San Francisco planning and preservation commissioners press for clearer CEQA communication and earlier review of preservation alternatives

Planning and Historic Preservation commissioners met in their first joint hearing of 2019 to press planning staff for clearer, earlier communication on CEQA historic‑resource reviews and preservation alternatives. Commissioners said they often receive preservation analysis and staff letters too late in the EIR process to influence design or alternatives.

The meeting opened with a short technical overview from Allison Van der Sluis of the planning department, who summarized the CEQA historic‑resource review steps: determine whether a property is a historic resource, assess whether a project would cause a significant impact, and, where impacts are significant and unavoidable, prepare an EIR and preservation alternatives. “If the impact on the historical resource is significant and unavoidable, then it will require an EIR and preservation alternatives will be developed,” Van der Sluis said.

Commissioners from both bodies described a recurring pattern where ARC or staff discussions about alternatives are not effectively transmitted to the Planning Commission before entitlement hearings. “There’s a lot less information that the planning commissioners are getting relative to why we think these are appropriate or not appropriate relative to the alternatives,” one commissioner said during the meeting. Commissioners asked staff to provide fuller context—summaries of commissioner reasoning, majority and dissenting viewpoints, and earlier circulation of materials—to make HPC comments more usable to decision makers.

Several commissioners singled out recent projects as examples. They asked whether developers’ stated project objectives sometimes narrow alternative development in ways that make preservation appear infeasible. Lisa Gibson, environmental review officer, defended the department’s process and the separation between sponsor and EIR consultant work: “The planning department does direct the development of preservation alternatives and all alternatives… under CEQA, we’re required to develop alternatives that meet most of the basic objectives of the project, and then that also lessen or avoid the significant impacts of the project.” Gibson also said financial feasibility claims that justify rejecting preservation alternatives require documentation and often a second‑party peer review.

Deputy City Attorney Andrea Ruiz Esquide cautioned about the legal limits of HPC authority: the HPC may review and comment on environmental documents, but cannot formally ‘certify’ the adequacy of a draft EIR; certification is the Planning Commission’s role later in the process. She noted procedural guardrails in the city charter that differentiate advisory review from certification authority.

Staff offered concrete follow‑ups. Tim Frey of the planning department agreed to present an overview of the citywide survey program (which neighborhoods have context statements and where additional survey work is needed) and to provide timing and resource estimates for completing surveys. Staff also said they will explore producing transcripts of HPC hearings to help planning commissioners review debate without watching full meetings.

Commissioners and staff agreed on next steps: test process changes that would bring schematic preservation alternatives earlier in scoping, improve staff summaries of HPC deliberations (including majority/dissent notes), and explore more informal design workshops or subcommittees to allow deeper technical exchange. The meeting concluded with a commitment from staff to return with fuller materials on the citywide survey and to pilot earlier HPC involvement in the alternatives process ahead of future EIRs.