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HomeMy WebLinkAboutStaff Report 3574 City of Palo Alto (ID # 3574) City Council Staff Report Report Type: Action Items Meeting Date: 3/4/2013 City of Palo Alto Page 1 Summary Title: Edgewood Plaza Update Title: Update and Direction to Staff Regarding Development Process for Edgewood Plaza From: City Manager Lead Department: Planning and Community Environment Recommendation and Draft Motion: Draft Motion: I move that Council direct staff to: 1. Proceed with preparation of a Supplemental Environmental Impact Report (SEIR) to address Building #1 historic resources issues (at the applicant’s expense); 2. Return to Council with the SEIR and an amendment to the PC zoning (including modification to the proposed “public benefits”) following review by the Historic Resources Board and Planning and Transportation Commission. 3. Prohibit any construction of Building #1 and any development of housing (including site preparation for the housing) until the SEIR is completed and an amendment to the approved Planned Community (PC) zone is considered by the Council; 4. Allow continued development of the grocery store (Building #3) as the remainder of the project moves forward; 5. Allow the rehabilitation of Building #2 to commence subject to a City designated historic peer review and on-site monitor; 6. Allow offsite improvements to proceed, including off-site traffic improvements; and 7. Allow the installation of the historic sign and other incidental related work. Executive Summary The Edgewood Plaza Planned Community (PC) Zoning was approved on March 19, 2012 to allow the redevelopment of an existing vacant and historic shopping center, including the relocation of one of the three retail buildings, the addition of ten homes and a new 0.20 acre park. The PC Zoning required that the two historically significant retail buildings be preserved as a primary City of Palo Alto Page 2 public benefit: Building #2 was to be rehabilitated in place, while Building #1 was proposed to be disassembled, relocated on site and rehabilitated. Work also began on the grocery store building, another key public benefit of the zoning. Subsequent to the issuance of a permit to disassemble Building #1 and contrary to the requirements of the PC Zoning and what was shown in the building permit plans, however, the applicant demolished the building without notifying or receiving approval from the City. The Planning Director issued a stop work order on September 9, 2012, following complaints of the unauthorized demolition. Following the issuance of the stop work order, the applicant, Sand Hill Property Company, initiated discussions with the City regarding next steps. The applicant was allowed to continue construction on the grocery store in Building #3, the one non-historic building, and any work related to the operation of the grocery store. Since the project no longer preserves one of the two historic buildings, however, a Supplemental Environmental Impact Report (SEIR) must be prepared before Building #1 can be rebuilt, and amendment to the PC zoning may be required to define adequate “public benefits,” a process that is likely to take 4 to 6 months. Staff recommends that, in the interim, on-site work be limited to construction of the grocery store (Building #3), rehabilitation of Building #2 (with additional limitations and historic resource inspections), and installation of the historic monument sign. Staff recommends that no work on Building #1 and the housing component of the project move forward until completion of the SEIR and consideration of an amendment to the Planned Community zoning, including potential additional public benefits. Background This item was continued from the Council’s January 22, 2013 calendar. Responses to questions submitted by Councilmember Holman are included as Attachment E to the staff report. Edgewood Plaza is a commercial shopping center built between 1956 and 1958 by Joseph Eichler/Eichler Homes and A. Quincy Jones of Jones and Emmons. The property is bounded to the south by Channing Avenue, by West Bayshore Road to the east, Saint Francis Drive to the west and an office building and gas station to the south. Embarcadero Road is located south of the site. The center was originally built with the existing grocery building (1957), two retail buildings (1958), an office building that formerly housed the office of Eichler Homes (1959), and a gas station (1957). The office building (Maharishi School of Vedic Science of California/1101 Embarcadero Road) and gas station (A.U. Energy LLC/1161 Embarcadero Road) sites are owned by different property owners and are not part of this project. The 3.58-acre commercial site is located at adjacent to the Duveneck/Saint Francis neighborhood, which is part of the Green Gables subdivision. Planned Community Zoning and Environmental Review City of Palo Alto Page 3 The Edgewood Plaza Planned Community Zoning (Attachment A) was approved on March 19, 2012 to allow the redevelopment of an existing vacant and historic shopping center, including the relocation of one of the three retail buildings, the addition of ten homes and a new 0.20 acre park. The site plan is provided as Attachment D for reference. Two of the existing commercial buildings, Buildings #1 and #2 have been deemed historic resources. Building 3, the former market building proposed to house the new Fresh Market, is not considered a historic resource. Building #1 was approved to be disassembled, relocated on site and rehabilitated. Building #2 was approved to be rehabilitated in place. The primary public benefits for the Edgewood Plaza project consist of 1) the preservation of historic resources and 2) the construction and operation of the grocery store. An Environmental Impact Report (EIR) was prepared and certified by the City Council to provide environmental clearance in accordance with the California Environmental Quality Act (CEQA) for the rezoning. The EIR was certified based on the assumption that historic impacts for the relocation of Building #1 would be mitigated to a less than significant impact because the building would be rehabilitated in accordance with the Secretary of the Interior’s Rehabilitation Standards. Specifically, the character defining features of the building, such as the wood window frames, glu-lam beams, concrete block wall, cornice and wood paneling, would be retained. The CEQA findings adopted by the Council are provided in Attachment B. Building #1 Demolition and Stop Work Subsequent to the City Council approval, the applicant submitted building permits to repair Building #3 (grocery store), disassemble and rehabilitate Building #1 and to rehabilitate Building #2, in compliance with the PC Zoning. The applicant submitted building permit plan sets that were prepared under review by the applicant’s historic consultant, Page and Turnbull, following the requirements of the project’s EIR. The building permit plan sets included specific notes for a review process to ensure that the disassembly of Building #1 would be completed in conformance with the Secretary of the Interior’s Rehabilitation Standards. Shortly after the building permits were issued, however, Building #1 was completely demolished. Once staff was notified, a Stop Work Order was issued immediately to stop all virtually all work at the Edgewood Plaza. Shortly after the issuance of the Stop Work Order, the applicant met with City staff to discuss the situation. Staff also requested a written explanation of the unauthorized demolition. A copy of the applicant’s explanation has been provided to the Council in Section II of Attachment C. The explanation, written by the applicant’s historic consultant, stated that the building materials were in a condition that was not salvageable. However, the applicant failed to follow the approved review process and disposed of the building material without notifying the City or obtaining City approval. Staff observed that although significant site improvement work had commenced, Building #2 remained largely untouched. Improvements to Building #3 (grocery store) were in process. City of Palo Alto Page 4 Other Work on Site Although all work had stopped, the applicant requested the ability to proceed with other components of the project. The key component was the ability to proceed with the construction of the grocery building, which was one of the primary public benefits of the PC adopted by Council. The Planning Director allowed the grocery store and any related work needed to make the site operational for Fresh Market to move forward since a) the new market was a public benefit and there were no environmental impacts identified with its development, b) the building was not a historic resource, c) there were no violations identified for this part of the project and d) the commercial portion of the project was subject to an earlier lot merger and was consistent with both the earlier PC zone and the new PC zone. The applicant submitted a phasing plan that showed that this work could be completed without affecting the site of Building #1, Building #2 or the location where the ten homes would be located. The grocery store work complies with the PC zoning requirements. The related work included parking lot improvements and utilities and was allowed to proceed. Staff also permitted a few other incidental activities that were allowed. Staff allowed the foundation to be poured at the new location of Building #1 to protect work that already had been done prior to the issuance of the Stop Work Order. The applicant was made to understand that any work on Building #1 would be subject to future review and requirements, and that the foundation pour was allowed at the applicant’s risk that a final resolution may require a modified location for Building #1 (though staff doesn’t believe that’s likely). Staff also allowed temporary roof protection to be installed on Building #2 to protect the interior. The applicant is targeting May as a grand opening date for the grocery store. PC Amendment The applicant has filed an amendment to the original PC application to permit the reconstruction of Building #1 in accordance with a modified Secretary of Interior Standards for Reconstruction. The modified standards would closely comport to the building plans previously approved by the City. It is also expected that the project would contain additional historic enhancements that would further unify the three Eichler commercial buildings. Discussion Staff has brought the Edgewood Plaza project forward to assure that Council is supportive of the direction of the process of rectifying the project violations of Building #1 and the associated environmental review (EIR). Staff anticipates that the components of the subsequent action will include: 1) an amendment to the Planned Community Zoning, 2) preparation of a Supplemental Environmental Impact Report (SEIR), and 3) determination as to which elements (if any) of the project may proceed in the interim, pending final Council actions. Planned Community Zoning Amendment City of Palo Alto Page 5 The original Planned Community Zoning approval included the relocation and rehabilitation of Building #1, with the retention of the character defining features of the Eichler building. The rehabilitation of the building was considered a “public benefit” of the project justifying the rezoning. Since Building #1 has been demolished and will need to be completely reconstructed, the Planned Community Zoning must be amended before work may commence on Building #1. The applicant has submitted a letter request to amend the zoning. The applicant proposes to rebuild Building #1 as approved, but with all new material rather than retaining some portion of the prior building materials. The revised application will be required to be reviewed by the Historic Resources Board (HRB) and the Planning and Transportation Commission (PTC). Subsequent to the HRB and PTC recommendations, the application would be brought back to the City Council for final approval. Architectural Review Board review will be required if significant changes to the elevations are proposed. However, the applicant has indicated that such changes are unlikely. Staff has informed the applicant that the rebuilding of Building #1 is likely to require certain enhancements in response to the loss of the historic building. The enhancements may include the requirement for the exact reproduction of the wood windows found in Building #2 or better replications of other components that had previously been altered over the years. The PC amendment will address the “public benefits” issue to define whether comparable historic benefits may be provided or whether additional benefits may be required to compensate for those lost by the demolition of Building #1. Supplemental Environmental Impact Report (SEIR) As required by the California Environmental Quality Act (CEQA), the Environmental Impact Report (EIR) for Edgewood Plaza was prepared to serve as a disclosure document to provide information to the public and decision making bodies as they consider pending applications. Specifically CEQA requires agencies to not only disclose the significant environmental effects of proposed projects, but the feasible alternatives or mitigation measures that could help avoid or reduce the environmental impacts. The site has been determined to be a historic resource in accordance with CEQA. The project’s EIR was certified based on the assumption that historic impacts for the relocation of Building #1 would be mitigated to a less than significant impact because the building would be rehabilitated in accordance with the Secretary of the Interior’s Rehabilitation Standards. Because Building 1 has been demolished, the Rehabilitation Standards are no longer applicable and a substituted mitigation measure or a statement of overriding considerations is required. Given that the project condition for Building #1 has changed, a Supplemental Environmental Impact Report (SEIR) is required to analyze the historic impacts of the demolition and to identify substitute mitigation measures for the loss of Building #1. Staff has engaged the original environmental consultant, David J. Powers and Associates, to prepare the SEIR, at the applicant’s expense. The SEIR will focus on the range of potential substituted mitigation measures for the loss of Building #1. The applicant is proposing to reconstruct Building #1 with all new material, but to replicate the prior approved design. A Notice of Preparation for the City of Palo Alto Page 6 SEIR has been published and mailed to responsible agencies requesting comments by March 4, 2013. A draft SEIR will be prepared to outline potential mitigation measures or alternatives and/or findings that would be required to allow for the loss of a significant historic resource. The draft SEIR will be available to the public and will be reviewed by the Planning and Transportation Commission prior to consideration of the amendment to the PC zoning and any modification of “public benefits” for the project. The Council will then consider the Final SEIR and the PC amendment following recommendations from the HRB and PTC. Staff expects that the EIR and PC amendment process will take approximately 4-6 months. Next Steps and Staff Recommendation The applicant understands that work on Building #1 cannot commence without Council approval of a PC Zoning amendment or a certified SEIR. However, the applicant has requested permission to proceed with the rest of the project. Staff recommends allowing the applicant to proceed with the commercial aspects of the development that comply with the prior PC ordinance as well as the contemplated PC ordinance. However, staff does not recommend allowing the housing to proceed as the status of the existing PC ordinance is in flux given the removal of a key community “public benefit.” Work on Commercial Buildings #2 and #3 The applicant has requested to continue work on the grocery store (Building #3) and to begin work on Building #2, the one remaining historic building, because he believes it will be possible to rehabilitate the building in place as previously approved. Staff’s primary concern with these requests is to ensure that unauthorized work will not be an issue and that staff will be fully aware of any potential issue or change. To address the concern, staff has requested that the applicant’s historic consultant, Page and Turnbull, provide an explanation of the previous events that led to the unauthorized demolition and how the applicant intends to comply with the requirements for the rehabilitation of Building #2. Page and Turnbull has prepared and provided a narrative (Attachment C) explaining the process that led to the demolition of Building #1 and a protocol for Building #2 to ensure compliance with the Secretary of the Interior’s Rehabilitation Standards. The protocol, which has been reviewed by the City’s Historic Preservation Planner, establishes a procedure for the documentation, notification, salvage, protection and approval needed for the successful rehabilitation of the historic building. Staff believes the protocol establishes a clear process to ensure compliance to supplement the process identified in the original building permit plans submitted for Building #1. However, the protocol will likely need to be refined as more information is discovered through the construction process. To further aid in the assessment of Building #2, the City authorized limited reconnaissance (with City staff on hand) to assess the building’s condition. Very small spot openings were created in the non-historically significant interior walls to allow viewing of the exterior walls. Although it was discovered that City of Palo Alto Page 7 much of the building has been replaced over time, the historic integrity of the building is still intact because the character-defining features that establish the historic fabric of the building were maintained. To ensure compliance throughout the entire construction process, staff recommends that the applicant also pay for a City-hired consultant to provide a historic peer review of the plans and construction site observation to ensure that the project is implemented as required. Staff also believes that the relocation and rehabilitation of the historic sign can be done in a way that will not further damage the historic integrity of the site. An Architectural Review permit would be required for the historic sign and would be reviewed by both the Historic Resources Board and the Architectural Review Board. Additionally, staff would also like the applicant to proceed with the following transportation related improvements required in the PC zoning as they directly relate to pedestrian and vehicular safety: a) median island modifications at Embarcadero Rd. and West Bayshore Road, b) signal modification at Embarcadero Road and St. Francis Drive, and c) two-way left turn restriping on Embarcadero Road from St. Francis Drive to Wildwood Lane. The goal would be to have these improvements in place when the grocery store opens. A team of City staff for the Edgewood Plaza project has been created and engaged to ensure regular communication and monitoring of the project. City staff has also been communicating with neighborhood resident groups to keep the neighborhood informed. Residential Development The applicant has also expressed interest in being allowed to process the Final Subdivision Map and at least prepare the housing sites and possibly construct a few model homes of the ten approved home sites, while the SEIR is prepared and the PC amendment is reviewed. Staff has objected to that approach, as the loss of the community benefit puts the current PC in flux and staff is not able to make the necessary findings to subdivide the residential lots at this time. Alternatives Council may, in lieu of staff’s recommendation, choose any of the following alternatives (or others): 1. Stop all work, including the grocery store, until the SEIR and PC amendment are presented to Council. The applicant would be required to cease all work immediately. The grocery store and related work would be placed on hold, perhaps jeopardizing the lease with the grocery tenant and substantially delaying the rehabilitation of the center. The site would remain completely vacant until the SEIR and PC Amendment are brought before the Council. The deferral of the housing provides some financial consequence and leverage to encourage City of Palo Alto Page 8 the applicant to move expeditiously on other components of the project, particularly relative to Building #1. 2. Stop all work other than the grocery store, until the SEIR and PC amendment are presented to Council. The applicant would be allowed to complete work only on the grocery store and related site work, as currently allowed. This would include the parking lot, utility, signage and traffic improvements. The remainder of the site, including Building 2 and the housing, would have to remain untouched and fenced off until the SEIR and PC Amendment are brought to the Council for a decision. This would result in construction adjacent to the grocery store after the store opens, which would be disruptive to the store, and would delay somewhat the rehabilitation of the center. Deferral of the housing again serves as leverage to assure compliance throughout the remainder of the construction. 3. Allow the housing or a portion of the housing to proceed at applicant’s risk while the SEIR and PC amendment are under development, and assess a fine for the demolition of Building #1. This would also allow for approval of the final map. This alternative would allow the applicant to proceed with the construction of Building #2 and some or all of the housing. If the housing moves forward, staff believes the City has somewhat reduced leverage to assure compliance and cooperation for the construction of the remainder of the project. If Council determines to allow the housing to proceed, staff recommends two additional provisions: a) no final inspection and issuance of a certificate of occupancy should be permitted until Council certification of the SEIR and approval of the PC amendment; b) applicant proceeds at his own risk in the event the amended project is not approved by the Council; and c) a penalty should be assessed for the unpermitted demolition of Building #1. Staff recommends a fine of $10,443.17 if such a penalty is levied (see discussion below). In order to construct the housing units, the applicant must comply with the PC Ordinance and EIR mitigation measures. Because the rehabilitation of Building #1, which was a major public benefit of the original PC approval and a required mitigation measure in the EIR, is no longer possible, construction of housing would not be in compliance with the PC conditions of approval and the EIR mitigation measures. Amending the PC ordinance and substituting a mitigation measure is a discretionary action which triggers a SEIR. Staff believes that options that avoid preparation of an SEIR and PC amendment are not legally viable. However, alternatives #1 and #2 would allow construction of the project components that are still in compliance with the PC Zoningand therefore do not require a SEIR and PC amendment. Penalties for Non-Compliance The project applicant has violated the conditions of approval for the PC zoning and the historic resources mitigation measures required. The City could impose financial penalties related to the violation. The applicant, however, has cooperated with staff’s subsequent direction, admits City of Palo Alto Page 9 culpability (though not intent) and concurs with staff’s recommendations in this report. The applicant will (and has to some extent already) incur substantial costs associated with a) delay in construction of the various components of the project, b) costs for the additional environmental review and staff work, c) additional onsite monitoring and peer review of the historic building (Building 2), and d) modifications to the project “public benefits,” to be determined subsequently by Council. Of particular note, staff believes that deferral of the housing component of the project is a substantial penalty for the developer and provides significant leverage for the City to assure the project complies fully as it moves forward. Nevertheless, the City Council may ultimately determine a penalty is required upon review of the amended PC zoning or presently. The Municipal Code allows the City to fine applicants for a variety of code violations. The Code provides that, for construction without a permit, an amount equal to the building permit fee (“double permit fees”) may be assessed. The building permit fee is based on the valuation of the construction cost and the scope of work for all trades (i.e. lighting, plumbing, etc.). The building permit fee that was charged for Building 1 was $9443.17. Accordingly, the City could use this rationale to fine the applicant an additional $9,443.17 for the illegal demolition. Additionally, given the special circumstance of the demolition of an historic structure, an additional fine may be warranted. There is a specific fine of $1,000 authorized in the City Code for demolition of a downtown historic structure. If a similar fine were added to the building permit fee, a total of $10,443.17 could be assessed. Given the discretionary nature of the Planned Community consideration, Council may assess a lesser or greater penalty. Resource Impacts The cost of additional review and preparation of the Supplemental Environmental Impact Report will be borne by the applicant. The resource impacts of the Planned Community zoning are not likely to change given the project modifications and the amended zoning. The grocery store is proceeding with construction, so that its economic benefits should be realized in a timely manner. Environmental Review Environmental review is addressed earlier in the report, as a Supplemental Environmental Impact Report (SEIR) will be required and is under preparation. Attachments:  Attachment A: PC Ordinance #5150 (Edgewood Plaza) (PDF)  Attachment B: CEQA Resolution for Edgewood Plaza (PDF)  Attachment C: February 4, 2013 Page and Turnbull Letter re: Historic Resources (PDF)  Attachment D: Site Plan (PDF) City of Palo Alto Page 10  Attachment E: Response to Council Questions (DOCX)  Attachment F: Public Correspondence (PDF) · Resolution No. 9239 Resolution Of The Council Of The City Of Palo Alto Certifying The Adequacy Of The Final Environmental Impact Report For The Edgewood Plaza Project Pursuant To The California Environmental Quality Act And Adopting The Mitigation Monitoring And Reporting Program The Council of the City of Palo Alto does RESOLVE as follows: SECTION 1. Introduction and Certification. (a) The City Council of the City of Palo Alto ("City Council"), in the exercise of its independent judgment, makes and adopts the following findings to comply with the requirements ofthe California Environmental Quality Act ("CEQA"; Pub. Resources Code, §§ 21000 et seq.), and Sections 15091, 15092, and 15093 of the CEQA Guidelines (14 Cal. Code Regs., § 15000 et seq.). All statements set forth in this Resolution constitute formal findings of the City Council, including the statements set forth in this paragraph. These findings are made relative to the conclusions of the City of Palo Alto Edgewood Plaza Project Final Environmental Impact Report (State Cleari11ghouse No. 2011022030) (the "Final EIR") , which includes the Draft Environmental Impact Report ("Draft EIR"), Public Comments, and Responses to Comments. The Final EIR addresses the environmental impacts of the implementation of the Edgewood Plaza Project (the "Project", as further defined in Section 2(b) below) and is incorporated herein by reference. These findings are based upon the entire record of proceedings for the Project. (b) Mitigation measures associated with the potentially significant impacts of the Project will be implemented through the Mitigation Monitoring and Reporting Program described below, which is the responsibility of the City. (c) The City of Palo Alto is the Lead Agency pursuant to Public Resources Code section 21067 as it has the principal responsibility to approve and regulate the Project. Sand Hill Property Company is the Project applicant. (d) The City exercised its independent judgment in accordance with Public Resources Code section 20182.1(c), in retaining the independent consulting firm David J. Powers & Associates, Inc. ("Powers & Associates") to assist with preparation of the Final EIR under the supervision and at the direction of the City's Director of Planning and Community Environment. (e) The City, with assistance from David J. Powers & Associates, initially prepared the Draft EIR and circulated it for review by responsible and trustee agencies and the public and submitted it to the State Clearinghouse for review and comment by state agencies, for a comment period which ran from September 30, 2011, through November 14, 2011. As noted above, the Final EIR includes the Draft EIR, copies of all comments on the Draft EIR submitted during the comment period, the City's responses to those comments, and changes made to the Draft EIR following its public circulation. 120402 dm 0120533 1 (f) The City's Planning and Transportation Commission has reviewed the Final EIR and a draft of these findings and has provided its recommendations to the City Council regarding certification of the Final EIR. The City Council has independently reviewed the Final EIR and has considered the Planning and Transportation Commission's recommendations in making these findings. (g) Based upon review and consideration of the inforn1ation contained therein, the City Council hereby certifies that the Final EIR was completed in compliance with CEQA, and reflects the City of Palo Alto's independent judgment and analysis. The City Council has considered evidence and arguments presented during consideration of the Project and the Final EIR. In determining whether the Project may have a significant impact on the environn1ent, and in adopting the findings set forth below, the City Council certifies that it has complied with Public Resources Code sections 21081, 21081.5, and 21082.2. (h) Section 6 of the Final EIR and the First Amendment to the Final EIR shows all revisions which the Final EIR made to the Draft EIR. All references to the Draft EIR in these findings include references to all revisions to the Draft EIR made in the Final EIR (as amended). Having reviewed this section and the Final EIR as a whole, the City Council hereby finds, determines, and declares that no significant new information has been added to the Final EIR so as to warrant recirculation of all or a portion of the Draft EIR. Likewise, the City· Council has considered all public comments and other information submitted into the record since publication of the Final EIR, and further finds that none of that additional information constitutes significant new information requiring recirculation of the Final EIR. SECTION 2. Project Information. The following Project information is supplied to provide context for the discussion and findings that follow, but is intended as a summary and not a replacement for the information contained in the Draft EIR, Final EIR, or Project approvals. (a) Project Objectives The Project Objectives of the Project applicant are set forth in Section 2.4 of the Draft EIR, which is incorporated herein by reference. (b) Project Description The proposed Project is the renovation of three existing commercial buildings at the Edgewood Shopping Center containing approximately 38,400 square feet of retail uses, and the redevelopment of the northern portion of the site with ten single-family residences and an approximately 0.20 acre park. The three buildings currently on site are arranged in an L-shaped plan, with the grocery store to the east, and the two one-story retail buildings to the west. The grocery store and the retail buildings are wood-framed with elements of stucco and concrete block, and have flat roofs. One of the existing retail buildings (Building 1) would be relocated to the north and west of its current location on the site to allow for a modified configuration of parking for the grocery store. This building and the other building to remain in place (Building 2) would be renovated 120402 dm 0120533 2 for continued retail use. Building 1 would be disassembled, and significant elements with distinctive design qualities, such as the walls and walkway overhangs would be retained. The building would be reconstructed to the north and west of the current Building 1 location, and visible historic building elements from the existing building would be rehabilitated and installed on a new building structure. The grocery building would remain in place and be renovated to allow for use as a small­ scale grocery store. A conceptual site plan ofthe proposed Project is shown on Figure 4. A breakdown ofthe proposed development areas and building square footage are shown in Table 2.3-1. Conceptual elevations of the commercial buildings are shown on Figures 5-10, and conceptual residential elevations are shown on Figure 11. (All references to figures and tables are to those appearing in the Draft ErR, as modified where applicable in the Final ElR.) A complete description of the Project as proposed by the Project applicant is set forth in Section 2.3 of the Draft ErR, as modified in the Final ErR. ( c) Required Approvals The approvals required by the City as lead agency for implementation of the Project include: A. Planned Community Zoning B. Tentative Subdivision Map C. Final Subdivision Map D. Lot Line Adjustments E. Tree Removal Permits SECTION 3. Record of Proceedings. (a) For purposes of CEQ A, CEQA Guidelines section 15091(e), and these findings, the Record of Proceedings for the Project includes, but is not limited to, the following documents: (1) The Final ErR, which consists of the Edgewood Plaza Project Draft Environmental Impact Report, published and circulated for public review and comment by the City from September 30, 2011 through November 14,2011 (the "Draft EIR") , and the Edgewood Plaza Project Final Environmental Impact Report, published and made available on February 17, 2012, a First Amendment to the Final ElR and made available on February 29, 2012 and all appendices, reports, documents, studies, memoranda, maps, testimony, and other materials related thereto; (2) All public notices issued by the City in connection with the Project and the 120402 dm 0120533 3 preparation of the Draft EIR and the Final EIR, including but not limited to public notices for all public workshops held to seek public comments and input on the Project and the Notice of Preparation, Notice of Completion, Notice of Availability; (3) All written and oral communications submitted by agencies or interested members of the general public during the public review period for the Draft EIR, including oral communications made at public hearings or meetings held on the Proj ect approvals; (4) The Mitigation Monitoring and Reporting Program; (5) All findings and resolutions adopted by the City Council in connection with the Project, and all documents cited or referred to therein; (6) All final reports, studies, memoranda, maps, staff reports, or other planning documents relating to the Project prepared by the City of Palo Alto and consultants with respect to the City of Palo Alto's compliance with the requirements of CEQ A, and with respect to the City of Palo Alto's actions on the Project, including all staff reports and attachments to all staff reports for all public meetings held by the City; (7) Minutes and/or verbatim transcripts of all public meetings and/or public hearings held by the City of Palo Alto in connection with the Project; (8) Matters of common knowledge to the City of Palo Alto, including, but not limited to, federal, state, and local laws and regulations; (9) Any documents expressly cited in these findings, in addition to those cited above; and (10) Any other materials required to be in the record of proceedings by Public Resources Code section 21167.6(e). (b) The custodian of the documents comprising the record of proceedings is the Director of Planning and Community Environment, City of Palo Alto, 250 Hamilton Avenue, Palo Alto, California, 94301. ( c) Copies of all of the above-referenced documents, which constitute the record of proceedings upon which the City of Palo Alto's decision on the Project is based, are and have been available upon request at the offices of the Planning and Community Environment Department, City of Palo Alto, 250 Hamilton Avenue, Palo Alto, California, 94301, and other locations in the City of Palo Alto. (d) The City of Palo Alto has relied upon all of the documents, materials, and evidence listed above in reaching its decision on the Project. (e) The City Council hereby finds, determines and declares that the above-referenced documents, materials, and evidence constitute substantial evidence (as that term is defined by 120402 dm 0120533 4 section 15384 of the CEQA Guidelines) to support each ofthe findings contained herein. SECTION 4. Mitigation Monitoring and Reporting Program. (a) CEQA requires the lead agency approving a project to adopt a Mitigation Monitoring and Reporting Program (MMRP) for the changes made to the project that it has adopted in order to mitigate or avoid significant effects on the environment. An MMRP has been prepared and is recommended for adoption by the City Council concurrently with the adoption of these findings to ensure compliance with mitigation measures during Project implementation. As required by Public Resources Code section 21081.6, the MMRP designates responsibility and anticipated timing for the implementation of the mitigation measures recommended in the Final EIR. The MMRP will remain available for public review during the compliance period. (b) The City Council hereby adopts the MMRP for the Project attached hereto and incorporated by reference, and finds, determines, and declares that adoption of the MMRP will ensure enforcement and continued imposition of the mitigation measures recommended in the Final EIR, and set. forth in the MMRP, in order to mitigate or avoid significant impacts on the environment. SECTION 5. Potentially Significant Impacts. By these Findings, the City Council ratifies and adopts the Final EIR' s conclusions for the following significant environmental impacts which, based on the analyses in the Final EIR, this City Council determines will be less than significant after the implementation of the mitigation measures described below. All citations to the Draft EIR chapters and sections below include reference to all revisions to those chapters and sections contained in the Final EIR. Section 3.2.5.3 Historic Resources Impacts in the Draft EIR included summaries of the expert opinion of two qualified historic resources consultants, Page &Turnbull and Carey & Company. The City Council finds the opinion of Page & Turnbull to be valid and agrees with their conclusions regarding the significance of project impacts on historic resources. The significance conclusions for Impact CR-2 and Impact CR-3 below reflect a revision of the impact statements in the Final EIR made available on February 17, 2012, based upon the City Council's independent judgment of the two analyses by experts presented in the EIR. 5.1 Cultural Resources Impact CR-l: Unknown subsurface archeological or paleontological resources could be present on the site, and could be disturbed during Project construction. a) Potential Impact. The impact identified above is described and discussed in Sections 3.2.1 and 3.2.5.2 of the Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures CR-1.1 and CR-1.2. 120402 dm 0120533 5 c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring that all construction activities be halted within a radius of fifty (50) feet of any potentially significant archeological or paleontological resources encountered during construction; (ii) requiring that such resources be examined by qualified professionals; and (iii) following the recommendation of the qualified professional to preserve, collect, record and/or analyze the resources, thereby ensuring that significant archeological and paleontological resources are not inadvertently destroyed and are appropriately preserved and/or recorded. The above-noted measures will also reduce the severity of this potentially impact to a less-than-significant level by: (i) requiring that all construction activities be halted in the event that any human remains are encountered during construction; (ii) requiring that such remains be examined by the County Coroner to determine whether or not the remains are Native American; (iii) to contact the California Native American Heritage Commission and COlmty Coordinator of Native American Affairs if the remains are determined to be Native American; and (iv) by prohibiting any further disturbance of the site except as authorized by the County Coordinator as provided by state law, thereby ensuring that any Native American remains encountered are not inadvertently destroyed and handled appropriately. Based upon the expert opinion of Page & Turnbull presented in the Draft EIR, the City Council finds that the following impact statement (Impact CR-2) regarding impacts to historic resources reflects its independent judgment. Impact CR-2: The Edgewood Plaza site is considered historically significant under federal, state and City of Palo Alto criteria. Although relocation of Building 1 on the site would alter the site design and characteristics of Edgewood Plaza, this change in spatial relationship would not result in a significant impact to the historic character of the buildings. The physical relocation of Building 1 and renovation of Buildings 1 and 2, however, could result in modifications to the historic design and integrity of the buildings. a) Potential Impact. The impact identified above is described and discussed in Section 3.2.5.3 of the Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures CR-2.1, CR-2.2 and CR-2.3. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) documenting the exterior of Buildings 1 and 2 and their settings in accordance with Historic American Buildings Survey Level III docunlentation requirements, as described in greater detail in Section 6 of the Final EIR, and preserving such documentation with the Palo Alto Historic Resources Preservation Officer; (ii) creating a display illustrating the history of the Edgewood Plaza as built by Eichler Homes prior to approval of final occupancy; (iii) requiring that the distinctive and defining architectural features, finishes and construction techniques of Buildings 1 and 2, including windows, frames, and eaves, be retained to the extent feasible during the relocation and reconstruction of Building 1 and the rehabilitation of Building 2, subject to verification by qualified professionals that work on these resources is completed in conformance with applicable 120402 dm 0120533 6 federal standards; and (iv) requiring review and approval of the final design and materials to be used in the renovation of these buildings by the City of Palo Alto Planning and Community Environment Department; thereby ensuring that this Impact is mitigated to a less-than-significant level. While the Draft and Final EIRs conservatively identified this impact as significant and unavoidable based upon conflicting expert opinion, the City Council agrees with the conclusions of the experts, as reflected in the record, that this impact can, in fact, be mitigated. Based upon the expert opinion of Page & Turnbull presented in the Draft EIR, the City Council finds that the following impact statement (Impact CR-3) regarding impacts to historic resources reflects its independent judgment. Impact CR-3: The Edgewood Plaza site is considered historically significant under federal, state and City of Palo Alto criteria. While construction of ten new single-family houses on the site would alter the overall site design and characteristics of Edgewood Plaza, this construction would not result in a significant impact to historic resources. 5.2 Air Quality Impact AQ-l: Construction of the proposed Project could result in temporary air quality impacts associated with dust and particulate matter generation at nearby residential uses. a) Potential Impact. The impact identified above is described and discussed in Section 4.3.2.3 of Appendix C the Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder ofthese findings: Mitigation Measure AQ-l.l. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by requiring the applicant to implement numerous construction practices determined by the Bay Area Air Quality Management District to significantly reduce the adverse air quality effects of construction activities. These practices include watering all exposed surfaces, covering all haul trucks, regularly removing all mud, dirt and debris from public roads, limiting vehicle speeds on the construction site, paving all appropriate surfaces as soon as possible, limiting idling times of construction vehicles and equipment, properly maintaining all construction equipment, and publicly posting contact information for public complaints regarding construction activities, all as described in greater detail in Section 4.3.2.3 of the Appendix C of the Draft EIR. Implementing these measures will minimize the extent to which dust and particulate matter generated by Project construction activities is dispersed to nearby residential uses and other sensitive receptors. 5.3 Biological Resources Impact BIO-l: Excavation during construction of the proposed Project could result in disturbance to active rapt or nests. 120402 elm 0120533 7 a) Potential Impact. The impact identified above is described and discussed in Section 4.4.2.1 of Appendix C of the Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measure BIO-l.I. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by requiring the applicant to implement numerous several measures, pursuant to the requirements of the federal Migratory Bird Treaty Act and the California Department of Fish and Game, designed to reduce adverse effects on raptors and their nests. These measures include having a qualified ornithologist complete pre-construction surveys to identify active nests that might be disturbed by Project activities, postponing all tree removal and pruning activities for trees containing active raptor nests and establishing buffer or exclusion zones around such trees, and monitoring such trees and nests and prohibiting construction activities within the buffer/exclusion zones until the young raptors have fledged from the nests. Implementing these measures will ensure that active raptor nests are not unduly disturbed by construction activities, thereby avoiding and reducing the potential adverse effects of the Project on raptors and their nests to less-than-significant levels. 5.4 Hazardous Materials Impact HAZ-l: construction workers and soil and groundwater. Construction of the proposed Project could expose others to residual hazardous materials contamination III a) Potential Impact. The impact identified above is described and discussed in Section 4.8.3.2 of Appendix C ofthe Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures HAZ-1.l, 1.2, 1.3, 1.4 and 1. 5. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring the applicant to prepare and implement a Soil Management Plan, to be reviewed and approved by the City of Palo Alto and in compliance with all applicable federal, state and local regulations and in conformance with applicable industry standards, to govern the handling of contaminated soil and other hazardous materials encountered during Project construction activities; (ii) requiring each contractor working on the site to prepare a health and safety plan that addresses the health and safety hazards that may affect each phase site operations due to potential exposures to hazardous materials, which plan includes requirements and procedures to ensure protection for each contractor's employees, in compliance with all applicable federal, state and local regulations and in conformance with applicable industry standards,; and (iii) requiring soil and groundwater sampling and, if appropriate, soil vapor sampling, from under 2125 st. Francis Drive to ensure 120402 dm 0120533 8 that soil exceeding applicable tetrachloroethene levels (PCE-affected soils) is not present within five (5) feet of the ground surface, requiring removal and disposal of any PCE-affected soils by qualified professionals using appropriate protective gear in accordance with applicable federal, state and local requirements, requiring an excavation base confirmation sample to confirm that sufficient PCE-affected soils have been removed, and requiring that documentation of all PCE­ affected soils be provided to the City of Palo Alto and appropriate oversight agencies prior to installation of pavement in the parking lot area; (iv) requiring characterization of all excavated soils prior to off-site disposal or on-site reuse; requiring that contaminated soils be disposed of at a licensed facility in accordance with all applicable local, state and federal regulations; (v) requiring that all excavated soil characterizations, storage, transportation and disposal be in conformance with all applicable federal, state and local procedures and requirements; and (vi) requiring the applicant to prepare a contingency plan prior to the beginning of Project construction to address any previously unknown sumps, hydraulic hoists, or tanks that may be present in the work area. Implementation of these measures will ensure that the risks associated with exposure to contaminated soils and other hazardous materials are reduced to a less-than­ significant level. Impact HAZ-2: Renovation and relocation of Project buildings could expose construction workers and sensitive receptors, including the surrounding residential uses, to lead­ based paint and/or asbestos-containing materials (ACMs). a) Potential Impact. The impact identified above is described and discussed in Section 4.8.3.2 of Appendix C ofthe Draft ElR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures HAZ-2.1, 2.2 and 2.3. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring surveys by qualified professionals of all structures proposed for renovation on the site to determine the presence of asbestos and lead-based paint, prior to commencing any work on such structures; (ii) requiring that a registered asbestos abatement contractor by retained to remove and dispose of all potential friable asbestos-containing materials, in accordance with applicable federal and state laws, regulations, guidelines and requirements, prior to any relocation or renovation activities that may disturb such materials; and (iii) requiring that all building materials containing lead­ based paint be removed and disposed of in accordance with applicable federal, state and local standards, which include requirements relating to employee training, air monitoring and dust control. Implementation of these measures will reduce the risks associated with potential exposures to asbestos-containing materials and lead-based paint to less-than-significant levels. 5.5 Hydrology and Water Quality. Impact HYDRO-I: Construction of the proposed residential units on the Project site may expose people or structures to flooding risks. a) Potential Impact. The impact identified above is described and discussed in 120402 dm 0120533 9 Section 4.9.3.1 of Appendix C ofthe Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures HYDRO-I. 1 and 1.2. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring that all construction activities on the site comply with the City of Palo Alto Flood Hazard Ordinance, including elevation of habitable spaces above anticipated flood levels; (ii) requiring that all Project plans show the base flood elevations on all applicable elevations, sections, and details, and otherwise comply with all other requirements listed in the Ordinance; and (iii) requiring that all construction activities on the site also comply with all applicable requirements of the Federal Emergency Management Agency for flood hazard areas. Implementation of these measures will ensure that structures on the site are constructed to minimize to the extent feasible risks associated with flooding on the site and that this potentially significant impact is reduced to a less-than-significant level. Impact HYDRO-2: Construction activities could temporarily increase pollutant loads in storm water runoff. a) Potential Impact. The impact identified above is described and discussed in Section 4.9.3.5 of Appendix C ofthe Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures HYDRO-2.l and 2.2. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring the implementation of certain erosion and sediment control measures based upon Best Management Practices recommended by the Regional Water Quality Control Board (RWQCB), including installing stormwater inlet protection around all storm drain inlets, watering all exposed surfaces, suspending all dust-producing activities during periods of high winds, covering and watering stockpiles of soil and other materials, covering all haul trucks, regularly sweeping and removing all mud, dirt and debris from all paved access roads, parking areas and staging areas, and replanting all vegetation in disturbed areas as soon as possible, as described in greater detail in Section 4.9.3.5 of the Appendix C of the Draft EIR; (ii) requiring that an erosion and sedimentation control plan be submitted to the City of Palo Alto Public Works Department for review and approval prior to the issuance of any grading or building permits; and (iii) requiring certain post-construction measures based on RWQCB Best Management Practices, including providing roofs on all trash enclosures on site, providing onsite treatment of stormwater runoff from the site prior to discharge to the City of Palo Alto stormwater system, preparing and submitting to the City of Palo Alto Public Works Department an annual post-construction maintenance agreement prior to the Issuance of grading or building permits, requiring 120402 dm 0120533 10 commercial development on the site to implement regular maintenance activities to prevent soil and litter from accumulating on the site, and requiring that landscaping and landscape maintenance on the site employ minimal pesticide use. Implementation of these measures will mitigate the Project's potential impacts relating to pollutant loads in stormwater runoff to less­ than-significant levels. 5.6 Noise Impact NOISE-I: Future residential uses on the site could be exposed to noise levels above City of Palo Alto standards for residential uses. a) Potential Impact. The impact identified above is described and discussed in Section 4.12.2.2 of Appendix C ofthe Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures NOISE-I. 1, 1.2, 1.3, 1.4 and 1.5. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring that sound-rated windows, doors, and exterior wall assemblies be used in residential buildings; (ii) requiring acoustical test reports of all sound-rated windows and doors, to be reviewed by a qualified professional and compared with traffic noise spectrums, prior to approval; (iii) requiring ventilation or air conditioning systems in all residential units that provide habitable interior environments, so that windows need not be relied upon to provide ventilation; (iv) requiring six (6) foot tall noise barriers in specific locations; (v) requiring that residential mechanical equipment be selected and located to meet the properly line limits in the City of Palo Alto Noise Ordinance, and additional measures such as equipment barriers and enclosures if determined to be necessary by the acoustical test and review described above, all as described in greater detail in Section 4.12.2.2 of Appendix C of the Draft EIR. Implementation of these measures will reduce the severity of potential noise impacts on future residents on the Project site to less-than­ significant levels. Impact NOISE-2: Commercial activities on the site could result in significant noise impact at the proposed residential units. a) Potential Impact. The impact identified above is described and discussed in Section 4.12.2.4 of Appendix C of the Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measures NOISE-2.1 and 2.2. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring that measures be 120402 dm 0120533 11 included in the renovation of the commercial buildings on the site to reduce noise impacts at nearby residences, in conformance with the City of Palo Alto Noise Ordinance, which measures may include installing solid noise barriers along the north and east sides of the loading dock combined with a shed roof, and lining roofs and walls with sound absorbing materials; and (ii) limiting all truck deliveries to the site to daytime hours (7 a.m. to 10 p.m.), communicating to vendors that their drivers will be operating close to residences so that they will limit noise, and providing a full disclosure statement to the owners of residential Lots Nos. 9 and 10 regarding potential truck noise, which statement shall be incorporated into the deeds for these residential properties. Implementation of these measures would reduce the severity of this potential Impact to a less-than-significant level. Impact NOISE-3: Noise from rooftop mechanical equipment for the retail buildings may exceed the noise standards at adjacent residential properties on the Edgewood Plaza site. a) Potential Impact. The impact identified above is described and discussed in Section 4.12.2.4 of Appendix C ofthe Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measure NOISE-3 .1. c) Findings. The above-noted mitigation measures will reduce the severity of this potentially significant impact to a less-than-significant level by: (i) requiring that mechanical equipment to be installed and used on the Project site be selected, designed and located to minimize noise impacts on adjacent and nearby residential uses; (ii) using solid rooftop screens or noise barriers as determined by a qualified professional to be necessary to meet applicable City of Palo Alto noise standards at the residential property lines; and (iii) providing for review and approval of mechanical equipment plans by the City of Palo Alto Building Department prior to the issuance of building permits; all as described in greater detail in Section 4.12.2.4 of Appendix C of the Draft EIR. Implementation of this mitigation measure will reduce the severity of this Impact to a less-than-significant level. 5.7 Transportation Impact TRANS-1: Project traffic would cause a significant impact at the Wildwood Land-North California Avenue and Embarcadero Road unsignalized intersection. a) Potential Impact. The impact identified above is described and discussed in Section 4.16.2.2 of Appendix C of the Draft EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the Mitigation Monitoring and Reporting Program, and as further described in the remainder of these findings: Mitigation Measure TRANS-I.l. c) Findings. The above-noted mitigation measures will reduce the severity of this 120402dm0120533 12 potentially significant impact to a less-than-significant level by: (i) restriping Embarcadero Road to create a left turn receiving lane; and (ii) installing a left turn lane receiving area at the Embarcadero RoadiSt. Francis Drive intersection at Wildwood Lane. Installation of these improvements will facilitate left turns and reduce left turn delays, thereby mitigating this Impact to a less-than-significant level. SECTION 6. Findings Regarding Project Alternatives. Public Resources Code section 21002 prohibits a public agency from approving a project if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of the project. When a lead agency finds, even after the adoption of all feasible mitigation measures, that a project will still cause one or more significant environmental effects that cannot be substantially lessened or avoided, it must, prior to approving the project as mitigated, first determine whether there are any project alternatives that are feasible and that would substantially lessen or avoid the project's significant impacts. Under CEQA, "feasibility" includes "desirability" to the extent that it is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors, and an alternative may be deemed by the lead agency to be "infeasible" if it fails to adequately promote the project applicant's and/or the lead agency's primary underlying goals and objectives for the project. Thus, a lead agency may reject an alternative, even if it would avoid or substantially lessen one or more significant environmental effects of the project, if it finds that the alternative's failure to adequately achieve the objectives for the project, or other specific and identifiable considerations, make the alternative infeasible. The City Council certifies that the Final EIR describes a reasonable range of alternatives to the Project, which could feasibly obtain the basic objectives of the Project, and that the City Council has evaluated the comparative merits of the alternatives. As explained in the findings set forth above, the Project will not result in any significant effect on the environment that cannot be mitigated through the mitigation measures which are hereby being adopted and imposed on the Project. Therefore, the Council need not make any additional findings regarding the feasibility of any Project alternative. \\ \\ \\ \\ \\\ \\ \\ \\ \\ 120402 dm 0120533 13 INTRODUCED AND PASSED: MARCH 19,2012 AYES: BURT, ESPINOSA, HOLMAN, KLEIN, PRICE, SCHARFF, SCHMID, SHEPHERD,YEH NOES: ABSENT: ABSTENTIONS: APPROVED AS TO FORM: Asst. City Attorney Director of Planning & Community Environment 120402 dm 0120533 14 February 4, 2013 Elena Lee City of Palo Alto Development Center 285 Hamilton Ave Palo Alto, CA 94301 RE: Edgewood Shopping Center – Report to the Palo Alto City Council for February 11, 2013 Dear Elena, This report is written to provide the Palo Alto City Council a summary analysis of the historic Building 1 and Building 2, beginning with permitted construction plans and continuing chronologically through the conditions of Building 1 and the grocer building, recent reconnaissance on Building 2, proposed revisions to the historic building elevations, and concluding with the protocol for proceeding with the construction of the historic buildings and project. The primary consideration for formulating our proposal in this letter is to ensure best efforts and outcomes by the project sponsor and its team that will allow completion of this very important community facility. EXECUTIVE SUMMARY ! We reviewed the Building 1 and Building 2 construction drawings for historic conformance and the City-issued demolition and construction permits. ! During construction, we assessed Building 1 and concluded that much of the material used in its construction was not repairable, was not in good condition, and would need to be replaced with new materials to match the material, configuration, character and finish of the original. ! All three walls of the grocery building that were intended to be retained were discovered during renovation to be in too poor condition and had to be replaced with compatible new materials. The grocery building was determined by the City to be no longer a historic resource due to extensive alterations. ! Building 2 was recently discovered to have 23.5% of its original 1957 exterior wall surfaces remaining including two sections of concrete block, two sections of storefront glass and wood frames, and most of the original transom windows and window frames. Most wall surfaces have been replaced at an undetermined date prior to the project sponsor’s ownership. The window frames were extensively replaced with similar but not identical wood window frames and are compatible but not as distinctive in design as the original window frames. Lee, page 2 ! Tenants and official neighborhood leaders request minor revisions to the permitted elevations, making the buildings appear more in keeping with the “Eichler” style. ! The project sponsor has put into place special protocol and specifications to ensure that the reconstruction of Building 1 and the rehabilitation of Building 2 can be completed efficiently and within the parameters of the City’s permitting process and the requirements of the EIR. We believe that this will result in the successful rehabilitation of the Edgewood Shopping Center. SUMMARY ANALYSIS OF BUILDING 1 AND BUILDING 2 I. Construction Plans Permitted by the City of Palo Alto on August 9, 2012 Prior to permitting, Page & Turnbull reviewed the construction drawings that were prepared by Little Architects and concluded that the proposed project was in keeping with the historic buildings’ original design and with the Secretary of the Interior’s Standards for Rehabilitation #5, 6, 7, and 9 as recommended by City staff and the Historic Resources Board. We issued a letter dated June 14, 2012 to the City of Palo Alto confirming this review and analysis. At that time, the construction drawings showed that distinctive materials and architectural features, finishes and construction techniques would be retained to the extent possible. The drawings that we reviewed also indicated that deteriorated features proposed for removal and replacement would be reviewed by Page & Turnbull and approved by the Director of Planning. As discussed during Palo Alto Historic Resources Board meetings in 2011, we believed that adjustments would be made to the exterior of building Buildings 1 and 2 out of a ‘kit of parts’* that would be compatible with the massing, size, scale, and architectural features of the original buildings. Item MM CR 2.3 of the EIR anticipated some alteration of existing character-defining features to accommodate accessibility, public safety and building code concerns. In addition, the EIR clarified that “the existing building components may be constructed out of new building materials that match the character and form of the existing, if reuse of existing building components is not feasible.” For reference, following is the complete Item MM CR 2.3 of the EIR, “Distinctive materials and defining architectural features, finishes, and construction techniques of Buildings 1 and 2 including windows, frames and eaves will be retained to the extent possible, as the building elements will require some alterations due to * A ‘kit of parts’ is the concept where four distinct wall materials - concrete masonry block, wood framed glass storefront, vertical wood siding, and plaster finish - are the ‘parts’ that variously combine into a ‘kit’ to create the historic Eichler buildings’ characteristic style. Lee, page 3 ADA compliance, public safety, building code compliance, or deteriorated condition. The existing building components may be constructed out of new building materials that match the character and form of the existing, if reuse of existing building components is not feasible. Prior to the relocation and reconstruction of Building 1 and the rehabilitation of Building 2, a qualified historic preservation architect shall review the plans for the remodeled buildings and verify that the work on these buildings is in keeping with the building’s original design and applicable Secretary of Interior’s Standards for Rehabilitation, such as Standards #5, 6, 7, and 9. The final design and materials to be used in the renovation of these buildings will be reviewed and approved by the Director and Historic Resources Planner of the City of Palo Alto Planning and Community Environment Department.” It should be noted that the structural drawings of the permitted plans indicate new concrete block shear walls and Glulam beams to replace the structurally deficient concrete block walls and beams in Building 1, and new concrete block shear walls to replace the structurally deficient concrete block walls in Building 2. II. Conditions of Building 1 and the Grocery Building On March 5, 2012 and September 10, 2012, a representative from Page & Turnbull visited the site with the project sponsor, construction manager and contractor to review the condition of existing materials in Building 1 and Building 2 and to review the contractor’s attempts to salvage building material as it was removed from Building 1. During the September site visit, the project sponsor expressed to the team that the structural engineer had reservations about the structural integrity of the existing Glulam beams in Building 1 and preferred that they be replaced. Page & Turnbull confirmed that many of the existing Glulam beams were in poor condition and were splitting and delaminating. During the same site visit, the contractor showed that the existing Redwood siding was splintering as it was removed from the building for salvage and future reinstallation. Page & Turnbull learned during this site visit that some of the existing wood siding was replacement siding - - not original siding - - and that in some places, original shiplap Redwood siding had been replaced with strips of painted plywood. While we believe that exploratory demolition and testing on the historic buildings should have been completed prior to the development of construction drawings, that likely would not have changed our determination that much of the material used in the construction of Building 1 was not repairable, was not in good condition, and would need to be replaced with new materials to match the material, configuration, character and finish of the original. Lee, page 4 It was also discovered during the recent renovation of the grocery building that it too was in poor condition and three of its walls which were intended to remain had to be replaced in their entirety. Its south concrete block wall was comprised of substandard concrete footings with inadequate steel reinforcing, and its north and west wood framed walls were highly compromised from dry rot and termite damage. The grocery building had previously been determined by the City to be ineligible for the California Register due to extensive alteration, and, therefore it was no longer a historic resource under CEQA. III. Reconnaissance to Assess the Condition of Historic Building 2 Exterior Walls On January 10, 2013, the Director of Planning authorized City Planner Elena Lee and City Historian Dennis Backlund to tour Building 2 with the project sponsor, construction manager and contractor to observe its condition. Soon thereafter, the City granted permission to perform very limited reconnaissance consisting of small openings in its non-character defining interior walls so that the building’s historic exterior skin could be viewed from inside and its condition assessed. On January 15, 2013, it was discovered during reconnaissance that only a limited amount of original exterior wall material remains unaltered for Building 2. The total area of exterior wall surface is 3,604 square feet and after studying the building’s exterior and interior small openings, Dennis Backlund concluded that two sections of concrete block along the building’s south and east walls, totaling 227 square feet (6.3%), two sections of storefront glass and wood frames along its west wall, totaling 143 square feet (4.0%), and most of the original transom windows and window frames, totaling 476 square feet (13.2%), collectively 23.5%, are what remain of the original 1957 exterior. This loss of original material is not surprising given that there likely have been dozens of tenant turnovers having different exterior requirements during the building’s 55 years. That the Building 2 project is a rehabilitation of a building that will not need to be moved helps in being able to retain more of its remaining original materials. Although our reconnaissance did not include detailed investigation of the Glulam beams, steel columns, concrete slab and roof purlins and sheathing for Building 2, we still believe those components can be re-used and reinforced as necessary per the previously permitted plans. The conditions that were discovered in Building 1 prior to its demolition were similar to Building 2. In addition to losses of original material, Building 1 was generally in worse condition due, we believe, to its superior visibility and location within the center which contributed to a more intensive use. This locational advantage not only attracted more tenant turnover but also tenants that generated higher traffic and heavier use compared to those in the less visible Building 2. Lee, page 5 We have researched files of the City of Palo Alto Building Department and other archives for information about original construction. With the knowledge gained from reconnaissance of Building 1 and Building 2, it has become clear that Building 1 and Building 2 appear to have been primarily glass enclosed structures with a wooden or concrete block wall segment, typically not exceeding 16 feet in width, located midpoint along each wall. IV. Tenants and Official Neighborhood Leaders, the Architectural Control Committee, Propose Exterior Revisions to the Historic Buildings During the City entitlement process, the buildings’ elevations were only approximated since future tenant requirements were unknown. With leasing now underway, tenant space requirements are adjusting exact door locations, and where interior visibility is not desired segments of wooden walls may replace glass storefront with Neighborhood Architectural Control Committee (“ACC”) support. Such adjustments conform to the ‘kit of parts’ composition approved by the Historic Resources Board. These adjustments are also desired by the neighborhood ACC who believe the proposed revisions will make the buildings appear more in keeping with the “Eichler” style. We have reviewed the proposed revisions and endorse them. We understand the Secretary’s Standards for Rehabilitation must continue to be met, which we judge to be the case with the revisions. These proposed revisions are shown clouded in the attached exhibits. Along the west wall of Building 1 the ACC requests replacing the five metal exit and utility doors with glass storefront doors and transom windows above. And along the south and east walls of Building 2, Chase Bank’s requirements propose to replace segments of glass storefront with wood in Eichler style. Unknown future tenant needs may warrant similar further adjustment to the buildings, all to be endorsed by the ACC and Page & Turnbull and approved by the City of Palo Alto before any are implemented. Due to the losses of original building material in Building 2, we propose to preserve an original 16 feet wide concrete block wall located mid-point along its east wall. This wall is structurally deficient and per the permitted plans was to be replaced with one having identical appearance. However, we can retain the original material and character of this Eichler wall. We will construct a new structural wall to the north and conceal this new wall behind one of the proposed glass-to-wood exterior revisions described above. V. Proceeding with Construction of the Historic Buildings and Project Since the previously approved construction procedure for Building 2 has not been compromised, a rehabilitation approach under the Secretary’s Standards will continue to be taken on Building 2. The scope of work described in previously approved permit drawings will be adhered to following our receiving City and ACC approvals. Lee, page 6 We recommend that the existing elevations in the previously approved permit set be updated to indicate areas of removal and replacement of existing materials, and in accordance with any approved revisions. All proposed removal and replacement should be clearly indicated on red mark-up, revised permit elevations, reviewed by Page & Turnbull and approved by the City and ACC before the contractor proceeds. All removed and salvaged materials will be sorted and stored on site to give Page & Turnbull and the City officials an opportunity to inspect the materials. The permitted plans indicate that all existing Building 2 structural elements including columns, footings, and Glulam beams are intended to remain in place, and reinforced as necessary. As changes are made during construction to accommodate the existing conditions, we recommend that the contractor and project sponsor consult with Page & Turnbull and the City of Palo Alto before proceeding with any work that does not conform to the permit set. On November 5, 2012, Page & Turnbull submitted the enclosed Protocol and Specifications for Salvage, Selective Demolition and Protection to the City that details the procedure for the documentation, notification, salvage, protection, selective demolition, and approvals by the City and Page & Turnbull necessary to move forward with the construction of the historic buildings. On January 10, 2013, Dennis Backlund recommended approval of the Protocol and Specifications to the Director of Planning. If the measures described above are adhered to, we are confident that the reconstruction of Building 1 and the rehabilitation of Building 2 can be completed efficiently and within the parameters of the City’s permitting process and the requirements of the EIR. We believe that this will result in the successful rehabilitation of the Edgewood Shopping Center. Sincerely, J. Gordon Turnbull, FAIA Principal Enclosure: Protocol and Specifications for Salvage, Selective Demolition and Protection Page & Turnbull Edgewood Plaza January 9, 2013 Salvage, Protection, Demolition 1 PROTOCOL AND SPECIFICATIONS FOR SALVAGE, SELECTIVE DEMOLITION AND PROTECTION PART 1. GENERAL Purpose: The rehabilitation of Building 2 and the reconstruction of Building 1 under the Secretary of the Interior’s Standards for Rehabilitation. Preface: These specifications are submitted to owner Ho Holdings No. 1, LLC (the “Owner”) and Owner’s contractor (the “Contractor”) as guidelines for ongoing reconstruction and rehabilitation work on Buildings 1 and 2 of Edgewood Plaza Shopping Center in Palo Alto, California (the “Project”). As Owner’s consultant, Page & Turnbull (the “Historic Preservation Consultant”) has reviewed the Project’s permit drawings but is not a part of the Project’s architectural team that prepared the drawings and is not submitting these specifications as formal construction documents. These specifications are for guidance only. The City of Palo Alto requires the project applicant to incorporate these specifications into all construction documents. Section 1.4(B) of these specifications pertains to both Buildings 1 and 2. All other Sections of these specifications pertain only to Building 2. In general, any proposed construction activity for Buildings 1 and 2 that is not in compliance with the permit plans should be reported by the Contractor or Owner to the Historic Preservation Consultant and the City of Palo Alto for review and approval prior to commencing work. All directions for Building 2 are set forth in permit plan sheet T0.4 “ARB Conditions of Approval” and sheet A4.2.1 “Retail Bldg. #2 Exterior Elevations.” If any proposed construction activity for Building 2 is not in compliance with sheets T0.4 or A4.2.1 then the Contractor shall receive written approval from the Historic Preservation Consultant and the City of Palo Alto prior to commencing work. 1.1 SUMMARY This Section includes the following: A. Demolition and removal of selected portions of building or structure as shown on the permit plan drawings. B. Salvage of existing items to be reused as shown on the drawings. 1.2 REFERENCES U.S. Department of the Interior, National Park Service: The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings. 1.3 DEFINITIONS Historic Fabric: Architectural and structural materials and finishes constructed during the buildings’ Period of Significance. Most, but not all, historic fabric is identified on the permit plan Page & Turnbull Edgewood Plaza January 9, 2013 Salvage, Protection, Demolition 2 drawings. It is the intent of this Section and this Project to maintain and restore as much historic fabric as possible. 1.4 SUBMITTALS A. Photographs of Existing Conditions of Building 2 Prior to commencement of selective salvage, demolition and protection work for Building 2, submit photographs of existing damage on surfaces that might be misconstrued as damage related to selective salvage, demolition and protection operations. B. Samples and Mock-ups 1. Samples of exterior materials for Buildings 1 and 2: Clearly label samples of all replacement exterior materials and submit photographs and samples as required by the Historic Preservation Consultant for approval prior to their installation. Such exterior materials may include concrete block, windows and window frames, new storefronts, plaster and stucco finish, Glulam beams, wood wainscot, and any other exterior replacement materials. 2. Mock-ups of Buildings 1 and 2: After acceptance of the exterior materials and proposed method of reconstruction, repair or refinishing, a representative sample area shall be reconstructed, repaired or refinished. Obtain acceptance of the mock-up from the Historic Preservation Consultant before proceeding with remainder of the procedure. C. Quality Control If alternative methods and materials to those indicated on the permit plans are proposed for any phase of work, provide written description to Historic Preservation Consultant and City of Palo Alto for review and approval prior to commencing work. 1.5 PROJECT CONDITIONS A. Required Care in Selective Salvage, Demolition and Protection operations 1. The work seeks to preserve historic fabric and to protect, salvage and reuse selected building materials. 2. Building materials shall be considered fragile and must be removed, restored, modified and handled with care. Historic materials damaged during selective salvage and demolition operations may not be available for replacement; to remedy such damage repair and restoration shall be required. Protection of existing materials and items is of great importance. 3. Contractor shall be responsible for restoration of materials and finishes damaged during selective salvage and demolition activities. Where damaged materials and/or finishes are beyond repair or restoration, Contractor shall be responsible for replacement in kind. The City of Palo Alto shall be notified of damage to materials and finishes and the plan for replacement prior to the removal of damage materials and finishes. B. Selective Removal and Salvage Page & Turnbull Edgewood Plaza January 9, 2013 Salvage, Protection, Demolition 3 1. Materials or items indicated on the permit plans to be salvaged shall be removed with care and stored in a designated storage area or facility. The City shall approve any materials or items proposed to be removed. 2. Each material or element indicated to be salvaged shall be carefully crated and packed to prevent damage during transportation and storage. No salvaged materials shall be removed from the site or altered without City approval. C. Protection 1. Protection: Construct temporary barricades and other forms of protection as may be necessary to fully protect existing building and all existing materials and items to remain. 2. Cover and protect existing materials when demolition work is performed in areas where existing materials have not been removed. 3. Cease operations and notify Owner and Historic Preservation Consultant immediately if safety of structure appears to be endangered; take precautions to properly support structure. Do not resume operations until safety is restored. D. Existing Conditions Notify Historic Preservation Consultant and City of Palo Alto of discrepancies between existing conditions and Drawings before proceeding with selective demolition. Page & Turnbull Edgewood Plaza January 9, 2013 Salvage, Protection, Demolition 4 PART 2. PRODUCTS 2.1 MATERIALS A. Verify with Historic Preservation Consultant and the City of Palo Alto the extent of materials to be retained prior to beginning selective demolition. B. Maintain possession of materials being removed unless otherwise noted. C. Carefully remove, store, and protect materials indicated for reinstallation; where stored materials are damaged, repair to original condition or replace with new undamaged materials. Notify City of Palo Alto prior to discarding and replacing any damaged materials. 2.2 STORAGE AND HANDLING A. Every effort must be made to use and reuse materials that are original to the structure. When removed from their rightful place, these materials must be stored under cover inside the building or on the site where they cannot be damaged. B. Salvaged materials and items shall be stored under cover inside the building or on the site where they cannot be damaged. C. If salvage material is to be reused, treat it as new or original material with regard to its storage. 2.3 PROTECTION AND SALVAGE MATERIALS A. All necessary precautions shall be taken to protect all parts of the building not being repaired from effects of the work. B. Provide protection against the spread of dust, debris and water at or beyond the work area by suitable enclosures of sheeting and tarpaulins. C. Provide masking or covering on adjacent surfaces. Secure coverings without the use of adhesive type tape or nails. Impervious sheeting that produces condensation should not be used. D. Scaffolding, ladders and working platforms, required for the execution of this work should not be attached to the building. Page & Turnbull Edgewood Plaza January 9, 2013 Salvage, Protection, Demolition 5 PART 3. EXECUTION 3.1 EXAMINATION A. Survey existing conditions and correlate with requirements indicated to determine extent of selective demolition required. B. Inventory and record the condition of items to be removed and reinstalled and items to be removed and salvaged. 3.2 PROTECTION A. Protect all elements that are to remain and are exposed during selective salvage, demolition and rehabilitation operations. B. Construct temporary protection at existing elements indicated to remain, to prevent damage to or marring of materials and items. Protection shall be of required size and thickness to withstand impact from falling debris, rolling equipment and objects; residue and droppings from all construction related activities. C. Protective materials shall not be anchored directly to the item being protected. Prevent direct contact between protective assemblies and existing elements or materials by use of spacers, corrugated cardboard, quilted pads, kraft paper, non-moisture retentive padding, or other adequate means. For Plaster, Stucco and Wainscot: provide hard barrier protection to prevent damage from construction activities. 3.3 SALVAGE AND REMOVAL A. Salvage and Removal: Where indicated on permit plan drawings to be ‘removed, salvaged and reinstalled’ and ‘removed and salvaged,’ carefully remove indicated materials and items, and store under cover inside the building or on the site where they cannot be damaged, or pack or crate for transport to storage area. Maintain any storage area for the duration of the Project. Storage areas and methods of storage shall be approved by the City. B. Removal and Demolition: Demolish and remove existing construction as indicated only after protection, catalog, documentation and salvage operations have been completed. Use methods required to complete work within limitations of governing regulations and as follows: 1. Proceed with selective salvage, demolition and protection systematically. 2. Neatly cut openings and holes plumb, square, and true to dimensions required. Use cutting methods least likely to damage construction to remain or adjoining construction. To minimize disturbance of adjacent surfaces, use hand or small power tools designed for sawing or grinding, not hammering and chopping. Temporarily cover openings to remain. 3.4 SELECTIVE DEMOLITION A. General: Demolish and remove existing construction only to the extent required by new construction as indicated on permit drawings. Use methods required to complete the work within limitations of governing regulations and as follows: Page & Turnbull Edgewood Plaza January 9, 2013 Salvage, Protection, Demolition 6 1. Neatly cut openings and holes plumb, square, and true to dimensions required. Use cutting methods least likely to damage construction to remain or adjoining construction. Use hand tools or small power tools designed for sawing or grinding, not hammering and chopping, to minimize disturbance of adjacent surfaces. Temporarily cover openings to remain. 2. Do not use cutting torches until work area is cleared of flammable materials. At concealed spaces, such as duct and pipe interiors, verify condition and contents of hidden space before starting flame-cutting operations. Maintain portable fire- suppression devices during flame-cutting operations. 3. Locate selective demolition equipment and remove debris and materials so as not to impose excessive loads on supporting walls, floors, or framing. B. Removed and Salvaged Items: 1. Clean salvaged items. 2. Store under cover inside the building or on the site where they cannot be damaged. C. Removed and Reinstalled Items: 1. Clean and repair items to functional condition adequate for intended reuse. 2. Store under cover inside the building or on the site where they cannot be damaged. 3. Protect items from damage during transport and storage. 4. Reinstall items in locations indicated. Comply with installation requirements for new materials and equipment. Provide connections, supports, and miscellaneous materials necessary to make item functional for use indicated. D. Existing Items to Remain: Protect construction indicated on permit plan drawings to remain against damage and soiling during selective demolition. When permitted by Historic Preservation Consultant, items may be removed to a suitable, protected storage location during selective demolition and reinstalled in their original locations after selective demolition operations are complete. 3.5 REPAIR Repair damage to adjacent construction caused as a result of selective demolition work. END OF SPECIFICATIONS ST . F R A N C I S D R I V E Existing Grocery Service Yard FFE (13.31) (Existing Retail) FFE (13.50) (Relocated Existing Retail) FFE (13.33) BLDG 1 BLDG 2 Vedic Center BAY S H O R E R O A D TRASH ST. F R A N C I S D R I V E T T T FRONT FRONT FR O N T M B-9 B-9 B-9 B-9 T 1 2 4 3 6 7 8 10 RE F . DW RE F . DW Signature Date Renewal Date 06-30-13 North 0 Scale: 1" = 20' 10 20 40 2 2 2 Edgewood Plaza Update Attachment E Please see below responses to Councilmember Holman’s questions regarding Edgewood Plaza. -----Original Message----- From: Karen Holman [mailto:kcholman@sbcglobal.net] Sent: Sunday, February 10, 2013 9:16 PM To: Tucker, Sheila; Williams, Curtis Cc: Keene, James; Stump, Molly Subject: Item 12 - Edgewood questions I have the following questions on this item: 1) In the Draft Motion, #4 it states "Allow continued development of the grocery store (Bldg 3) as the remainder of the project moves forward.” Can staff please explain/clarify what this means? Staff Response: Staff is proposing to allow the grocery store to be fully constructed and to open while the SEIR and PC amendment are being processed. 2) Draft Motion #5: Why is staff recommending the commencement of work on BLDG 2 as it would seem that some compensation for the demo of BLDG 1 could potentially be a higher level of preservation than previously identified? Staff Response: Staff believes that Building 2 can be rehabilitated as previously approved, subject to special protocols and inspections. A protocol for work on Building 2 has been developed by the applicant to guide work and to prevent what had happened with Building 1. Staff is also already working with the applicant to provide a higher level of historic preservation/enhancement, such as the installation of wood windows that replicate the very specific style of the existing windows on Building 2. The building would not be finaled until the FEIR and PC amendment are approved, but staff does not believe that extensive changes to the building can be accomplished unless it is demolished, which of course is to be avoided. The Council may direct otherwise, however. 3) Preparation of the SEIR: the staff report states that the original DEIR consultant is being engaged. Why is not Carey & Company being engaged since the primary concerns on the site are historic resources with which Carey & Co. is most familiar as they were the historic consultants for the original DEIR? Staff Response: Carey & Company was hired as a subconsultant by Powers & Associates, the City’s CEQA consultant, to provide a peer review of the historic report on the shopping center that was prepared by the applicant’s historic consultant Page & Turnbull. Carey & Company has not been brought back as a subconsultant because the primary CEQA consultant has the technical expertise to prepare the SEIR with information submitted by Page & Turnbull. The analysis for this project is more straightforward because the building in question was demolished. There is no difference in opinion as there was previously about the historic significance of Building 2. If issues arise and Powers and Associates feels that further assistance is needed, Carey & Company or another consultant could be authorized as a subconsultant. 4) Has a peer reviewer been identified and if so is it Carey & Co. given the above reference? 4a) Has Carey & Co been consulted and provided any advisory on potential outcomes to date? Staff Response: Staff has not yet identified a peer reviewer and has not contacted Carey & Co. Carey & Co. will be one of the firms considered. Staff will select a consultant if the City Council authorizes construction of Building 2. A key component of the peer reviewer’s duties will be onsite monitoring. The chosen firm will be the one that can provide both the peer review of plans and monitoring, which may be a historic architect rather than a historic resources consultant. 5) Draft Motion #6: might there not be additional traffic improvements that could be included in addition to what was originally provided? I think there may have been additional conditions that the PTC had recommended that were not incorporated. Please advise. Staff Response: The approved Planned Community Ordinance required two additional traffic related improvements: 1) preservation of the vehicular access/driveway between the adjacent gas station and the project site and 2) modification of the traffic signal on Embarcadero Road at Saint Francis Drive to provide left turn signal phasing. The applicant is still required to provide those improvements. Staff is proposing that those improvements be constructed with the grocery store work to ensure safe circulation once the grocery store is in operation. Staff is not at this time proposing additional traffic improvements because there are no changes to the project that would create changes in traffic impact. The project as approved fully mitigates all potential traffic impacts. The only new environmental impact is the loss of the historic Building 1, so staff’s focus has been on potential historic impact mitigations. However, if additional traffic improvements are desired, it can be discussed and considered as part of the public benefits discussion of the PC Amendment process. 6) Draft motion #7: The relocation of the iconic and historic sign. Might not one compensation for the demo be to retain the sign in its original location, thus altering the site plan and historic integrity to a lesser degree? Staff Response: The approved relocation of the historic sign did not result in a significant historic impact. The new location, proposed for better visibility, is within a few feet of the original location in the same island and the applicant is proposing to preserve the historic elements of the sign. Historic Resources Board and Architectural Review Board review would be required for the final design of the sign face. The new location was approved as part of the PC ordinance. The City Council can require that the sign be placed back in the original location as part of the PC Amendment. However, staff believes that placing the sign back in its original location would not provide substantive compensation and would have negative impacts on visibility for the shopping center. By the way, I was by the site this afternoon, and the sign was down. It was still in place when last I noticed just a week or so ago. Has any authorization been given to move ahead and take the sign down esp given the inclusion of this consideration is on the agenda Monday night? Staff Response: The applicant was allowed to take down the sign for site improvements related to the grocery store following extensive discussion with staff, including the historic preservation planner. The applicant is required to retain and protect the sign onsite per the PC zoning. Architectural Review Board and Historic Resources Board hearings would be required prior to the installation of the rehabilitated sign. As stated in the staff report, the applicant has been allowed to proceed with site improvements needed for the grocery store construction and operation. 7) Would considerations referenced in questions 2, 5, & 6 above be part of the SEIR and thus giving the go ahead at this time be out of sequence? Staff Response: In accordance with CEQA, the SEIR is required for changes to the project that may result in new environmental impacts. The only change that will create new environmental impacts to the project is the demolition of Building 1, because the change will be a new building rather than a rehabilitated building. There are no changes currently proposed to Building 2, the sign or traffic impacts. Council certainly has the discretion to direct staff to hold back on other project elements if desired, but that is not staff’s recommendation. 8) The staff report references "mitigations" in a couple of places but there is no mitigation possible for the demolition of an historic building. Is staff referring to the demolition or to the situation? Staff Response: Although a demolished building cannot be mitigated, possible measures to mitigate the loss of the building will be studied and determined through the SEIR process. There may be additional measures that will strengthen the historic integrity of the site, although mitigation may still require a statement of overriding considerations for the loss of the historic structure. 9) The staff report indicates that the applicant has experienced costs due to their violations of the array of previous approvals and conditions and seems not to support imposing penalties due to this. How much have the violations cost the City in terms of staff time devoted to rectifying the situation to date and going forward? How far would the financial penalties go to cover the costs the City has experienced and is likely to experience...in other words, what is the level of financial penalty that can be imposed? Staff Response: Staff has spent a considerable amount of time on this project following the issuance of the Stop Work Order. As a PC amendment, all staff costs are charged to the applicant. The applicant will also fund the preparation of the SEIR and the additional review required for the historic buildings. If it is deemed that additional penalties are warranted, the City Council may require them. Options will be outlined in the staff report, but typical penalties relate to either double permit fees for re-permitting the building or fines for removal of a historic building (though the fee schedule only includes such a fine for demolishing historic buildings downtown). 10) The staff report indicates the array of violations: CEQA, approved plans, the PC zone and public benefits. Why has this not come to Council for direction and/or comment previously as the violations took place in September? All of the approvals required Council approval, so I am trying to understand how/why staff has been authorized to allow continuation of work on the site prior to coming to Council for direction. Staff Response: The project was not brought to the Council earlier to allow staff to work with the applicant to develop a full and accurate picture of what had happened and why, as well as to outline a potential path forward. Staff has allowed the applicant to proceed with work on the grocery store and related site work because the new market was not a historic resource, the market is a key public benefit, and there were no violations associated with this building. Staff has tried to balance the need to stop and evaluate the historic consequences of the Building 1 demolition with the community’s desire to see the site redeveloped in a timely fashion. Thank you. Karen