Sierra Club Saves Parking Garage

I presented to the Sierra Club this month to request that they join Affordable Divis in asking for CEQA analysis for 650 Divisadero, which received Categorical Exemption from CEQA.

​Above: Original proposal for 650 Divisadero preserving the garage for adaptive reuse

First of all, it’s not a parking garage

650 Divisadero is not a parking garage. The building was a mechanic’s garage shop built in the 1920s, after the Great Fire and before the Great Depression, when the automobile was becoming popular and horses and carriages grew out of favor, in reconstruction-era San Francisco. It’s not currently used for parking. A seismic retrofitting business occupies the garage, and previously it was Alouis Radiator.

This is a question of due process

The original project that the developer filed in 2014 would have been rightfully exempt from CEQA, as that proposal preserved the garage facade for adaptive reuse. However, when Divisadero was upzoned in 2015, the plans changed to demolish the building. The Planning Department determined that this did not constitute a substantial change and issued a Categorical Exemption from CEQA in January 2017.

What’s the big deal with demolishing this garage?

In the Categorical Exemption document the Planning Department admits that hazardous materials exist on the site, and that the proposed demolition would not “substantially” alter existing groundwater quality. I brought this to the Sierra Club’s attention since the SFPUC is proposing to add groundwater into our drinking supply in San Francisco. Hazardous materials and water quality are issues that can be examined in an Environmental Impact Report.

Planning determined 650 Divisadero qualifies as a historical resource

It is the Planning Department’s initial determination that 650 Divisadero qualifies as a historical resource, which requires CEQA analysis.

Per the Categorical Exemption:

“A categorical exemption shall not be used for a project that may cause a substantial adverse change in the significance of a historical resource.”

Then later:

“the building appears to be a significant individual resource….”

A building can be considered a historical resource if it meets one of four criteria: If the property is associated with a historically significant event (Criterion 1), person (Criterion 2), or architectural style (Criterion 3), or if there is potential to gather historically significant information from the site (Criterion 4).

The Planning Department affirms that this project meets Criterion 3:

“While the building was not surveyed in the Van Ness Auto Row Survey, based on the historical use and age of the building it is a moderately early example of the second most important group of auto-related facilities established by the study. In addition, the building was referenced in two prior publications, The Architect & Engineer and The Early Public Garages of San Francisco. Thus, the building appears to be a significant individual resource under Criterion 3.”

So how does the Planning Department reconcile the fact that 650 Divisadero is a historical resource and that there are no categorical exemptions for historical resources?

To be a resource for purposes of CEQA, a property must not only be shown to be significant under the CRHR criteria, but must also have integrity. Due to alterations to the building’s original features, including the vehicle entrance, windows, and circulation pattern, the historic resource determination concludes that the building lacks sufficient historical integrity. As the building does not retain historical integrity, it does not warrant a discussion of character defining features.

The Early Public Garages of San Francisco, which shows historical and current photographs of garages side by side, argues:

“Wherever possible, archival and contemporary photographs of particular garages are juxtaposed. The aim is to illustrate the impact of neglect and to reveal the integrity that often lies just beneath the surface of the façade.”

Even more exemption requests for 650 Divisadero

Despite the 2015 upzoning, 650 Divisadero does not meet zoning laws, so the project requires a conditional use authorization for exceeding square footage and bulk, and a variance for not meeting rear yard setback requirements. Instead of following the guidelines in place, this project is getting a CEQA exemption, and recommendation by Planning to approve the project, to authorize the conditional use, and to give it the rear yard variance.

If a project deserves CEQA analysis, then it should get it. CEQA analysis gives the Planning Commission the facts to make the best decision on a project. It doesn’t require anyone to save a parking garage. CEQA analysis examines the evidence and provides options and alternatives, but the actual decision of what gets built in San Francisco is always up to the Planning Commission.

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