1 From: Martin McTaggart
Sent: Monday, September 14, 2026 1:03 PM
To: Chantal Eaton
Subject: FW: Four Ways the Zoning Ordinance Fails San Mateos Historic Districts, Resources, and Landmarks. (File ID 26-11552 )
Hi Chantal,
Kindly append this as public comment to the ordinance adoption item on 9/22.
Thank you,
Martin
From: Doug D'Anna < >
Sent: Monday, September 14, 2026 12:51 PM
To: Clerk <[email protected]>; City Council (San Mateo) <[email protected]>; Zachary Dahl <[email protected]>
Cc: ; Laurie Hietter >; Ashley Zerpa < >;
Ruthmary Cradler >
Subject: Four Ways the Zoning Ordinance Fails San Mateos Historic Districts, Resources, and Landmarks. (File ID 26- 11552 )
September 2026
Mayor and Members of the City Council
City of San Mateo
330 W. 20th Avenue, San Mateo, CA 94403
2 Re: File ID 26-11552 — Agenda Item 18 — High-Density Mixed-Use and Multi-Family Zoning Districts Dear Mayor and Councilmembers,
I am submitting this letter to document four distinct ways the proposed ordinance fails to extend historic- adjacency protection to San Mateo's historic districts and resources — each traced to the City's own adopted standards and certified environmental record.
Executive Summary
The City's proposed zoning ordinance (File ID 26-11552) creates four new high-density districts — R6, R7, MU3, MU4 — but does not extend historic-adjacency protection to them.
The standard isn't new. Every parcel adjacent to an R1 or R2 zone already gets a mandatory buffer. No parallel buffer specificially exists for adjacency to a historic district. landmark or resource.
The ordinance exempts itself from CEQA, up front, by claiming consistency with the General Plan 1 — yet the General Plan itself calls for exactly the standard this ordinance omits (Action CD 5.12 2).
The City's own certified Final EIR named that same action, by name, as the fix for a formal Heritage Alliance objection3 — and never delivered it.
Without this amendment, any protection San Mateo's historic districts have is an accident of unrelated zoning, not a recognition of their historic status — protection this same ordinance could erase the moment a parcel inside or directly adjacent to them is upzoned.
The ask: pause adoption; insert one subsection into four existing sections extending the R1/R2 buffer to historic districts and resources.
Failure 1 — The Missing Buffer
R7 alone permits 8 stories / 100 feet, with just a 5-foot rear setback 4.
Chapter 27.66 already requires review — a planning application or Certificate of Appropriateness — whenever a historic building is altered5. It has never governed what's built beside a historic resource.
The new ordinance's buffer trigger: 10-ft side / 15-ft rear buffer, only if adjacent to an R1 or R2 zone 6. No equivalent trigger exists for historic adjacency, anywhere in Chapters 27.50–27.53. "If a side property line is adjacent to a R1 or R2 district, a buffer of ten (10) feet must be provided..." — Municipal Code § 27.50.080, identical across all four new districts Same ordinance, same city — a buffer is required next to an R1 or R2 zone; none is required next to a historic district or resource.
3 Where a historic district's underlying zoning happens to be R1, as it does for at least part of the Glazenwood Historic District and the Yoshiko Yamanouchi House Historic District, a parcel there may receive today's buffer — but only as an accident of that unrelated zoning, not because the ordinance recognizes historic status.
The Downtown Historic District, which is not zoned R1, receives no buffer of any kind. And even where the buffer applies today, nothing in the ordinance ties it to historic status — it would disappear the moment that parcel were rezoned under one of the very districts this ordinance creates.
The gap has only widened since. The City's own 2023 Multi-Family and Residential Mixed-Use Objective Design Standards — still in effect today, and entirely independent of this ordinance — go further still. Section 4.4.1, Neighborhood Transitions, requires mandatory stepbacks for any qualifying project within 10 to 20 feet of an abutting R1 zoning district: a five-foot third-story stepback for low-rise buildings, ten- to twenty-foot stepbacks above the second story for mid-rise and high-rise buildings, plus mandatory evergreen screening along the property line7. Every one of these triggers is keyed to R1 zoning. None of them is keyed to a historic district, landmark, contributor, or historic resource — those words do not appear anywhere in the standard.
CEQA requires evaluating a project's impact on a historic resource's surroundings, not just the resource itself 8.
This standard and the buffer above are now two separate City rules, both keyed to R1 adjacency, both silent on historic adjacency. And as Failure 3 shows, the City drew this same line thirty years earlier, in 1993 — recognizing that adjacency to a historic resource creates a design impact worth regulating, and then never carrying that recognition forward.
Failure 2 — The CEQA Self-Exemption
CEQA recognizes harm to a historic resource's surroundings, not just the resource itself, as potentially significant8.
Section 18 declares the ordinance "statutorily exempt" from further CEQA review, on the basis of General Plan consistency9. No historic-adjacency study accompanies it.
The consistency claim doesn't hold: the General Plan's Action CD 5.12 calls for exactly the standard the ordinance skips10.
This isn't inference — it's the City's own record. Heritage Alliance formally objected (Sept. 2023) that the Draft EIR's historic-resources analysis was inadequate11.
"Action CD 5.12 Historic Resources Design Standards. Create objective design standards for alterations to historic resources and contributors to a designated historic district, and new development adjacent to historic resources within historic districts."— Strive San Mateo General Plan 2040, p. 116, Chapter 5: Community Design and Historic Resources Element (adopted May 31, 2024)
Every new project already needs Site Plan and Architectural Review, which requires it be "in scale and harmonious with the character of the neighborhood"12. That finding is discretionary, citywide, and predates this ordinance — it never mentions historic resources by name. A subjective aesthetic finding is not the objective design standard this action requires.
Why This Gap Exists
4 Two City systems — historic review and zoning — were never measured against each other. Historic review governs the building. Zoning governs what's built beside it. Neither covers the seam between them.
Any parcel near a historic district can be reclassified into a new high-density district with zero historic- adjacency review.
Failure 3 — The Zoning Code Ignores Its Own Historic-
Preservation Framework
The Zoning Code cites the General Plan for CEQA consistency — but nothing historic in any of these four documents is cross-referenced in it:
1. Historic Context Statement (2026) — Defines what's historic and why.13
2. Preservation Ordinance (Ch. 27.66) — Sets the legal test: any alteration to a Landmark or Contributor must comply with the Secretary of the Interior's Standards for Rehabilitation, incorporated by reference — including Standard 9, which requires new construction to be compatible in scale and massing. 14
3. Downtown Retail Core & Downtown Historic District Design Guidelines (1993) — Translates the test into a design standard — but scoped by section number to the old chapters, not the new districts. 15
4. General Plan (Action CD 5.12, 2024) — Calls for design standards for development adjacent to historic resources — already adopted, never implemented.
5. Zoning Code (Ch. 27.50–53) — The only one that grants permission to build — and the only one none of the other four are cross-referenced in.
Two of these are binding law the ordinance is supposed to be consistent with — the Preservation Ordinance and Action CD 5.12. Neither is cited. The other two are the City's own guidance, one of them three decades old, both admitting the same problem this ordinance ignores.
The City has used item 3 before — and never carried it into the new districts. The 1993 Downtown Retail Core & Downtown Historic District Design Guidelines devote an entire section (Guidelines CC–FF) to non-historic buildings within the Downtown Historic District, stating they apply "to ensure that new development is compatible with existing historic buildings."15
The guidelines direct new construction to align cornices with neighboring historic buildings (CC), incorporate common facade components (DD), echo the architectural rhythm of nearby historic structures (EE), and match materials common to historic buildings (FF). That the City felt compelled to write these guidelines in 1993 is itself an admission that adjacency to a historic resource creates a design impact worth regulating — the exact impact this ordinance now ignores for the four new districts.
But those guidelines only reach buildings sited within the mapped Downtown Historic District boundary — they say nothing about a parcel just outside that boundary, looking in. And even within the boundary, they are discretionary: the City's own guidelines state that "the approving body may approve projects not in compliance with the guidelines" when it determines other solutions may be preferable 15 — not an objective, code-enforceable standard like the one the City already requires for R1 adjacency today. 5 The City may argue that zoning code doesn't typically cite outside guidance. But this ordinance already does exactly that when it chooses to — deferring to "the Downtown Plan" for retail frontage requirements 16, and to "an adopted plan, such as the Mariner's Island Specific Plan or the Bay Meadows Specific Plan" for other exclusions17. The zoning code is comfortable citing outside plans. It has simply never chosen to for anything historic — which is exactly what makes Section 18's claim of General Plan consistency, addressed in Failure 2, difficult to sustain.
Thirty years after 1993, the City wrote a second design standard for R1 adjacency — see Failure 1. It still didn't carry the lesson forward. Two chances, three decades apart, both taken for an ordinary neighbor and both missed for a historic one.
In the Ordinance's Own Words: The Zoning Code Totally Ignores Historic Preservation
This is not paraphrase. The following is the primary text of the proposed ordinance itself (Attachment 1). "...the proposed Ordinance is consistent with the adopted General Plan in that it supports the development of housing and achieves the General Plan's stated goals and policies."— Section 1, Legislative Findings. No policy is named. Action CD 5.12 is never cited — anywhere in this ordinance. "Historic" appears exactly once across all 21 sections of this ordinance — an existing cross-reference to Chapter 27.66, confined to the Downtown Specific Plan area (Section 4). Nothing new. Nothing about the four new districts.
"If a side property line is adjacent to a R1 or R2 district, a buffer of ten (10) feet must be provided." — §§
27.50.080(a), 27.51.080(a), 27.52.090(a), 27.53.090(a) — identical, word for word, in all four new chapters Historic district. Landmark. Contributor. Resource. None of these words appear.
Failure 4 — The General Plan Called for This Design Standard in 2024
But you won't find it in the new zoning update.
2024 — The General Plan called for these design standards (Action CD 5.12). Never created. 2024 — The City's own certified EIR response promised it, by name, to answer a formal objection. Never delivered.
2026 — Still missing in this zoning ordinance, same as it was in 2024.
The Fix & The Ask
The fix has two parts — one already promised, one an interim step:
6 Step One (the real fix): Direct staff to implement Action CD 5.12 — the historic design review standard the City already adopted in the General Plan, and already named in its own certified Final EIR as the mitigation for this exact concern.
Step Two (interim stopgap): Add one sentence to four existing sections, extending the R1/R2 buffer to historic districts and resources, tonight, while Step One is built out. "(c) If a side or rear property line is adjacent to a Historic District, Landmark, Contributor, or Historic Resource... the buffer required by subsections (a) and (b) for adjacency to an R1 or R2 district shall apply in the same manner."— Proposed new subsection (c) — the interim step, one sentence, inserted into four existing sections Without this amendment, any protection San Mateo's historic districts have is an accident of unrelated zoning, not a recognition of their historic status — protection this same ordinance could erase the moment a parcel inside or directly adjacent to them is upzoned.
This letter asks Council to:
1. Direct staff to implement the historic design review standard called for in Action CD 5.12, and extend the existing R1/R2 adjacency buffer to historic districts and resources, per Steps One and Two above; and
2. Direct staff to map which parcels near San Mateo's historic districts could be rezoned under the new districts, before final adoption.
Respectfully submitted,
Doug D’Anna
Laurie Hietter, San Mateo Heritage Alliance
Ashley Zerpa
Ruthmary Cradler
John Cradler
Laura Watanuki
Notes
1. Proposed Ordinance Amending Title 27 (File ID 26-11552), Section 18, citing Public Resources Code § 21080.17 and CEQA Guidelines § 15183.
2. Strive San Mateo General Plan 2040, Action CD 5.12, p. 116 (adopted March 18, 2024).
3. Strive San Mateo General Plan 2040 Final EIR, Response to Comments, Response ORG1-7, p. 5-14 (January 18, 2024).
4. San Mateo Municipal Code § 27.51.060; § 27.51.070.
5. San Mateo Municipal Code §§ 27.66.090(a)-(b), Review Required, and 27.66.100, Certificate of Appropriateness, Historic Preservation (adopted May 18, 2026).
7 6. San Mateo Municipal Code §§ 27.50.080(a)-(b), 27.51.080(a)-(b), 27.52.090(a)-(b), 27.53.090(a)-(b).
7. City of San Mateo, Multi-Family and Residential Mixed-Use Objective Design Standards, § 4.4.1, Neighborhood Transitions, pp. 33–34 (adopted December 4, 2023, effective January 3, 2024).
8. Public Resources Code § 21084.1; CEQA Guidelines § 15064.5(b).
9. Proposed Ordinance Amending Title 27 (File ID 26-11552), Section 18.
10. Strive San Mateo General Plan 2040, Action CD 5.12, p. 116 (adopted March 18, 2024).
11. San Mateo Heritage Alliance, comment letter on the Draft EIR, September 25, 2023 (Comment ORG1-3).
12. San Mateo Municipal Code § 27.08.030, Site Plan and Architectural Review, as amended by Section 4 of the proposed ordinance (File ID 26-11552).
13. City of San Mateo, Notice of Exemption, City of San Mateo Citywide Historic Context Statement, San Mateo County Document No. 129498 (filed May 6, 2026), citing Strive San Mateo General Plan 2040 Policy CD 5.1 and Action CD 5.9.
14. U.S. National Park Service, The Secretary of the Interior's Standards for Rehabilitation, Standard 9, incorporated by reference in San Mateo Municipal Code § 27.66.100(b)(1) (adopted May 18, 2026).
15. City of San Mateo, Downtown Retail Core & Downtown Historic District Design Guidelines (1993).
16. San Mateo Municipal Code § 27.38.020(a), Permitted Uses, as amended by Section 9 of the proposed ordinance (File ID 26- 11552).
17. San Mateo Municipal Code § 27.04.200(b)(2)(G), Floor Area, as amended by Section 3 of the proposed ordinance (File ID 26- 11552).
1 From: Doug D'Anna < >
Sent: Thursday, September 17, 2026 2:40 PM
To: City Council (San Mateo); Clerk
Subject: Re: File ID 26-11552 — Zoning Code Amendments Creating R6, R7, MU3, and MU4 Districts September 22, 2026 City Council Meeting
Attachments: Four_Reasons .pptx
Follow Up Flag: Follow up
Flag Status: Flagged
Categories: Public Comment Added to SharePoint
Dear City Clerk and Members of the Council,
I am submitting the attached PowerPoint for a group presentation, "Four Reasons This Ordinance Fails Historic San Mateo," for the record in connection with the above-referenced item on your September 22, 2026 agenda. I respectfully request that it be entered into the public record and distributed to Council members in advance of the meeting.
The PowerPoint sets out four specific, document-based concerns with the proposed ordinance as it relates to San Mateo's historic districts and resources:
The ordinance's buffer requirements apply to R1 and R2 neighbors but not to historic districts or individually designated historic resources. No design-compatibility review applies to new construction next to a historic building or contributor outside the Downtown Retail Core.
The ordinance does not reference any of the City's own governing historic-preservation documents.
The ordinance's CEQA exemption relies in part on a Public Resources Code section that, by its own text, applies only to accessory dwelling unit ordinances.
The PowerPoint also notes that the City's own staff report for this item describes several of the ordinance's standards as "interim," pending the Comprehensive Zoning Code Update — while historic-district compatibility is not addressed anywhere in that report.
I ask that Council direct staff to implement Action CD 5.12 of the General Plan — the design standard the City has already adopted — and to reference historic districts, landmarks, and resources directly in this ordinance's language before final adoption.
Thank you for your time and consideration.
Respectfully,
2 Doug D'Anna
FILE ID 26- 11552 · SEPTEMBER 2026
Four Reasons This Ordinance
Fails Historic San Mateo
The new high-density zoning code doesn’t just overlook our historic districts — it doesn’t know they exist.
Doug D’Anna · San Mateo, CA — Glazenwood Historic District REASON 1
1 No Buffer
R1 and R2 neighborhoods get a mandatory buffer next to new high-density construction. San Mateo’s three historic districts — Downtown, Glazenwood, and Yoshiko Yamanouchi House — and its individually designated historic resources get nothing.
Any protection Glazenwood receives is just an accident of also being zoned R1 — not because it’s historic.
Municipal Code §§ 27.50.080(a)-(b), 27.51.080(a)-(b), 27.52.090(a)-(b), 27.53.090(a)-(b) 2 Same Rule, Drawn to Scale
Same ordinance, same city — buffer required next to R1/R2, none required next to a historic district or resource, across all four new districts (R6, R7, MU3, MU4).
ADJACENT TO R1 / R2 ZONE
New High-Density
Development
10-ft
buffer
R1/R2
Home
Mandatory buffer applies.
ADJACENT TO HISTORIC DISTRICT
New High-Density
Development
0 ft
Landmark /
Contributor
No buffer required.
Illustrative, not to scale · Municipal Code §§ 27.50.080(a), 27.51.080(a), 27.52.090(a), 27.53.090(a) — identical across all four new districts 3 REASON 2
2 No Design Review
Even where a buffer exists by accident, nothing requires new construction next to a historic building or contributor outside the Downtown Retail Core to look compatible — no review of height, scale, or materials. The General Plan calls for exactly this kind of standard, city-wide.
A buffer is just distance. It doesn’t stop a glass tower from standing right next to a historic structure.
Secretary of the Interior’s Standards for Rehabilitation, Standard 9 · 1993 Downtown Design Guidelines · General Plan Action CD 5.12 4 REASON 3
3 No Reference
The zoning code mentions historic buildings once — never for what’s built beside them:
5 ● The Historic Preservation Ordinance
● The 1993 Design Guidelines
● The 2026 Historic Context Statement
● The General Plan’s own Action CD 5.12
Four documents that define what’s historic and why. The zoning code acts like none of them exist.
Action CD 5.12, Historic Resources Design Standards:
“Create objective design standards for alterations to historic resources and contributors to a designated historic district, and new development adjacent to historic resources within historic districts. Use the Secretary of the Interior’s Standards as the basis for these objective design standards to ensure projects have a contextual relationship with land uses and patterns; spatial organization; visual relationships; cultural and historic values; and the height, massing, design, and materials of historic resources.”
— Strive San Mateo General Plan 2040, Action CD 5.12
REASON 4
4 No Environmental Review
Bypasses CEQA review using the wrong exemption
The ordinance cites Public Resources Code § 21080.17 — without explanation — to bypass further CEQA review. That section, by its own text, only exempts ordinances implementing state ADU law. This ordinance creates four new high-density zoning districts. It implements nothing about ADUs.
It also claims consistency with the General Plan — a separate exemption, cited alongside the first.
But the General Plan calls for design standards covering height, massing, and materials for new construction next to historic resources — exactly the protection this ordinance skips.
You can’t bypass CEQA with a citation that doesn’t apply, then claim consistency with a plan you’re not following
Ordinance Section 18 · Public Resources Code § 21080.17 · CEQA Guidelines § 15183 · General Plan Action CD 5.12 6
THE PROMISE
The General Plan Already
Called For This
Action CD 5.12, adopted in 2024, directs the City to:
“Create objective design standards for alterations to historic resources and contributors to a designated historic district, and new development adjacent to historic resources within historic districts. Use the Secretary of the Interior’s Standards as the basis for these objective design standards to ensure projects have a contextual relationship with land uses and patterns; spatial organization; visual relationships; cultural and historic values; and the height, massing, design, and materials of historic resources.”
— Strive San Mateo General Plan 2040, Action CD 5.12
The zoning code ignores it.
File ID 26-11552 · Doug D’Anna · San Mateo, CA — Glazenwood Historic District 7
THE URGENCY
Interim, But Not Harmless
The City’s own staff report calls this ordinance’s standards “interim” — height limits and FAR are explicitly flagged for revision once the Comprehensive Zoning Code Update (CZCU) is adopted. Staff’s own estimate: mid-2027.
Historic districts were never flagged the same way. The word “historic” does not appear once in the entire 8-page staff report.
Any project approved before the CZCU arrives gets built. “Interim” doesn’t undo a building.
Agenda Report, File ID 26-11552 · Staff estimate: CZCU completion mid-2027 8
THE ASK
This Is a City That Takes
Its History Seriously…
That is why it placed preservation in these four documents:
● The Historic Preservation Ordinance
● The 1993 Design Guidelines
● The 2026 Historic Context Statement
● The General Plan — Action CD 5.12, adopted 2024
The zoning code ignores all four.
THE ASK:
1. Direct staff to implement Action CD 5.12 — the design standard the City already adopted.
2. Reference historic districts, landmarks, and resources directly in this zoning ordinance's language before final adoption.
File ID 26-11552 · Doug D’Anna · San Mateo, CA — Glazenwood Historic District 9