Title
Application #PLN24-0256 - Alameda Point Historic District - Certificate of Approval to Replace Gutters on the “Big Whites” - Applicant: City of Alameda - Public hearing to consider a Certificate of Approval to allow the replacement of copper gutters with a different material at the “Big Whites,” located at 2765 Seattle Road, 2805 Seattle Road, 2765 Newport Road, 2801 Newport Road, 2815 Newport Road, 2825 Newport Road, 2775 San Diego Road, 2805 San Diego Road, 2835 San Diego Road, 2865 San Diego Road, 2795 San Pedro Road, 2815 San Pedro Road, 2835 San Pedro Road, 2845 San Pedro Road, 2875 San Pedro Road, 2805 Pearl Harbor Road, 2825 Pearl Harbor Road, 2845 Pearl Harbor Road and 390 West Essex Drive, which are the contributing buildings within the NAS Alameda Historic District’s residential subdistrict, and the existing copper gutters were identified as character defining features in the National Register nomination. General Plan: Main Street Neighborhood. Zoning: AP-MS, Alameda Point Main Street. CEQA Determination: Categorically Exempt pursuant to CEQA Guidelines Section 15301, Existing Facilities.
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To: Honorable Chairperson and Members of the Historical Advisory Board
EXECUTIVE SUMMARY
The Base Reuse and Economic Development Department (BRED) has applied for a Certificate of Approval to make modifications to the exterior of the former officers housing at the former Naval Air Station (NAS) now referred to as Alameda Point. In particular, the gutters and downspouts on 19 houses, made of copper that has acquired a patina over the past 80 years, have been the recent target of theft and require replacement where they are now missing, as well as preemptive replacement to avoid further risk of damage to property and injury to persons. BRED proposes to replace the existing copper gutters with a more common metal material and color (aluminum with a white finish or dark jade, which resembles patinaed copper formed in a replica shape (rectangular with square edges), that is less prone to theft (Exhibit 1). Staff recommends that the Board approve the request based on conformance with local preservation ordinance findings, consistency with national preservation standards, and environmental impact findings as set forth in this report.
BACKGROUND
The NAS Alameda Historic District, covering approximately 406.5-acres, is located within the former naval air station and contains 100 contributors including 99 contributing buildings and structures, and a designed landscape site. The historic district also has 58 non-contributing buildings, structures, and objects (Exhibit 2). The historic district encompasses the buildings and landscape that adhere to the original master plan and architectural design of an Interwar-era designed naval air station. The NAS Alameda Historic District is a local City of Alameda Historic Monument.
The subject copper gutters and downspouts are documented in the 2012 National Register Nomination Form as follows:
Character-defining features of the Officers’ Housing include exterior stucco surface, hipped roof form, two story core with one-story wings, attached garage, two-over-two double-hung wooden sash windows, remaining original garage doors, porch supports with circular cut outs, the column of windows to light the staircases of the Officers’ Houses, and remaining original copper gutters and downspouts.
It should be noted that some of the original copper gutters were already missing when the property was evaluated for inclusion on the National Register. As shown in the photographs, numerous gutters were previously replaced with white painted aluminum by the US Navy. In addition, as of today, over 47 gutters and downspouts have been stolen from several of the 19 Officer’s Houses (including the Admiral’s Residence) due to the value of the copper.
Copper theft is a significant and persistent issue at Alameda Point. Copper gutters, flashing, and wiring are routinely stolen throughout the area. Residential tenants have reported gutter thefts from their homes while they slept and express a significant concern for the neighborhood. Copper is two to three times as expensive as aluminum to replace, and, due to the value of copper, it is anticipated that this will continue to be major issue for Alameda Point, in spite of additional security measures executed by the property management team.
The Base Reuse and Economic Development Department (BRED) is requesting HAB approval of a Certificate of Approval to replace the existing copper gutters with a more common metal material and color (aluminum with a white finish or dark jade), which resembles patinaed copper formed in a replica shape (rectangular with square edges), that is less prone to theft. Should the request be approved, BRED plans to install the replica where they are now missing, as well as perform preemptive replacement of existing gutters and downspouts to avoid further risk of damage to property and injury to persons caused by theft activity. Staff recommends that the Board approve the request based on conformance with local preservation ordinance findings, consistency with national preservation standards, and environmental impact findings as set forth in this report.
DISCUSSION
Pursuant to AMC 13-21.5.b.1, the HAB shall determine whether to issue a certificate of approval for repairs and alterations of Historical Monuments, with or without conditions of approval, based on whether plans and specifications meet the standards established by the Historical Advisory Board and the Secretary of the Interior's standards for rehabilitation and guidelines for rehabilitating historic buildings. Thus, the prime consideration in this context is whether the replacement of the existing gutters will satisfy the Secretary of the Interior’s standards. The National Register criteria and guidelines and the CEQA review standards allow for compatible materials and designs as an acceptable strategy for maintaining the integrity of the resources, as more fully set forth below.
California Environmental Quality Act:
The California Environmental Quality Act (CEQA) statute (Public Resources Code) section 21084.1 establishes the premise that “[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.” Because they are listed in the nomination to the National Register, the relevant question is not whether the Big Whites are historical resources, but whether there would be a substantial adverse change to their significance.
CEQA Guidelines (California Code of Regulations) section 15064.5 outlines a detailed process for determining the significance of impacts to historical resources. Again, given that the Big Whites are a historical resource, the question is whether the proposal would result in the “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired.” (CCR 15064.5(b)(1))
CEQA Guidelines section 15064.5(b) continues:
(2) The significance of an historical resource is materially impaired when a project:
(A) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or
(B) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or
(C) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.
(3) Generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings… shall be considered as mitigated to a level of less than a significant impact on the historical resource.
(4) A lead agency shall identify potentially feasible measures to mitigate significant adverse changes in the significance of an historical resource. The lead agency shall ensure that any adopted measures to mitigate or avoid significant adverse changes are fully enforceable through permit conditions, agreements, or other measures.
The proposed gutter replacement project is intended to satisfy subsection (3) above, i.e. conform to the Secretary of the Interior (SOI) standards and guidelines. Those standards provide acceptable means of rehabilitating historic buildings, including when features are missing. CEQA Guidelines section 15126.4(b) also provides in relevant part that the same approach would be required to mitigate any identified impacts:
Mitigation Measures Related to Impacts on Historical Resources… Where maintenance, repair, stabilization, rehabilitation, restoration, preservation, conservation or reconstruction of the historical resource will be conducted in a manner consistent with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings… the project’s impact on the historical resource shall generally be considered mitigated below a level of significance and thus is not significant.
Secretary of Interior’s Standards:
The SOI Standards for Rehabilitation are as follows (Exhibit 3):
1. A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces and spatial relationships.
2. The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces and spatial relationships that characterize a property will be avoided.
3. Each property will be recognized as a physical record of its time, place and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.
4. Changes to a property that have acquired historic significance in their own right will be retained and preserved.
5. Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.
6. Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.
7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used.
8. Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.
9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.
10. New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
The SOI Guidelines for Rehabilitation allow replacement in kind as a recommended approach with the following discussion on roofs:
Designing and installing a new roof covering for a missing roof or a new feature, such as a dormer or a monitor, when the historic feature is completely missing. It may be an accurate restoration based on documentary and physical evidence, but only when the historic feature to be replaced coexisted with the features currently on the building. Or, it may be a new design that is compatible with the size, scale, material, and color of the historic building.
A similar discussion is provided regarding metals:
Replacing in kind an entire metal feature that is too deteriorated to repair (if the overall form and detailing are still evident) using the physical evidence as a model to reproduce the feature or when the replacement can be based on historic documentation. Examples of such a feature could include cast-iron porch steps or steel-sash windows. If using the same kind of material is not feasible, then a compatible substitute material may be considered.
In this case, many of the existing gutters have been removed by theft and, without intentional removal and replacement by the City, more of them are likely to be stolen. Without gutters and downspouts, the buildings are likely to be damaged by water intrusion as well as lose some of the character-defining elements of the streamlined design. Therefore, because staff believes the replacement would conform to the SOI standards and guidelines, no further environmental review is warranted in any case.
Conclusion
Staff have considered the safety concerns of residents, the likelihood of recurrent theft of copper material, and fiscal responsibility in making the recommendation to allow replacement with a different material. Staff believe the simple aesthetics of aluminum gutters in white color would be acceptable replacements to maintain consistency with others that have already been replaced in past decades, and the white finish on the houses, as well as a lower likelihood of theft. Therefore, staff believes the proposal is consistent with the criteria recommends the Board approve the Certificate of Approval with white aluminum as the preferred option.
ENVIRONMENTAL REVIEW
The proposed project is Categorically Exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15301, Existing Facilities. None of the exceptions apply. In particular, no impact to historic resources would occur pursuant to Section 15064.5, which outlines a detailed process for determining the significance of impacts to historical resources, and the proposal would not result in the “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” because the project follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings and the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings.
PUBLIC NOTICE AND COMMENTS
Property owners and residents within 300 feet of the project boundaries were notified of the public hearing and given the opportunity to review and comment on the proposal. Public outreach on this project also occurred on multiple occasions as part of the City’s deliberations on the optional approaches to the project. Prior comments addressed a desire to see the gutters retained and more security provided by the City to reduce theft. Any further comment letters will be forwarded to the Historical Advisory Board.
CLIMATE IMPACT
There are no climate impacts as the result of the proposed project.
RECOMMENDATION
Hold a public hearing and approve the Certificate of Approval as specified in the draft resolution (Exhibit 4).
Respectfully submitted,
Steven Buckley, Secretary to the Historical Advisory Board
Annie Cox, Base Reuse and Economic Development Department
Exhibits:
1. Documentation of Existing and Proposed Gutters
2. National Register Nomination Form (excerpt)
3. Secretary of the Interior’s Standards & Guidelines (excerpt)
4. Draft Resolution