when the project is the issuance of rules, regulations, or plans to govern the conduct of a continuing program and future individual activities would be carried out under the same authorizing statutory or regulatory authority and have generally similar environmental effects (CEQA Guidelines Section 15168 (a)(3) and (4)).
PUBLIC NOTICE:
A public review period of the Draft Environmental Impact Report ran from August 23 to October 6, 2024. A public notice for this meeting was published in the Coronado Eagle Journal on November 20, 2023.
ATTACHMENTS:
1. PEIR for Amendments to the Coronado Historic Preservation Program, Appendices, Errata, and Findings
Submitted By: Community Development Department / Tricia Olsen