Updated Draft Historic Preservation Ordinance

Ken abreu May 2 2026 at 9:36AM on page 7

Suggestion

The 60% is too low a number. it should be 100%, unless an owner can self select to be a non contributor and not be subject to the constraints of a historic district. The reason for this is that a family‘s home is too important an asset to allow neighbors to constrain it. A family home reflects the family identity and is the major source of generational wealth. It reflects culture and is the safely net for extended family and future generations. A house may need to be modified or added onto support an important family member or need for care. Or to help build stronger family relations. These vital needs should not be constrained by 60% of the neighbors. Also, this will lead to pitting neighbors against each other. This is damaging to our community.

Jeremy Levine Apr 14 2026 at 9:24PM on page 7

Very good affirmative consent standard, thank you!

Jeremy Levine Apr 14 2026 at 9:23PM on page 7

To save the city time and expense, HLC recommends that the ordinance clarify the mailer shall be paid for by the applicant(s) seeking to create a historic district.

Frank Elliott Apr 14 2026 at 10:49AM on page 2

This opening paragraph does not distinguish between local resources and resources in general. The ordinance is billed as applying to "local only", that should be made explicit in the preamble. Future generations may not be clear about this, and may assume a broader interpretation of the ordinance provisions.

Please consider adding language to that effect.

Frank Elliott Apr 14 2026 at 9:38AM on page 4

Again, need precision here... are we talking about just the local inventory, or in general.

Frank Elliott Apr 14 2026 at 9:37AM on page 4

This definition includes districts outside the local inventory, which is why it needs to be clarified elsewhere when referring to districts, this ordinance only applies to those districts in the local inventory.

Frank Elliott Apr 14 2026 at 9:36AM on page 4

This definition includes resources outside the local inventory, which is why it needs to be clarified elsewhere when referring to resources, this ordinance only applies to those resources in the local inventory.

Frank Elliott Apr 14 2026 at 9:34AM on page 2

This needs to be clear that it refers to resource listed in the inventory. That is spelled out in (4) below, but not here. It needs to be consistent, (since they are both under (a), that would seem to be the intention.

By adding the words in 4 and not here, one could conclude a different meaning.

Frank Elliott Apr 14 2026 at 9:28AM on page 8

Add the words "listed in the inventory" same as (a) above, to be consistent, otherwise not clear if this is expanding the provisions beyond the local inventory.

Frank Elliott Apr 14 2026 at 9:24AM on page 6

If not deemed complete within 60 days, then denied (do not want these things to drag out forever)

Frank Elliott Apr 14 2026 at 9:21AM on page 4

Any designation or resolution should require advanced notice to all effected property owners, first-class mail, with 60 days notice.

Frank Elliott Apr 14 2026 at 9:20AM on page 4

This is defined in more detail in the National Register Bulletin, not clear why the definition is useful here.

Frank Elliott Apr 14 2026 at 9:19AM on page 4

Should be: "resources that are unified historically, culturally, or architecturally... significant." It's correct in the next definition

Frank Elliott Apr 14 2026 at 9:17AM on page 3

It should be clear that this is for the purpose of this ordinance. Demolition means something else for the purposes of permitting.

Jean Garcia Apr 10 2026 at 11:59AM on page 4

Suggestion

Coucil should not be able to create a historic district without 60% owner consent.

Laurie Apr 9 2026 at 4:05PM on page 6

Suggestion

Please provide appeal procedures.

Laurie Apr 9 2026 at 4:04PM on page 7

Suggestion

Please provide appeal provisions, as suggested in state guidance.

Laurie Apr 9 2026 at 4:03PM on page 7

Suggestion

Please include appeal provisions

Laurie Apr 9 2026 at 4:00PM on page 10

Suggestion

Please provide meaningful, monetary penalties.

Laurie Apr 9 2026 at 3:25PM on page 9

Suggestion

Please describe enforcement actions and procedures. Provide more specificity in time to correct. The Zoning Administrator is given too much latitude to grant undefined extensions.

Laurie Apr 9 2026 at 3:15PM on page 5

Suggestion

Owner consent for designating landmarks is inconsistent with national and state guidance and tends to weaken historic preservation efforts. Most cities on the SF Peninsula (including San Francisco and Palo Alto) do not require owner consent.

Laurie Apr 9 2026 at 3:07PM on page 4

Suggestion

Please provide a list of properties that are included in the Inventory

Laurie Apr 9 2026 at 1:30PM on page 5

Add a timeframe for HRC review--suggest 14 days.

Laurie Apr 9 2026 at 1:30PM on page 5

Suggestion

Add a timeframe for application review--suggest 14 days.

Laurie Apr 9 2026 at 1:26PM on page 5

Suggestion

The qualified architectural historians should make the determination as to which properties are non-contributing.

Laurie Apr 9 2026 at 1:24PM on page 5

Suggestion

The 25% noncontributor threshold is arbitrary, inconsistent with guidance. Districts should be judged based on their merit.

Laurie Apr 9 2026 at 1:22PM on page 5

Suggestion

The determination should be made by qualified historians, rather than the City Council. The Council could confirm findings.

Laurie Apr 9 2026 at 1:20PM on page 4

Suggestion

The Historic Resources Inventory must include all known historic resources identified in the 1989 Historic Building Survey and through subsequent Historic Resource Evaluations.

Laurie Apr 9 2026 at 1:17PM on page 2

Suggestion

The ordinance gives lip service to historic preservation. The Historic Resource Inventory only include the downtown and two properties. The ordinance procedures only apply to properties in the inventory. The 200+ historic properties identified in the 1989 Historic Building Survey will not be subject to any process, according to this ordinance.
Please expand the inventory and include procedures to make this a workable tool.

Steve Apr 7 2026 at 1:41PM on page 7

Suggestion

I am concerned that a house, though historically insignificant, that happens to fall into a Historic District will be subject to lengthy, expensive reviews and impede any improvements of a property with either remodeling or additions.

Frank Apr 6 2026 at 2:58PM on page 7

Suggestion

This language is not included in the landmark procedures, and might appropriately be added there, although it is already included in the preamble to this section.

As with landmarks, a bit more specificity might help here, like a reference to the OHP forms for district nominations (as a guide).

Frank Apr 6 2026 at 2:53PM on page 5

Suggestion

A little more information about what is expected in a nomination seems appropriate. Perhaps a reference to the OHP standards.

Frank Apr 6 2026 at 2:49PM on page 9

Suggestion

This seems problematic, particularly for district resources, where an owner may not have consented. And in particular for a non-contributor.

Suggest that districts are excluded from this provision.

There is probably a better way to phrase this, and unless the City plans to subsidize such repairs, this seems like an unfair burden. That is what the Mills Act is for.

Frank Apr 6 2026 at 2:46PM on page 9

Suggestion

This section can be removed. Council already has these authorities, and unless council is committing to making these incentives available, including these incentives in the ordinance is misleading.

The City should consider making some incentives available, to entice owners of particularly important resources to consider designation, to the extent they otherwise would not agree.

Frank Apr 6 2026 at 2:43PM on page 9

Suggestion

Add a provision here to avoid other non-economic problems. A $10,000 door replacement should not be required, when a $1,000 will suffice. How you codify that , I don't know.

Frank Apr 6 2026 at 2:41PM on page 7

Suggestion

Add a time limit for this process. It is 60 days for the OHP to gather objections. That is near impossible to gain support for anything in a large district. Good or bad, depending on one's point of view.

Frank Apr 6 2026 at 2:39PM on page 6

Suggestion

Add a time limit for applications to be processed, once the preliminary application is complete, or at appropriate intervals. I believe this would be most appropriate at the time the nominators are attempting to gain 60% consent.

Frank Apr 6 2026 at 2:36PM on page 7

Suggestion

Add language that if consent is not achieved, the nomination and its materials cannot be used in any finding of "eligibility" for projects within the district, for CEQA purposes. This would be an argument to retain the definition of eligibility in the definitions.

Frank Apr 6 2026 at 2:33PM on page 6

Suggestion

Add timeline limit for processing a nomination.

Frank Apr 6 2026 at 2:33PM on page 5

Suggestion

Suggest making this 60% for consistency. If not, flag this as a discussion item for council, so they are intentionally setting a different bar for districts versus landmarks. Getting to 100% should be much easier for landmarks (assuming districts are not part of this path).

Frank Apr 6 2026 at 9:37AM on page 5

Suggestion

Resources in the definitions includes districts. Assuming a second path is not intended, clarify that the landmark path does not apply to districts.

Frank Apr 6 2026 at 9:33AM on page 5

Suggestion

Per my separate email, this is missing the "two step process" that is part of the federal criteria. First something must be significant, and then fit one of the criteria. See bulletin 15.

Here is suggested language. The City Council shall first determine that the resource has significant historical, architectural, or cultural value to the community, and shall find that the historic resource satisfies one or more of the criteria outlined below, and retains its historic integrity.”

Frank Apr 6 2026 at 8:35AM on page 4

Suggestion

Under Federal definitions, a property includes districts. Clarify whether property includes districts in this instance.

Explain why this is needed. Doesn't Council already have the right to designate by resolution.

The ordinance should clearly state here or elsewhere, that Council may not designate a residential district (or anything else) without consent of the property owners. Or that they may. Either way, the council should be deliberate on this point, and not leave their power undefined.

Note, even if the ordinance blocks the council from designating without consent, that can be later changed by resolution. However, it will create a bit more friction. I think council should be clear on what they hope to achieve.

Frank Apr 6 2026 at 8:29AM on page 3

Suggestion

This definition does not apply to anything else in the ordinance. Suggest removing, as later users of the ordinance may construe it means something with respect to other portions of the ordinance.

Frank Apr 6 2026 at 8:27AM on page 4

Suggestion

Note, resource, district, and property are used inconsistently throughout the document. Suggest defining all the components of historic resource, so the rest of the document is clear).

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Updated Draft Historic Preservation Ordinance

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