HomeMy WebLinkAbout11-19-19 Heritage Preservation Commssion Agenda PacketPage 1 of 2
HERITAGE PRESERVATION COMMISSION
SPECIAL MEETING
November 19, 2019
8:30 AM SPECIAL MEETING
Linda Callon Conference Room, City Hall | 13777 Fruitvale Avenue, Saratoga, CA
95070
1.Site Visit(s):
a.None
2.Call to Order:
3.Roll Call- Alexandra Nugent, Annette Stransky, Dr. Jo Rodgers, Marilyn
Marchetti and Rina Shah
4.Oral Communications
Any member of the public may address the Commission about any matter not
on the agenda for this meeting for up to three minutes. Commissioners may
not comment on the matter but may choose to place the topic on a future
agenda.
5.Approval of the November 12, 2019 meeting minutes.
6.New Business:
a.None
7.Staff Comments:
a.None
8.Old Business:
a.Heritage Lane and Heritage Resource Inventory
9.Commission Items
a.None
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10. Adjournment
In compliance with the Americans with Disabilities Act, if you are a disabled person and you need a
disability-related modification or accommodation to participate in this meeting, please contact the
City Clerk’s Office at (408) 868-1216 or dbretschneider@saratoga.ca.us. Requests must be made as
early as possible and at least one full business day before the start of the meeting.
Any recommendation made by the Heritage Preservation Commission may be appealed to the
Planning Commission within ten (10) days of the date of the decision. The appeal shall be taken by
filing with the Secretary of the Heritage Preservation Commission a written notice and filing fee within
ten (10) days of the date of the decision.
In accordance with the Ralph M. Brown Act, copies of the staff report, and other materials provided
to the Heritage Preservation Commission by City staff in connection with this agenda are available at
the office of the Community Development Department Director at 13777 Fruitvale Avenue, Saratoga,
California 95070. Any materials distributed by staff after the posting of the agenda are made available
for public review at the office of the Director at the time they are distributed to the Heritage
Preservation Commission.
CERTIFICATE OF POSTING OF AGENDA
I, Nicole Johnson, Planner II, for the City of Saratoga, declare that the foregoing agenda for the meeting of
the Heritage Preservation Commission was posted and available for public review on November 13, 2019 at
the City of Saratoga, 13777 Fruitvale Avenue, Saratoga, CA 95070 and on the City’s website at
www.saratoga.ca.us.
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HERITAGE PRESERVATION COMMISSION
REGULAR MEETING
Draft Minutes
November 12, 2019
8:30 AM REGULAR MEETING
Linda Callon Conference Room, City Hall | 13777 Fruitvale Avenue, Saratoga, CA
95070
1.Site Visit(s):
a.None
2.Call to Order: Chair Marchetti called the meeting to order at 8:31 AM
3.Roll Call-
Present: Chair Marilyn Marchetti, Vice Chair Dr. Jo Rodgers, Alexandra Nugent,
and Annette Stransky, Rina Shah
Absent: None
Staff: James Lindsay, City Manager, Debbie Pedro, Community Development
Director, Nicole Johnson, Planner II
Commissioner Shah left the meeting at 10:15 AM
4.Oral Communications
None
5.Approval of the October 8, 2019 and October 22, 2019 Minutes STRANSKY/
NUGENT MOVED TO APPROVE THE MINUTES FOR THE OCTOBER 8, 2019
MEETING. MOTION PASSED. AYES: NUGENT, SHAH, STRANSKY,
RODGERS, MARCHETTI. NOES: NONE. ABSTAIN: NONE. ABSENT: NONE
STRANSKY/NUGENT MOVED TO APPROVE THE MINUTES FOR THE OCTOBER
22, 2019 MEETING. MOTION PASSED. AYES: NUGENT, SHAH, STRANSKY,
RODGERS, MARCHETTI. NOES: NONE. ABSTAIN: NONE. ABSENT: NONE
6.New Business:
Item 5
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a.James Lindsay, City Manager-Heritage Lane and Heritage Resource
Inventory Discussion
•Mr. Lindsay discussed how the decision was reached at to
place both discussion items on the December 18, 2019 City
Council Agenda. Commission members asked questions and
discussed process and expectations for the City Council
meeting.
b. Memo from the HPC to City Council
•Discussion postponed.
7.Staff Comments:
a.Heritage Lane and Heritage Resources Inventory Discussion (City
Council meeting December 18, 2019).
•The HPC discussed their attendance at the City Council meeting
and holding special meetings prior to the City Council meeting
to prepare.
8.Old Business:
a.Point of Interest Markers (4)
•The commissioners discussed reviewing the language on their
own and forwarding the comments on to Commissioner
Stransky to complete the final language for review at the
December 10, 2019 HPC meeting.
b. Project Status Update
•None
c.Heritage Orchard Master Plan Update
•Chair Marchetti discussed that she has some revisions to make
to the document and will forward to the HPC for their review.
9.Commission Items
a.The commission discussed the Heritage Orchard Sign and the recent
Mill Act Application at 14475 Oak Place.
10. Adjournment
Chair Marilyn Marchetti adjourned the meeting at 10:42 AM.
Minutes respectfully submitted:
Nicole Johnson, Planner II
City of Saratoga
CITY OF SARATOGA
Memorandum
To:Mayor Cappello & Members of the Saratoga City Council
From:Nicole Johnson, Planner II
Date:March 11, 2019
Subject:Heritage Preservation Commission Work Plan – FY 19/20
On January 8, 2019 and February 12, 2019, the Heritage Preservation Commission (HPC)
held their regularly scheduled meetings. During the meetings, the HPC discussed their
upcoming 2019/2020 work plan.
1.Increase and update Heritage Resource Inventory-Continue their duty as HPC
commissioners to recommend and add residences, commercial structures, districts, and
lanes onto the Heritage Resource Inventory. This fiscal year, the HPC has so far added three
(3)sites to the Heritage Resource Inventory. There are currently 30 sites for consideration
to be included on the inventory.
2.Plaques/Point of Interest Markers - To properly recognize heritage resources and
properties of special interest in our City, the HPC would like to continue recommending to
Council special sites that warrant a Point of Interest Marker, providing plaques to
designated Landmark sites, andreinstate awarding plaques to sites that contain designated
Heritage Trees. This fiscal year, no Point of Interest Markers have so far been considered.
There are currently five (5) sites for consideration of a Point of Interest Marker. No plaques
have been considered for this fiscal year.
3.Public Outreach –Continue to participate in City events such as the Blossom Festival, Arbor
Day, Historic Preservation Month, the State of the City, and provide information about the
Commission at these events.
4.Continuing Education -The City of Saratoga is a Certified Local Government (CLG)
recognized by the State of California Office of Preservation (OHP). The CLG requires that all
commissioners receive annual training in Historic Preservation.
5.Heritage Lane City Code Amendment- Currently the HPC has the responsibility to review
and comment upon all applications for building, demolition, grading or tree removal
permits involving work to be performed upon or within a designated historic landmark,
heritage lane or historic district, and all applications for tentative map approval, rezoning,
building site approval, use permit, variance approval, design review or other approval
pertaining to or significantly affecting any heritage resource. City staff recently discussed
3
Item 8a
the duties of the HPC with the City Attorney for clarification. It was determined that the
HPC had the authority to only review building, demolition, grading or tree removal permits
that were upon or within the public right-of-way of the heritage lane portion of Saratoga
Avenue.
The HPC is requesting that City CodeSections 13-05.020 and 13-10.040be amended so that
building, demolition, grading and tree removal permits on private property adjacentto the
heritage lane portion of Saratoga Avenue also be required to be reviewed by the HPC
(Attachment 1).
6.Saratoga Avenue (Heritage Lane) Inventory-Review, update, video and inventory of all the
homes, fences and trees along the portion of Saratoga Avenue that is designated as Heritage
Lane, for potential to add to the City’s Heritage Resource Inventory. This project may require
a professional videographer.
7.Heritage Orchard Master Plan –As part of the City’s process in updating the Heritage Orchard
Master Plan, review the goals and polices in the 2001 Heritage Orchard Master Plan, update
accordingly and work on the long-term management of the orchard.
8.War Memorial Arch –Provide the required documentation to include Saratoga’s War
Memorial Arch located in Blaney Plaza, as part of the World War I Memorial Inventory Project
(WWIMIP) which is an online inventory of World War I memorials and monuments in the
United States and U.S. territories. The WWIMIMIP is working in partnership with the United
States World War I Centennial Commission. A Mobile Application has been established to
invite and enable public participation in locating, documenting, and providing a preliminary
condition assessment of all the World War I memorials and monuments in the United States.
9.Village Inventory-Review, update, video and inventory the buildings facing Big Basin Way for
historical significance.This project may require a professional videographer.
Notable Accomplishments in fiscal year 2018/2019
During fiscal year 2018/2019, in addition to placing three (3) properties on the Heritage Resource
inventory, the HPC reviewed five (5) projects along a Heritage Lane (Saratoga Avenue), and two (2)
planning applications. In addition, the HPC attended two (2) training webinars.
Budget Request
The Heritage Preservation Commission would like to request a budget allocation of $6,900 for the
FY19/20.
Request Requested Allocation
Two new point of interest markers (plaque, redwood posts and
installation)
$5,100
Training & Membership (California Preservation Foundation)$1,000
Preservation Month activities in May: (poster, speaker, photo
display-note photo display can be used year-after-year, etc.)
$800
Total $6,900 4
Current Commission Membership:
Name Term Ending Eligible for
Reappointment
Alexandra Nugent (Saratoga Historical Foundation rep)12/31/2020 No
Annette Stransky 12/31/2021 No
Jo Rainie Rodgers (Vice Chair)12/31/2020 Yes
Marilyn Marchetti (Chair)12/31/2019 No
Rina Shah 12/31/2022 No
Heritage Preservation Commission Powers and Duties (City Code Section 13-10.040)
The Heritage Commission shall be advisory only to the City Council, the Planning Commission and the
agencies and departments of the City and shall establish liaison and work in conjunction with such
authorities to implement the purposes of this Chapter. The Heritage Commission shall have the
following powers and duties:
a) Conduct, or cause to be conducted, a comprehensive survey of properties within the boundaries of
the City for the purpose of establishing the Heritage Resource Inventory. To qualify for inclusion in the
Heritage Resource Inventory, a property must satisfy any one or more of the criteria listed in Section
13-15.010 of this Chapter. The Inventory shall be publicized and periodically updated, and a copy
thereof shall be kept on file in the Planning Department.
b)Recommend to the City Council specific proposals for designation as a historic landmark, heritage
lane or historic district.
c)Recommend to the appropriate City agencies or departments projects and action programs for the
recognition, conservation, enhancement and use of the City's heritage resources, including standards
to be followed with respect to any applications for permits to construct, change, alter, remodel,
remove or otherwise affect such resources.
d)Review and comment upon existing or proposed ordinances, plans or policies of the City as they
relate to heritage resources.
e)Review and comment upon all applications for building, demolition, grading or tree removal permits
involving work to be performed upon or within a designated historic landmark, heritage lane or
historic district, and all applications for tentative map approval, rezoning, building site approval, use
permit, variance approval, design review or other approval pertaining to or significantly affecting any
heritage resource. The Commission’s comments shall be forwarded to the City agency or department
processing the application within thirty days after receiving the request for such comments.
f) Investigate and report to the City Council on the availability of federal, state, county, local or private
funding sources or programs for the rehabilitation and preservation of heritage resources.
g)Cooperate with county, state and federal governments and with private organizations in the pursuit
of the objectives of heritage conservation.
h)Upon the request of a property owner or occupant and at the discretion of the Heritage Commission,
render advice and guidance on the conservation, rehabilitation, alteration, decoration, landscaping
or maintenance of any heritage resource; such voluntary advice and guidance shall not impose any
regulation or control over any property.
i) Participate in, promote and conduct public information and educational programs pertaining to
heritage resources.
j) Perform such other functions as may be delegated to it by resolution or motion of the City Council.
5
Date:February 12, 2019
To:Saratoga City Council
From:Heritage Preservation Commission
Subject:Background information – Heritage Lane proposed ordinance amendment
In 2018, Saratoga City staff and the HPC conducted research on the history and definition of a Heritage
Lane. As a result of this effort to clarify HPC’s role regarding Heritage Lanes, the HPC recommends
that commissioners work with City staff to propose amendments to the City Code under section 13-
05.020 – Definitions and section 13-10.040 – Powers and duties.
The 1981 ordinance that created the Heritage Preservation Commission included the concept of a
Heritage Lane, as a way to “preserve the width and appearance of roads associated with Saratoga’s
earlier development.” Records from City Council meetings held that year include concern regarding
the “limited scope of ordinance with respect to Heritage Lanes” and that “Heritage Lanes were not
adequately defined by the ordinance.”
A July 26, 1991 memo to the City Council from then Planning Director Steve Emslie summarized the
characteristics of the Saratoga Avenue Heritage Lane as “two traffic lanes lined by old trees and
homes,” and further stated that “Measures such as maintenance of the street width and existing
vegetation as well as preservation of historic homes may be addressed in the ordinance to preserve
the historic street character.”
The amendment to the Heritage Lane ordinance proposed by the HPC exemplifies the City’s
commitment to preserving the historic character of a Heritage Lane, and is consistent with the DPR
for the Saratoga Avenue Heritage Lane, which notes that “properties on both sides of the street” are
“Related Features.”
Heritage Preservation Commission powers and duties include “Review and comment upon all
applications for building, demolition, grading or tree removal permits involving work to be performed
upon or within a designated historic landmark, heritage lane or historic district, and all applications
for tentative map approval, rezoning, building site approval, use permit, variance approval, design
review or other approval pertaining to or significantly affecting any heritage resource.” Historically,
the HPC and the Planning Department have taken this code to mean that the commission should
review and provide recommendations regarding structures adjacent to the lane, since properties
bordering the lane are “related features” and there are no buildings located on the road itself.
A June 12, 2018 memo from Sandy Baily, Special Projects Manager for the City of Saratoga, noted
“confusion and interpretation inconsistencies by City staff and the HPC regarding HPC’s role in
reviewing work along the heritage lane portion of Saratoga Avenue,” and that “staff has determined
that the City Code regulates HPC review for work done only within the public right-of-way of a
heritage lane, not beyond the limits of the right-of-way.”
An August 18, 2018 memo from the City Attorney’s office notes that since 2005, the HPC has reviewed
both Building Applications, as well as Planning Applications for development along the Saratoga
Avenue Heritage Lane, although it has primarily approved Planning Applications. It is unknown if there
were Building Applications along Saratoga Avenue that the HPC did not review. According to the City
Attorney, “the HPC has authority to review and comment on Building Applications as long as such
Attachment 1
6
applications concern work “upon or within” a heritage lane. With regard to Planning Applications, the
HPC has the authority to review and comment on such work to the extent such work is “pertaining to
or significantly affecting” any heritage lane.
An amended Heritage Lane ordinance will clarify the definition of a Heritage Lane and be consistent
with past HPC review practices. Residents whose houses border Saratoga Avenue will not face the
confusion of a perceived change in how Building and Planning Applications are reviewed and they can
continue to view their properties as being part of a Heritage Lane vs. being located adjacent to a
Heritage Lane.
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Community Development Department
City of Saratoga
13777 Fruitvale Avenue
Saratoga, California 95070
M E M O R A N D U M
DATE: June 12, 2018
TO: Heritage Preservation Commission (HPC)
FROM: Sandy L. Baily, Special Projects Manager
SUBJECT: HPC’s Role Regarding Heritage Lanes
Background
Due to the confusion and interpretation inconsistencies by City staff and the HPC regarding
HPC’s role in reviewing work along the heritage lane portion of Saratoga Avenue, the HPC
requested that staff research the matter and draft HPC policies or a City Code amendment to
clarify. Following is the background information regarding the matter.
In 1981, Saratoga City Council adopted an ordinance creating a heritage preservation
commission and establishing procedures for the designation, conservation and control of heritage
resources within Saratoga. This ordinance included the concept of heritage lanes. Prior to the
adoption of the ordinance, there was concern by some council members regarding the scope of
the proposed ordinance in respect to heritage lanes. Based on archived documentation, in 1981
the perceived community motives in advocating heritage lanes were as follows (Attachment 1):
Preserve the width and appearance of roads associated with Saratoga’s earlier
development.
Prevent widening and improvement to current city standards of certain roads, as currently
required in conjunction with new development and infill projects.
Discourage increased traffic on certain roads.
In 1991, the portion of Saratoga Avenue from Fruitvale Avenue to 14301 Saratoga Avenue was
designated by Ordinance as a Heritage Lane to help protect the street from being widened, which
would have resulted in the loss of the mature street trees (Attachment 2). The protection would
also regulate the construction of sound walls and fencing within the public right-of-way.
Discussion
In order to understand the role of the HPC in regards to heritage lanes, City staff fully analyzed
various sections of the City Code. Following are excerpts from the Heritage Preservation
Ordinance of the City Code regarding the regulations pertaining to heritage lanes. Section 13-
05.020(b) of the City Code defines a designated heritage lane as follows:
Designated heritage lane means a street, road, avenue, boulevard, pathway or trail
designated as a heritage resource pursuant to this Chapter.
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Section 13-10.040(e) of the City Code states that the powers and duties of the HPC is to review
and comment on work to be performed upon or within a heritage lane. Section 13 -20.010 of the
City Code states that a HPC permit is required for specified work within a designated heritage
lane. These three sections of the City Code do not discuss boundaries outside the limits of the
public right-of-way of a heritage lane. The only section of the City Code that regulates review
outside the boundaries of the public right-of-way of heritage lanes is 15-29.070 of the Zoning
Ordinance (Attachment 3). This section states that the HPC has purview to review fences which
exceed three feet in height which are within 50 feet of a right of way from a designated heritage
lane (unless exempted specifically by Ordinance).
Conclusion
Based on the information provided above, except for certain fencing, staff has determined that
the City Code regulates HPC review for work done only within the public right-of-way of a
heritage lane, not beyond the limits of the right-of-way. To ensure staff’s conclusion met the
intent of past Council’s expectation, staff contacted a former Council member who was on the
Council at the time of the creation of a portion of Saratoga Avenue as a heritage lane. The
former Council member confirmed that the goal was to protect the street width and the trees
within the public right-of-way. There was no expectation to review work beyond the limits of
the public right-of-way unless the property is already included in the City’s Heritage Resource
Inventory.
Attachments
1. 1981 Community motive notes regarding heritage lanes
2. Excerpts of City Council minutes for the meetings of October 21, and November 4, 1981
3. City Code Section 15-29.070 – Fences adjacent to heritage lanes
Attachment 1
Attachment 2
EXCERPT FROM CITY CODE
15-29.070 - Fences adjacent to heritage lanes.
In addition to the regulations set forth in Section 15-29.010 of this Article, fences adjacent to
a designated heritage lane shall comply with the following requirements:
(a) Fence permit. No person shall construct any fence which faces and is located within fifty
feet from the right-of-way of a designated heritage lane, and which exceeds three feet in height,
without first obtaining a fence permit from the Community Development Director. Application for
such permit shall be submitted and processed in the manner provided in Article 13-20 of the City
Code. If the Heritage Commission recommends issuance, the Community Development Director
shall issue the permit in accordance with those recommendations and any condition related but
not limited to the design standards set forth in subsections (c), (d), (e) and (f) of this Section and
pursuant to the process prescribed in Article 13-20.
(b) Supporting data. The level of detail of the supporting data required by Section 13-
20.030 shall be determined by the Community Development Director to allow adequate review of
the proposed fence.
(c) Setback. No fence which exceeds three feet in height shall b e constructed within the
required setback area fronting a heritage lane. This minimum setback may be required to be
increased to a maximum of fifty feet upon the finding that such increased setback is necessary to
preserve the historic qualities of the heritage lane.
(d) Color, material and design. Fences adjacent to a heritage lane may be constructed of
wood, stone, masonry, wrought iron or similar material. The design, color and materials of the
fence shall be approved based upon a finding that the fence will not adversely affect the historic
qualities of the lane and will be compatible with the design and materials of existing buildings on
the site and structures on adjacent properties.
(e) Height. The height of any fence adjacent to a heritage lane sha ll comply with the
regulations set forth in Section 15-29.010 of the City Code.
(f) Landscaping. The applicant shall landscape and maintain an area within the right -of-
way, parallel to and along the entire length of the exterior side of a fence in excess of three feet
in height and facing the heritage lane, in accordance with a landscape plan approved by the
Community Development Director. Such landscape plan shall provide for the planting of trees
and vegetation that are native to the area and require little or no maintenance. The landscape
plan may be approved by the Community Development Director upon the finding that the
proposed landscaping will effectively blend the fence with its environment and enhance the visual
appearance of the lane.
Attachment 3
Date: August 9, 2018
To: Heritage Preservation Commission and Community Development Director
From: Wittwer Parkin LLP Assistant City Attorney By Pearl Kan
Legal Analysis of Role of Heritage Preservation Commission regarding Heritage Lanes
The City of Saratoga’s Heritage Preservation Commission (HPC) has requested that the
Community Development Director obtain clarification regarding its role with regard to heritage
lanes.
In July 1991 the City Council of the City of Saratoga (City Council) adopted Ordinance
No. HP-19 which established a portion of Saratoga Avenue as a heritage lane. Section 2 of
Ordinance No. HP-19 provides that “The City will ensure the protection of the historic and rural
character of the lane through future land use decisions and development controls.”
In September 2002 the City Council adopted Ordinance No. 213, which designated
Austin Way as a heritage lane. Ordinance No. 213 also established that “Notwithstanding the
permit requirements established by Article 13-20 of the City Code, a permit shall be required
pursuant to that article only to the following actions occurring on or within 10 feet of Austin
Way: any paving, construction (such as fences, walls, or drainage) or removal or destruction of
any protected tree as that term is defined in section 15-50.050 of the City Code.”
In addition, City Code Section 15-29.070(a) authorizes the HPC to review permit
applications for fences “which faces and is located within fifty feet from the right-of-way of a
designated heritage lane, and which exceeds three feet in height.” While Section 15-29.070(a)
authorizes HPC review of permit applications for fences located within fifty feet of a designated
heritage lane, Ordinance No. 213 specifies that as to fences along Austin Way, such review is
limited to fences occurring on or within 10 feet of Austin Way.
The portion of Saratoga Avenue designated as a heritage lane pursuant to Ordinance No.
HP-19 and Austin Way are the only heritage lanes established under the City’s Heritage
Preservation Ordinance (Chapter 13 of the City Code).
City Code Section 13-10.040(e) establishes the Powers and Duties of the HPC. The HPC
has the authority to:
Review and comment upon all applications for building, demolition, grading or tree
removal permits involving work to be performed upon or within a designated historic
landmark, heritage lane or historic district, and all applications for tentative map
approval, rezoning, building site approval, use permit, variance approval, design review
Legal Analysis Regarding Heritage Preservation Commission and Heritage Lanes
Heritage Preservation Commission and Community Development Director
Page 2
or other approval pertaining to or significantly affecting any heritage resource. The
Commission’s comments shall be forwarded to the City agency or department processing
the application within thirty days after receiving the request for such comments.
City Code Section 13-10.040(e) delineates two types of work. The first category of work
includes “applications for building, demolition, grading or tree removal permits…” which can be
categorized as “Building Applications.” The second category of work includes “all applications
for tentative map approval, rezoning, building site approval, use permit, variance approval,
design review…” which for ease of reference can be categorized as “Planning Applications.”
The language concerning “upon or within” a heritage lane applies to Building Applications.
With regard to this first category of work, HPC has purview over such applications as long as
they involve work “upon or within” a heritage lane.
By contrast, the City Code does not expressly limit the purview of the HPC’s review to
“upon or within” a heritage lane for the second category of work, “Planning Applications.” The
Code authorizes the HPC to review and comment on “all applications for tentative map approval,
rezoning, building site approval, use permit, variance approval, design review or other approval
pertaining to or significantly affecting any heritage resource.” (City Code Section 13-
10.040(e) (emphasis added).) For such applications, the HPC has the authority to review the
impact of such Planning Applications pertaining to or significantly affecting a heritage lane (a
type of heritage resource).1
To the extent a Planning Application pertains to or significantly affects a heritage lane,
the City Code provides authority to the HPC to review and comment on such work. However, to
the extent that the work falls under a Building Application, the HPC is authorized to comment on
such application only if the work is “upon or within” a heritage lane.
Rules of statutory interpretation warn against construing a statute or ordinance in a
manner as to render deliberate word choices superfluous: “significance must be given to every
word in pursuing the legislative purpose, and the court should avoid a construction that makes
some words surplusage.” (Krupnick v. Duke Energy Morro Bay, LLC (2004) 115 Cal.App.4th
1026, 1029 (internal citations omitted).) This analysis which respects the limitations of review
for Building Applications to work “upon or within” a heritage lane avoids the erroneous
construction which would render those words mere surplusage. This analysis is also consistent
with the rule of statutory interpretation which requires giving the words of an ordinance their
plain, usual, ordinary, and commonsense meaning. (People v. Wright (2006) 40 Cal.4th 81, 92.)
1 “Heritage resource means any public or private property designated by the City, pursuant to this
Chapter, as a historic landmark, heritage lane, or historic district, and those properties listed on
the City’s Heritage Resource Inventory.” (City Code Section 13-05.020(h) (emphasis added).)
Legal Analysis Regarding Heritage Preservation Commission and Heritage Lanes
Heritage Preservation Commission and Community Development Director
Page 3
Generally, the City’s past practice has been consistent with the analysis above.
December 2005 was the first instance wherein the HPC reviewed a Building Application for the
demolition of a garage that was not located upon or within a heritage lane. From 2005-2017,
there have been a few additional instances wherein the HPC reviewed a Building Application for
work proposed outside of the heritage lane. Apart from these relatively isolated instances, the
HPC historically has only reviewed Planning Applications along the heritage lane portion of
Saratoga Avenue.
The manner in which City Code Section 13.10-040(e) distinguishes between “Building
Applications” and “Planning Applications” is also consistent with the language of Ordinance No.
HP-19: “The City will ensure the protection of the historic and rural character of the lane through
future land use decisions and development controls.” Work authorized under Planning
Applications, such as design review, use permits, and variance approvals qualify as “future land
use decisions and development controls” (as compared with work contemplated under Building
Applications, such a reroofing or demolition). Such Planning Applications also have a higher
likelihood of implicating the stated Ordinance purpose “to ensure the protection of the historic
and rural character of the lane.”
Based on the language of the 1991 Ordinance establishing a portion of Saratoga Avenue
as a heritage lane, the City’s past practices, and the powers and duties of the HPC set forth under
the City Code, the HPC has authority to review and comment on Building Applications as long
as such applications concern work “upon or within” a heritage lane. With regard to Planning
Applications, the HPC has the authority to review and comment on such work to the extent such
work is “pertaining to or significantly affecting” any heritage lane.
Page 1 of 2
MEMORANDUM
MEETING DATE: October 8, 2019
TO: Heritage Preservation Commission (HPC)
FROM: Nicole Johnson, Planner II
SUBJECT: Item 7c- Heritage Resource Inventory Letters and CEQA
requirements
CEQA, or the California Environmental Quality Act, is a statute that requires state and
local agencies to identify the significant environmental impacts of their actions and
to avoid or mitigate those impacts. CEQA applies to discretionary projects. A
discretionary project is one that requires the exercise of judgement or deliberation
by a public agency in determining whether the project will be approved. Some
common discretionary decisions include whether to grant design review or
conditional use of a proposed project.
Local governments (cities, counties, special districts) may be designated under CEQA
as “Lead Agencies” and are tasked under CEQA with carrying out the environmental
impact analysis (Initial Study, Mitigated Negative Declaration, and/or Environmental
Impact Report) for a proposed project.
Per Section 15064.5 of the CEQA Guidelines, local (city) historical resources (buildings,
structures, or archeological resources) are considered part of the environment and
are subject to review under CEQA. Therefore, adding a structure to Saratoga’s
Historic Resource Inventory, will likely trigger environmental review for a design
review application submitted to the city for such a structure. This may add
considerable time and substantial costs associated with the application, for the
property owners. Hence, to make sure that property owners are fully aware of the
legal requirements associated with being included in the Heritage Resource
Inventory, the City Council has provided direction that the process to place a
structure on the inventory follows a similar process as provided in Article 13-15 of
the Saratoga City Code for designation of a Historic Landmark, with regards to
notification to the property owners via a minimum of two (2) letters and being given
Page 2 of 2
the opportunity to object to the request of being placed on the Heritage Resource
Inventory.
Please see letter from the City Attorney regarding the Heritage Resource Inventory
letters and process included in Attachment 1.
Date: September 19, 2019
To: Debbie Pedro, Community Development Director
Nicole Johnson, Planner
From: Wittwer Parkin LLP, Assistant City Attorney by Pearl Kan
The City of Saratoga’s Heritage Preservation Regulations and
the California Environmental Quality Act
1. Introduction
Chapter 13 of the City of Saratoga’s City Code governs Heritage Preservation. The City
Code defines a heritage resource as “any public or private property designated by the City,
pursuant to this Chapter as a historic landmark, heritage lane, or historic district, and those
properties listed on the City’s Heritage Resource Inventory.” (City Code Section 13-05.020(h).)
The City Code defines the Heritage Resource Inventory (Inventory) as:
the City’s official inventory of heritage resources, as adopted and amended from time to
time by resolution of the Heritage Commission. A property may be listed on the Heritage
Resource Inventory without being designated pursuant to this Chapter as a historic
landmark, heritage lane or historic district.
(City Code Section 13-05.020(i).) Pursuant to City Code, while a historic landmark, heritage
lane, and historic district are necessarily heritage resources; a heritage resource may not be
specifically designated as a historic landmark, heritage lane or historic district.
Setting forth the power and duties of the Heritage Preservation Commission (HPC), City
Code Section 13-10.040 states that the HPC has the power and duty to “[c]onduct, or cause to be
conducted, a comprehensive survey of properties within the boundaries of the City for the
purpose of establishing the Heritage Resource Inventory.”
Pursuant to Sections 13-05.020(i) and 13-10.040 of the City Code, cited above, the City’s
practice has been for the HPC to add qualifying properties onto the Inventory as a heritage
resource from time to time.
2. City Code Affords Property Owners an Opportunity to Object to Designation of a
Historic Landmark, Heritage Lane, or Historic District
In the event that the HPC decides to recommend to City Council designation of a
“historic landmark, heritage lane or historic district,” the City Code requires the HPC to provide
the property owner with an opportunity to object to such proposed designation:
The Heritage Commission shall mail written notice of its intended recommendation to
each person whose name appears on the latest available tax roll of the County as owning
the property, or any portion thereof, which is the subject of the proposed designation.
Such written notice shall contain a complete description of the proposed designation and
shall advise the property owners that written objections to the proposal may be filed
within the Heritage Commission within forty-five days from the date of the notice.
(City Code Section 13-15.040(a).)
The City Code expressly provides a process whereby qualifying property owners can
voice written objections to a proposed designation of a historic landmark, heritage lane, or
historic district. However, the City Code is silent with regard to the process for a property owner
to object to their property being listed on the Inventory as a heritage resource.
3. The City Code Requires a Permit for Certain Changes to a Historic Landmark,
Heritage Lane, or Historic District
Article 13-20 of the City Code requires a permit for proposed changes to a historic
landmark, heritage lane, or historic district: “It is unlawful for any person to alter, demolish
remove, relocate, or otherwise change any exterior architectural features… of a designated
historic landmark…or to construct, alter…any property located within a designated heritage lane
or historic district…without first obtaining a permit to do so in the manner provided under this
Article.” (City Code Section 13-20.010.) The permit procedure set forth in Section 13-20.010
does not expressly apply to heritage resources that are not otherwise designated as a historic
landmark, heritage lane, or historic district.
4. CEQA Would Likely Treat All Listings on the Heritage Resources Inventory as a
“Historical Resource”
CEQA is a state law that requires public agencies, such as the City of Saratoga, to
conduct environmental review for discretionary project approvals that may result in a direct or
indirect change in the environment. A project that may result in substantial adverse change to
the significance of an historical resource is likely to require environmental review under CEQA:
A project that may cause a substantial adverse change in the significance of an
historical resource is a project that may have a significant effect on the
environment. For purposes of this section, an historical resource is a resource listed in,
or determined to be eligible for listed in, the California Register of Historical Resources.
Historical resources included in a local register of historical resources, as defined in
subdivision (k) of Section 5020.1, or deemed significant pursuant to criteria set forth in
subdivision (g) of Section 5024.1, are presumed to be historically or culturally significant
for purposes of this section…
Pub. Resources Code § 21084.1.
Subdivision (k) of Section 5020.1 of the Public Resources Code defines a “Local register
of historical resources” as “a list of properties officially designated or recognized as historically
significant by a local government pursuant to a local ordinance or resolution.” Because the
City’s Inventory includes a list of properties officially designated or recognized as historically
significant by the City by resolution, the Inventory most likely qualifies as a “local register of
historical resources” under CEQA.
Further, because the Inventory includes historic landmarks, heritage lanes, historic
districts, as well as all other heritage resources, CEQA would likely define all properties listed
on the City’s Inventory as “historical resources” under CEQA. While the City differentiates
between heritage resources that are not otherwise designated as historic landmarks and historic
landmarks, heritage lanes and historic districts; proposed adverse changes affecting the
significance of any heritage resource listed on the Inventory may have the potential to trigger
environmental review requirements under CEQA.
Environmental review under CEQA would likely require the City to identify potential
significant impacts to the historical resource as well as potential mitigation measures that would
avoid or lessen such impacts consistent with state law requirements. CEQA imposes both
substantive and procedural elements. While public agencies are entrusted with compliance of
CEQA, the public also enforces CEQA through litigation and the threat thereof.