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April 20, 2020 Planning Building & Code

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April 20, 2020 Planning Building & Code April 20, 2020 Planning Building & Code Enforcement: Juliet Arroyo (Historic Preservation Officer) Kara Hawkins (CEQA Manager) Rosalynn Hughey (Director) City of San Jose 200 E Santa Clara Street San Jose CA 95113 SUBJECT: PAC*SJ Response to NoP of Draft EIR for City National Civic Auditorium Loading Project, File No. ER19-058, APN: 259-42-023 Although PAC*SJ remains concerned with the City’s ongoing review of development projects that do not appear to meet Federal, State, County and even the City’s owns standards for what are deemed essential initiatives for its citizens who are under mandatory shelter in place orders, we are responding with comments regarding the City’s NoP for Draft EIR for the City National Civic Auditorium Loading Project. We do not believe this provides a sufficient opportunity to provide public input, but remain grateful for your 3/27/20 notice of the NoP Scoping Period for this project and for your consideration of our comments. For starters, PAC*SJ asks that this proposed project be evaluated for not only the obvious impact that would result from the proposed demolition of McCabe Hall but also its impact to the physically connected City Landmark Civic Auditorium and Montgomery Theatre. The Civic Auditorium, Montgomery Theatre and McCabe Hall represent three different elements of what is essentially one contiguous Historic building with an external street wall that is familiar to the public with its compatible and complimentary design elements that is the single most prominent feature of San Carlos Street from Market Street to the East, to the Park Avenue-to- San Carlos Street paseo to the West. It is important to note that McCabe Hall and the Civic Auditorium are supported operationally by the Parkside Plaza and Park Avenue-to-San Carlos Paseo. These two (2) additional elements are key to the function of the Civic Auditorium and McCabe Hall. These five (5) elements work together in such a way that a change to any one element impacts them all. The demolition of McCabe Hall to make way for a new parcel and loading dock access on San Carlos will not only destroy a building with extremely significant historic status in its own right, while extending that damage to the remaining complex. The damage will be significant and irreversible to the Civic Auditorium directly and to the Montgomery Theatre as well. PAC*SJ believes that this damage is 100% avoidable. To truly preserve these outstanding tributes to San Jose’s history and the people and events that make these buildings significant it will take an honest analysis of the historic impact to all three (3) parts of the McCabe Hall/Civic Auditorium/Montgomery Theatre, PLUS an honest analysis of the option of NOT demolishing McCabe Hall to create a loading dock path and new parcel for sale where the current Parkside Plaza exists, PLUS an honest analysis of what it would really take to preserve all or a portion of the Parkside Plaza while NOT eliminating scheduled access for Mid-to-Heavy Duty Vehicles to the Park Avenue-to-San Carlos Street Paseo for access to the Parkside Plaza. PAC*SJ asks that the scope of the analysis for Draft EIR for this project be broad enough to include the cumulative impact of the many other development projects and road and paseo changes occurring simultaneously. Specifically, PAC*SJ believes that the impact of this project must include consideration of the 200 Park Project, Museum Place II Project and the Paseo that is envisioned between Park Avenue and San Carlos Street. The analysis should also include an impact of the massing, height and type of future building that might take place in the new parcel that this project identifies along San Carlos Street. In addition to its inherent architectural significance of all of three buildings, PAC*SJ asks that the EIR take into account the degree to which the attached Civic Auditorium’s historical significance is magnified by its hosting of famous bands, organizations and corporations which have made history in this building. PAC*SJ believes that TSJ Staff, Concert Tour Historians, IATSE Foreman and Stagehands along with City Staff and others can provide a wealth of information on this. Note: To support bands, buses have always been required by musicians on tour. Semi- Tractor trailers are also used to move in/out staging/rigging and other audio visual and production equipment that is demanded by the musicians, organizations and corporations that produce concerts and evens at the Civic Auditorium. Secure satellite up/down links and productions trucks for the live broadcast of concerts and corporate or media/press events are also required (please note that satellite trucks typically require an unobstructed view of the Southern Horizon). All of these busses, tractor trailers and satellite trucks require an enclosed, secure area that is also open air for up/down links, and operation of generators that are often required to manage voltage levels during production, along with enhanced HVAC systems. All of these things are directly enabled by the current Park Avenue-to-San Carlos Street Paseo. PAC*SJ asks that this analysis include the related use and circulation patterns for pedestrians, performing arts clients, corporate clients, etc. This analysis should include interviews with touring bands, corporations such as Microsoft which have launched major products and services on the Civic Auditorium’s stage, satellite truck and video production operators, major media/network production teams, etc. Note: There is likely significant negative impact to trying to provide access to the Civic Auditorium’s loading dock from San Carlos Street. The City should not accept any of the research that was done on parking radius and elevation requirements for the San Jose Convention Center’s Expansion loading dock as it was flawed relative to providing access to large Semi-Tractor Trailers to the point that the loading dock is virtually un-usable. PAC*SJ asks that the report take into full account the input of all agencies with jurisdiction of this roadway. To better inform any subsequent analysis of alternatives, PAC*SJ specifically asks that the scope of the Historical Analysis include all positive (or negative) impacts that might result to the Landmark Civic Auditorium (with its McCabe Hall intact) by preserving as much of the Parkside Hall Plaza area that remains from the Museum Place II Project, AND retaining physical vehicular access to it via the Paseo between Park Street and San Carlos VERSUS demolishing the McCabe Hall expansion, bending/reducing the sidewalk area and adding an entrance way and gate to a loading dock ramp right next to the entrance of the Historic Landmark Civic Auditorium. According to Public Resources Code §15064.5(b), a project has significant effect on an historic resource (such as the Civic Auditorium) if it “causes a substantial adverse change in the significance” of that resource. Specifically, “substantial adverse change in the significance of an historical resource means 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.” As such, PAC*SJ asks that the analysis specifically state if substantial adverse impact will result to the Civic Auditorium by demolishing the Civic Auditorium’s McCabe Hall, to build a San Carlos Street gated access to the building’s prevailing loading dock and create a new parcel with a TBD future building. If a project for the space is not already contemplated, the analysis should assume the maximum height and massing allowed by City Code. Given that the marque and entrance to the Historic Landmark Civic Auditorium will be right next to all of this, it is hard to imagine how this project will not substantially damage the historical significance of the most prominent and familiar perspective of the Civic Auditorium on San Carlos Street. PAC*SJ requests that the historic review include a comparison of an option to use the existing Plaza and Paseo to access the Civic Auditorium’s loading dock versus creating a new entrance on San Carlos Street, and state with clarity which is the best option to preserve the Historic Landmark Civic Auditorium. PAC*SJ asks that the San José’s long standing Downtown Historic Design Guidelines https://www.sanjoseca.gov/DocumentCenter/Home/View/428 be used to provide relevant criteria for addressing new construction adjacent to historic landmarks. The Guidelines are applicable to this property, as it is within the downtown core area and adjacent to an historic landmark building. PAC*SJ asks that the report state in as much detail as is necessary, to what degree the project complies with the following guideline. PAC*SJ asks that no less than the following items be considered, individually and then in sum: The Guidelines include the need to retain and respect historic lot patterns on the street, and that any larger new buildings should be divided into smaller articulated building widths with multiple entrances that are similar in size and proportion to those seen traditionally; The Guidelines include the need to retain and respect the massing of historic buildings on a street. Respect the overall heights of historic buildings, street walls, districts and areas. The Guidelines include the need to add significantly higher new buildings, where appropriate, that are carefully sited in relationship to historic structures and predominant street ‘’walls;’’ The Guidelines include the need that building
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