On June 15, The Friends of 1800 wrote Bevan Dufty, Supervisor for District 8, concerning the need for a comprehensive survey of the Eureka Valley, demonstrated by the lack of environmental review and impending demolition of 70 Douglass Street. In the 1880's photo above taken, 70 Douglass stands at the center, its roof partially blurred. Additional photos can be viewed here.
FRIENDS OF 1800 LETTER TO BEVAN DUFTY
June 15, 2006
Mr. Bevin Dufty
President Board of Supervisors
City Hall, 1 Dr. Carlton B. Goodlet Place
San Francisco, CA 94102
Dear Bevan,
The exemption of 70 Douglass Street from environmental review, and the threatened demolition of this historic building, prompts me to stress the need for a comprehensive historic resource survey of District 8, including the Duboce Triangle, Castro, Eureka Valley, Noe Valley, Upper Market and Buena Vista neighborhoods.
With the exception of the area included in the Market/Octavia Area Plan, there are no known plans to survey the areas listed above. Most of building stock in these areas is comprised of structures that are 50 to 100 years old and represent the work of important architects, designers and builders of the period, and exhibit a wide variety of important architectural styles, comprising visually rich streetscapes that contribute to the areas identity, as well as neighborhood character.
In this case of 70 Douglass, you have an early 1883 Victorian residence that is sound housing and that displays a substantial degree of integrity. The Planning Department incorrectly determined that the subject building lacks integrity because the exterior is treated with asbestos shingles. However, the building appears to meet six or the seven criteria that are used to determine whether an historic building is eligible for listing on the National or California Registers. Therefore, we believe that the structure must be treated as an historic resource for the purposes of environmental review pursuant to the California Environmental Quality Act (CEQA). Additionally, the building is the oldest remaining building on the block, and one of the earliest residential structures in the Eureka Valley neighborhood. Arguably, it would qualify as a contributory resource to an historic district. Yet, this building was found exempt from environmental review, because it has not been designated as an historic resource because no survey work has been undertaken in this area to identify individual historic resources and historic districts.
The Planning Department's individual property evaluations do not provide as thorough an analysis of a property’s eligibility as would a comprehensive historic resources survey. Currently, the determination of whether a property is an eligible resource is an administrative action of the Planning staff with no opportunity for public input or oversight by the Planning Commission, or Landmarks Board. The Planning Department's administrative process for determining a property’s significance and the evaluation of alteration and demolition proposals is occurring without benefit of environmental review, evidenced by the numerous Categorical Exemptions issued.
This process relies on a set of environmental review procedures drafted by the Planning Department specifically for historic resources. These procedures, which have been contested by the historic preservation community, have not been sanctioned by a formal City adoption process.
The actions of the Department in this regard are cumulative and have resulted in serious negative impacts on the streetscapes, quality of life and the neighborhood character of District 8. Concerned neighbors can only be heard if they are fortunate enough to know that they have the right to file DR's or to appeal the Categorical Exemptions.
San Francisco neighborhoods deserve a more careful and sensitive planning process that fully considers the value of its architectural and historic resources. District 8 needs a comprehensive historic resources survey to identify the important buildings that should be protected, as well as those that are not deserving of such recognition. Spending our resources on an historic survey to provide information about the historic nature of properties would go a long way towards reducing neighborhood battles that take the form of DR’s and environmental appeals.
Please contact me should you have questions, or require additional information.
Sincerely,
Mark Paez, Chair
Friends of 1800
cc: Dean Macris, Bridget Maley, Charles Chase