CITY COUNCIL: Appeal of a Planning Commission's Decision Approving Demolition & Certification of Final EIR for Plaza del Mar Project

Meeting Date: 4 November 2008
Prepared by: Brian Roseth,
Planning

City Council
Agenda Item Summary

Name: Consideration of an appeal of a decision of the Planning Commission approving
demolition and the certification of the final Environmental Impact Report for a building at the SE corner of Dolores and 7th Avenue – the Plaza del Mar project. The appellant is Barbara Livingston.

Description: On September 10, 2008, the Planning Commission approved the Plaza del Mar project and certified an Environmental Impact Report (EIR). These actions have been appealed to the City Council for review.

Overall Cost:
City Funds: N/A
Grant Funds: N/A

Staff Recommendation: Hold the public hearing and continue action.

Important Considerations: The Plaza del Mar project will result in the demolition of a former bank building designed by Walter Burde and the construction of condominiums, apartments, commercial space and two levels of underground parking. The appeal challenges the Planning Commission’s action to certify the EIR and approve the project despite its significant environmental impact on the City’s visual quality resources. At the heart of the appeal is the interpretation of affordable housing statutes. In most circumstances, these statutes mandate approval of projects with affordable housing. The appeal challenges the Planning Commission’s determination that these statutes apply to the Plaza del Mar project and compelled project approval.

Decision Record:
City Council reviews on prior appeals: June 2006, February 2007 and July 2007.
Planning Commission action on September 10, 2008.

Reviewed by:


__________________________ _____________________
Rich Guillen, City Administrator Date


CITY OF CARMEL-BY-THE-SEA
DEPARTMENT OF COMMUNITY PLANNING AND BUILDING
STAFF REPORT
TO: MAYOR MCCLOUD AND CITY COUNCIL MEMBERS
THROUGH: RICH GUILLEN, CITY ADMINISTRATOR
FROM: BRIAN ROSETH, PLANNING CONSULTANT
DATE: 4 NOVEMBER 2008
SUBJECT: CONSIDERATION OF AN APPEAL OF A DECISION OF THE PLANNING COMMISSION APPROVING DEMOLITION AND THE CERTIFICATION OF THE FINAL ENVIRONMENTAL IMPACT REPORT FOR A BUILDING AT THE SE CORNER OF DOLORES AND 7TH AVENUE. THE APPELLANT IS BARBARA LIVINGSTON

I. INTRODUCTION
The Plaza del Mar project has been undergoing review since 2001. The planning process was arduous and complex for all parties. At the time of permit approvals, the project had been subject to review in an Environmental Impact Report, a Revised Environmental Impact Report, and three appeals to the City Council. Extensive public comment has been provided throughout the process. As approved, the project includes:
• Demolishing the existing building
• Constructing a two-level underground garage. One level of traditional parking is for on-site uses and the second level with valet parking is to be operated as a commercial business to serve off-site uses
• Five market-rate condominiums
• Two apartments restricted to low-income households
• 4,958 square feet of ground-floor retail
• Using a contemporary architectural treatment that does not conflict with the historic district across the street on Seventh Avenue

On 10 September 2008, the Planning Commission approved the Plaza del Mar project by taking action on the following permits and approvals:
• Certification of an Environmental Impact Report (EIR)
• Demolition Permit
• Use Permit for Underground Garage
• Use Permit for Commercial Space
• Condominium Subdivision
• Design Review Permit
• Coastal Development Permit

II. IMPORTANT ISSUES RELATED TO THE APPEAL
Environmental Review
In an appeal during the EIR process (November 2006), the City Council determined that the existing building on the property (designed by Walter Burde) is not historic.

The appeal hearings produced substantial testimony and evidence on visual quality issues in Carmel. When the Planning Commission reviewed the EIR for certification, it became apparent that the section on Visual Quality Resources was no longer valid. The EIR stated that the Burde building was inappropriate in Carmel because it was not consistent with historic styles nearby. The Commission directed staff to revise the EIR to explain that contemporary architecture was just as important as historic styles and that the Burde building, in particular, was important enough to qualify as an important visual resource. Therefore, its demolition would constitute a significant environmental impact. The only way to avoid this impact was to incorporate the building into the Plaza del Mar project design—a solution not feasible for the applicant.

Ultimately, the Commission accepted the project with the significant impact unmitigated and adopted Findings of Overriding Consideration. These findings are required by CEQA whenever a project is approved with significant environmental impacts. The Commission’s basis for the overriding findings were California laws (see next section) that mandates approval of projects if they include affordable housing, except under very limited circumstances. Essentially, the Commission believed that it had no choice; the law compelled approval.

Affordable Housing
Two California Statutes related to projects that include affordable housing were significant in the approval. Government Code Section 65915 requires the City to grant “incentives or concessions” requested by the applicant. These can include waivers from adopted ordinances and policies. In the Plaza del Mar project, 29% of the units are affordable to low-income households and this qualified the project for two incentives/concessions. The applicant requested (1) removal of two trees classified as significant and (2) the ability to include more condominiums and fewer apartments than the Zoning Code allowed. The Commission approved both requests.

The second statute (Government Code Section 65589.5) limits the City’s authority to deny projects that include affordable housing. Denial is permitted only when one of five specific reasons apply. The Planning Commission and staff determined that none of these reasons were relevant and, therefore, the project must be approved.

III. THE APPEAL
On 24 September 2008, an appeal was filed on two of the Commission’s actions (1) certification of the Environmental Impact Report and (2) the Demolition Permit.

Appellant’s First Basis for Appeal
The appellant argues that the California Government Code sections noted above did not compel the City to approve the project. The City retains discretion to deny a project if there are significant environmental impacts that cannot be mitigated. 65915 (e): Nothing in this subdivision shall be interpreted to require a local government to waive or reduce development standards if the waiver or reduction would have a specific, adverse impact, as defined in paragraph (2) of subdivision (d) of Section 65589.5 upon health, safety, or, the physical environment and for which there is no feasible method to satisfactorily mitigate or avoid the adverse impact.

According to the appellant, the Commission erred in adopting Findings of Overriding Consideration based solely on the statutory mandate to approve projects with affordable housing. The appellant asserts that section 65915, quoted above, preserves the City’s discretion to deny an incentive if it will have an adverse impact on the physical environment—even if the incentive does not directly cause the impact. If a requested incentive is essential to make the project feasible, and the project will result in an environmental impact, the City may deny the incentive. If the Commission wanted to approve the project it should have adopted overriding findings using some other basis—something the Commission specifically chose not to do.

The appellant further notes that Section 65589.5 does not conflict with this interpretation. It contains the following text that mandates CEQA compliance: 65589.5(e): ...This section also does not relieve the local agency from making one or more of the findings required by section 21081 of the Public Resources Code, or otherwise complying with CEQA.

Staff Notes:
1. The letter of Appeal cites California Government Code section 65917. Staff has verified with the appellant’s legal counsel that the correct section is 65915.
2. Section 21081 of the Public Resources Code is the section that requires adoption of findings of overriding consideration when a project is approved with significant, unmitigated adverse impacts.

Appellant’s Second Basis for Appeal
The letter of appeal states “The appellant further appeals the determination that there are no impacts to historic resources; the EIR’s conclusions are not based on substantial evidence”.

Staff Comment on the Second Basis for Appeal
The appellant submitted no argument to support this claim.

IV. RECOMMENDATION
The appeal is based on the interpretation of three statutes that are intertwined. At the time this Staff Report was prepared, staff had received the initial letter of appeal but no supplements. Rebuttal arguments from the applicant’s legal counsel also were not available. Staff recommends that the Council receive written and oral presentations from both the appellant and the applicant, then continue the appeal hearing for one month. This will allow the City Attorney and staff to review the full body of testimony and legal analysis and make a more informed recommendation for Council action.

Plaza del Mar Project
Findings for Decision on the Environmental Impact Report
Amended and Adopted by the Planning Commission 9/10/08
I. FINDINGS OF FACT
1. The project site is a 16,000 square foot parcel of land located in the Service Commercial Land Use District. Existing improvements on the site include a building constructed in 1972 and a paved parking lot.

2. On 9 September 2001, the project applicant filed an application for development of this site. The project includes full demolition of all site improvements, construction of a two-level underground garage, construction of a floor at street grade to be occupied with a mix of commercial shop spaces and residences plus a top floor level with residences.

Evidence:
• Assessor’s parcel record showing the size and configuration of the site.
• Application materials showing existing and proposed improvements.
• Final EIR, page 1-1 describing the project scope.

3. Full approval of the proposed project requires issuance of a Demolition Permit, Tree Removal Permit, Conditional Use Permit, Design Review Permit, Coastal Development Permit and a Condominium Subdivision Map. Due to the scope of the project, the City required preparation of an Environmental Impact Report (EIR) consistent with the provisions of the California Environmental Quality Act (CEQA) prior to taking action on any permits needed to approve the project.

Evidence:
• CMC Title 17:
17.48.050 Trees.
17.30.010 Demolition.
17.14.050 Use Permit.
17.14.010 Design Review.
17.52.090 Coastal Development Permit.
• California Subdivision Map Act.

4. The City hired the firm of EIP Associates to prepare the EIR. Impacts identified in the draft EIR were:
Biology Impact BR-2: Vegetation removal may result in impacts to nesting birds. (Potentially significant)
Cultural Resources Impact CR-1: Excavation activities during demolition and construction may disturb previously unidentified cultural resources. (Potentially
significant)
Cultural Resources Impact CR-2: During excavation of the project site, the proposed project may encounter unidentified buried archaeological resources or human remains.
(Potentially significant)
Noise Impact NO-1: Construction activities associated with the proposed project could generate substantial temporary or periodic noise levels. (Potentially significant)
Noise Impact NO-2: Construction activities associated with the proposed project could generate or expose persons off site to excessive groundborne vibration. (Potentially significant)
Mitigations to reduce each impact to a level of less-than-significant were identified.

5. The Draft EIR was circulated for a 45-day public review and comment period beginning on 28 May 2004 and ending on 15 July 2004. The City’s Planning Commission held a public hearing during the comment period. During the comment period the City received comment letters from the following sources:

*Brian T. Congleton, American Institute of Architects (Monterey Bay Chapter)
*Kent L. Seavey
*Richard N. Janick
*Clive and Salley Anne Smith
*Enid Sales, representing the Carmel Preservation Foundation
*Richard F. Barrett

At the public hearings, testimony was received from the following speakers:
*Kent Seavey
*Richard Janick
*Marshall Hydorn
*Brian Congleton
*Ann Bell
*Richard Barrett
Don Kramer
Alan Hewer
*Julie Culver
John Mandurrago-Applicant
Several comments both oral and written (identified above with an asterisk), questioned the determination that the bank building was not historic.

Evidence:
• Draft EIR 5/28/04.
• Planning Commission Minutes dated 7/14/04.
• Comment letters.

6. After the close of the public comment period, EIP Associates prepared a Final EIR. As required by CEQA, the Final EIR responded to each comment received during the 45- day public comment period. A (draft) Final EIR was released in October 2005.

Evidence:
• draft Final EIR

7. The (draft) Final EIR reached the same conclusion as in the draft EIR—the building is not historically significant. Based on this evidence, City staff prepared a Preliminary Determination of Ineligibility for the Historic Resource Inventory. This action was appealed to the Historic Resources Board. The Board granted the appeal. The Board’s action was appealed to the City Council by the applicant. The City Council’s action was to reverse the Board’s action and to determine that:

The Palo Alto Savings and Loan Building (Bank Building) does not qualify as an historic resource. It shall not be listed on the Carmel Inventory of Historic Resources and shall not be considered an historic resource for purposes of any environmental review.

Evidence:
• Preliminary Determination of Ineligibility for the Historic Resources Inventory, dated 8/12/2005.
• American Institute of Architects, Monterey Bay Chapter appeal letter, dated 12/14/05.
• Historic Resources Board Minutes, dated 12/16/05.
• Letter of appeal submitted by the project applicant, dated 1/28/06.
• City Council Minutes for meetings dated, 6/6/06, 8/8/06, 10/3/06 and 11/7/06.
• Findings, evidence and conclusions in the Findings for Decision, adopted by the City Council, dated 11/7/06.

8. Text in the EIR discussing historic resources was revised accordingly. During the revision process it became evident that conclusions in the EIR regarding visual quality resources were no longer valid. At the historic resource appeal hearings testimony and evidence presented by professionals and lay-people recognized the existing building on the site as visually significant, even if it was not historically significant. The City Council adopted a finding regarding this issue:

The bank building is visually striking. It is an excellent representative of the Second Bay Area Tradition in architecture. It is modern in design and it reflects a more recent period in the City’s history. It contrasts with earlier historic styles of design and it adds to the architectural diversity of the City.

At the hearing, architects characterized it as heroic or monumental in design. There are few buildings in Carmel that share all of these qualities. (Finding #25 adopted by the City Council, 7 November 2006)

The visual quality impact has two aspects. First, as an example of contemporary architecture from the 1970’s, its loss would diminish the diversity of architecture in the City. Architectural diversity is of general benefit to the community and has been an important local issue. Second, the City would lose an individually significant building of great visual quality designed by an important architect. This is a specific benefit to the community.

If demolished, the first aspect can be recovered by constructing a new building that reflects its time and enhances architectural diversity. The second aspect of the visual quality impact cannot be recovered: once an architecturally important building is demolished, it is gone forever. Using the visual impact threshold already established in the 2005 Draft EIR, the Planning Commission identified this loss as a significant environmental impact (hereinafter called VQ-1). Mitigating this impact would require incorporating some or all of the existing building into the project design. On 13 December 2006 the Planning Commission added the following text to the EIR:

Visual Quality
VQ-1 Threshold of Significance: Loss of special character-defining features of the project setting that make it architecturally and visually distinctive.

The evidence submitted by professional architects at the appeal hearing, the determination by the City Council, the findings adopted by the Historic Resources Board and the Planning Commission’s own judgment, all support the conclusion that the building qualifies as having special characterdefining features that make it architecturally and visually distinctive. Upon demolition, the loss of architectural diversity can be mitigated; the loss of great architecture cannot. Therefore, the project would result in a significant impact on visual quality.

MITIGATION MEASURES. The following two mitigation measures address this issue. Implementation of either would reduce the visual quality impacts associated with loss of the building’s architectural and visual distinction to a less-than significant level. (LTS):

VQ-1.1 Incorporate the existing building into the design of the proposed project. This would probably require a significant reduction in the size of the underground parking garage so as to avoid excavating under the existing building.

VQ-1.2 Deconstruct the existing building, complete the underground garage, reconstruct the building and build the remainder of the project around it.

Evidence:
• City Council Minutes dated, 6/6/06, 8/8/06, 10/3/06 and 11/7/06.
• Findings, evidence and testimony documented in The Findings for Decision adopted by the City Council, dated 11/7/06.
• Planning Commission Minutes, dated 12/13/06, 1/10/07
• Staff Reports dated, 6/6/06, 8/8/06, 10/3/06, 11/7/06, 12/13/06 and 1/10/07.
• Historic Resources Board Minutes, dated 12/16/05 and 1/23/06.
• Draft EIR, October 2005.
• Final EIR (draft), December 2006

9. A second visual quality impact resulted from the similarity of architecture in the project to existing designs in the Historic Resource District across the street. This similarity would blur the boundary of the District and diminish its value. The Planning Commission identified this as a significant environmental impact (VQ-2). Mitigating this impact would require a redesign of the project using more contemporary architecture.

Evidence:
• Historic Resources Board Minutes, dated 1/23/06
• Planning Commission Minutes, dated 12/13/06 and 1/10/06.
• Staff Reports, dated 12/13/06 and 1/10/06.

10. On 10 January 2007, the Planning Commission reviewed the new text on visual quality issues, found it adequate and certified the EIR. On 1/11/07, one Commissioner filed a Request for Reconsideration for the Commission’s action on grounds that identification of a new significant impact required a recirculation of the EIR to allow for public comment. Since the impacts on visual quality were identified as significant impacts, certification was premature. On 1/16/07, the Commission reconsidered the issue, rescinded certification and directed staff to circulate the Revised Draft EIR with its new text discussing visual quality impacts.

Evidence:
Planning Commission Minutes for meetings dated 1/10/07 and 1/16/07.
Staff Reports, dated 1/10/07 and 1/16/07.
Request for Reconsideration, dated 1/11/07

11. On 24 January 2007, the project applicant appealed the Commission’s action to the City Council. On 6 February 2007, the Council heard the appeal, upheld the Commission and denied the appeal.

Evidence:
• Letter of appeal from the project applicant, dated 1/24/07.
• Staff Report to the City Council, dated 2/6/07.
• City Council Minutes for 2/6/07.

12. The Revised Draft EIR was recirculated for 30 days from 1 March 2007 to 1 April 2007. Due to an error in public notice, the comment period was extended to 10 May 2007. Public comments were received from the following:
• Enid Sales
• Monte Miller
• Clark Watkins
• Clive and Sally Anne Smith
• Mike Cate
• Niels Reimers
• Miriam Shikat
Following the close of the public comment period, the City prepared responses to comments for inclusion in a Revised Final EIR. The (draft) Revised Final EIR was released on 7 June 2007.

Evidence:
• Revised Draft EIR.
• Public Notices dated 3/1/07 and 4/1/07.
• Letters to interested parties dated 4/1/07.
• Comment Letters.
• Revised Final EIR (draft).

13. The Planning Commission reviewed the project and the EIR on 13 June 2007. The applicant presented testimony on why demolition of the existing building was required and why any alternative or mitigation that would save all or a portion of the building was infeasible. The applicant also stated his willingness to redesign the building using contemporary architecture and thereby avoid visual impact VQ-2. The Commission accepted the applicant’s argument regarding feasibility. The Commission also accepted the applicant’s pledge to pursue project design revisions to mitigate impact VQ-2. Without seeing the new design, or any issues it might raise, the Commission followed staff recommendations and certified the Revised Final EIR.

Evidence
• Revised Final EIR, dated 6/7/07.
• Planning Commission Minutes, dated 6/13/07.
• Staff Report dated 6/13/07.

14. On 3 July 2007 the City Council reviewed the Commission’s action and determined that certification should not occur until the final project design and all project permits were ready for approval.

Evidence:
• City Council Minutes, dated 7/3/07.
• Staff Report, dated 7/3/07.

15. In January 2008, the applicant submitted revised plans for the project using contemporary architecture, an increased amount of commercial floor area and adding two housing units restricted to occupancy by low-income households. These plans addressed land use, design and environmental issues (VQ-2). The revised design still required full demolition of the existing building on the property and, therefore, the significant environmental impact (VQ-1) resulting from demolition would still occur.

Evidence:
• Revised project plans.

16. The Commission reviewed these plans at a public hearing on 6/11/08, 7/16/08 and 8/13/08. It determined that only minor revisions to the design of the project were needed and that the EIR was ready for certification. Since no feasible alternative/mitigation existed to remedy the visual quality impact, project approval would require adoption of overriding findings. The Commission directed staff to work with the applicant on final revisions, prepare all permits for adoption and to draft a Resolution to Certify the EIR all for review and approval at the meeting of 10 September 2008.

Evidence:
• Planning Commission Minutes, dated 6/11/08, 7/16/08 and 8/13/08.
• Staff Reports, dated 6/11/08, 7/16/08 and 8/13/08.
• California Environmental Quality Act Guidelines Sections 15091, 15092 and 15093.

II. FINDINGS OF ANALYSIS FOR DECISIONMAKING ON THE EIR
17. During project review, the California Quality Act Guidelines require cities to consider environmental impacts classified as significant and to take one of the following three actions:
• Deny the project.
• Adopt feasible mitigation measures or a project alternative that eliminates or substantially lessens the significant impact.
• Determine that mitigating the significant effect is unavoidable and adopt findings of overriding consideration explaining why the project is being approved in spite of the significant effect.

Evidence:
• CEQA Guidelines Sections 15091, 15092 and 15093

18. California Government Code Section 65589.5 requires cities to approve projects that include affordable housing unless specific circumstances exist. None of these circumstances is applicable to the Plaza del Mar Project. Therefore, it is unlawful to deny the project (bullet #1, above) unless it is inconsistent with the City’s General Plan or Zoning. The Plaza del Mar project does conflict with two provisions of the City’s plans and ordinances (see findings and discussion in the Staff Report amended and adopted by the Planning Commission 9/10/08). However, these conflicts are overcome by California Government Code Section 65915 which requires the City to grant incentives/concessions to projects that include specified amounts of affordable housing.

Evidence:
• California Government Code Sections 65589.5 and 65915.
• Staff Reports, dated 8/13/08 and 9/10/08.

19. On 13 June 2007, the Commission determined that mitigating the Visual Quality impact is infeasible as defined in the CEQA Guidelines. This determination eliminates the second option (bullet #2 in finding 17, above) provided in the Guidelines for responding to significant impacts.

Evidence:
• Planning Commission Minutes, dated 6/13/07.
• CEQA Guidelines Section 15091(a)(3) and 15092(b)(2)(A).

20. For responding to significant environmental impacts, the remaining option provided in the CEQA Guidelines is to acknowledge the impact and approve the project with overriding findings. For the Plaza del Mar project the overriding finding is that because of the important benefit of providing affordable housing, California Statutes have removed the City’s discretion. The City is compelled to approve the project because it includes two units of housing reserved for low-income households. On 10 September 2008, the Planning Commission adopted all findings, herein, and a Resolution Certifying the Environmental Impact Report for the Plaza del Mar Project.

Evidence:
• CEQA Guidelines sections 15092(b)(2)(B) and 15093.
• California Government Code Section 65589.5.
• Planning Commission Minutes, dated 8/13/08 and 9/10/08.
• Staff Reports dated 8/13/08 and 9/10/08.
• Resolution Certifying an EIR for the Plaza del Mar Project, dated 9/10/08.
• All supporting Findings and Evidence, herein, and referenced herein.

Informational Report to the Carmel-by-the-Sea City Council
Regarding the Visual Significance of the Palo Alto Savings Building.
November 4, 2008

On behalf of the Board of Directors of the Monterey Bay Chapter of the American Institute of Architects, I am pleased to submit this informational report on the significance of the Palo Alto Savings Building (now the Homescapes Building), located at Seventh & Dolores Streets in Carmel.

We have presented portions of the information in this report for City Review in prior hearings, as part of the City’s consideration of the building as an historic structure.

Because of the building’s relatively young age (less than fifty years), the Council determined that the property did not comply with the exceptional standards for historic designation.

In the hearings, the AIAMB noted that the building is significant more in an architectural context than a historical one, and that historic designation did not provide the best representation of the building. However, at the time, historic designation appeared to be the best means of recognizing the importance of the building.

Now the Carmel City Council is considering an appeal of a project proposed for the Palo Alto Savings site, which would necessitate demolition of the existing building. This brings back into consideration the significance of the building, this time under the General Plan reference to preservation of elements of “visual significance”. The AIAMB Board feels that the architectural import of the building is exactly what the General Plan reference represents. The Palo Alto Savings building is a visually significant element in the Carmel Community for the following reasons:

1. It is Unique. While much of the Commercial District is comprised of buildings built between 1925-1950, very few new buildings were built after that time. Few buildings were added to the essentially “built-out” central zone after that time. During a period of extensive evolution of modern architectural design, extensively represented in other areas, only a few examples were added to the fabric of Carmel. The Palo Alto Savings Building is such a unique example.

2. It is architecturally significant. The building was designed by Walter Burde of Burde & Shaw Architects AIA. Mr. Burde was a well-known architect on the Monterey Peninsula and in central California. He received the national AIA Honor Award (the highest award bestowed by the AIA) in 1969, and was inducted as a Fellow in the AIA in 1987. In 1984, Mr. Burde was awarded the Stanton Award for Contributions to the Architecture of the Central Coast for Design. The Palo Alto Savings Building, designed in the Bay Region style (an outgrowth of the Arts and Crafts movement), is a rare example in Carmel of the style and of Mr. Burde’s fine work.

3. It is monumental architecture. In many cities and towns, the civic pride of the community is expressed by its public and commercial public-serving buildings. In Carmel, a village with pedestrian streets and quaint shops, only a few monumental buildings can be found, including Sunset Center, the library, the churches, and several banks. As representatives of the prosperity of the populace, banks have long been built in monumental style. Carmel’s monumental banks include the China Art Center on Dolores Street (built in the 1930’s as a bank), Olaf Dahlstrand’s Wells Fargo Bank on San Carlos Street, and the Palo Alto Savings & Loan building.

4. It supports and enhances Carmel’s architectural diversity. The concept of community diversity is noted throughout the zoning ordinance and design guidelines, as well as in the Local Coastal Plan. Carmel’s diversity has been threatened often by repetitive “cookie cutter” house designs and the emulation of traditional period designs in the commercial district. The Palo Alto Savings Building stands out from the sameness of its surrounding environs, helping to support and balance a diverse architectural representation of the community. Loss of the Palo Alto Savings Building would irreparably harm the balance of diversity in Carmel.

We submit this report regarding the Palo Alto Savings Building, asking that the Carmel City Council make a determination on the visual significance of the property based on a review of all of the information. The AIAMB Board does not feel it is our place to speak to other elements being considered in the appeal (including elements of state law, or of the proposed design). We feel it our responsibility as a professional board to provide this information of work of our profession for your review.

On behalf of the Board of the Monterey Bay Chapter of the American Institute of Architects, I thank you for your consideration.

Brian T. Congleton AIA

For the Board of Directors – Monterey Bay Chapter American Institute of Architects

Interior view – Palo Alto Savings & Loan Building - 1974

China Art Center – originally a bank in the 1930’s

Wells Fargo Bank – designed by Olaf Dahlstrand