Certificate of Appropriateness Findings

SPMC 2.65(e)(10) is the section that decides whether a Certificate gets issued. The Commission cannot approve a Certificate unless every mandatory finding can be made, and at least three of twelve project-specific findings can be made. That structure — three plus at least three of twelve — is the analytical framework an application has to land in. A project that satisfies only the three mandatory findings cannot be approved.

All three of these must be made for any Certificate to issue:

1. General Plan consistency. The project is consistent with the goals and policies of the General Plan, including the Historic Preservation Element.
2. Article IVH consistency. The project is consistent with the goals and policies of the Cultural Heritage Ordinance — the Sense of Place, Physical Setting, Education, and Economic objectives stated in the purpose clause at SPMC 2.58B.
3. SPMC 2.65(e)(8) criteria consistency. The project is consistent with the criteria the Commission applies to alterations, demolitions, and relocation requests.

The (e)(8) criteria are themselves a substantial list, divided into two groups. Local criteria include the purpose of Article IVH; the South Pasadena zoning code; the city’s residential and commercial design guidelines (particularly for alterations and additions to historic residences and for new residential buildings in established neighborhoods); the historic and architectural value of the affected resource; the qualities of the improvement in relation to its surroundings; the impact of the project on the historic district; replacement-structure review for relocations and demolitions; reproducibility considerations for proposed demolitions; any applicable historic-architect or civil-engineer feasibility report (subject to peer review by a city consultant); the application materials and any architectural-historian evaluation; and any related certificate of economic hardship application.

National and state criteria include the Secretary of the Interior’s Standards for the Treatment of Historic Properties and the associated guidelines; the National Park Service preservation briefs, tech notes, and bulletins; CEQA and the Class 31 historical-resource exemption (CEQA Guideline § 15331); the State Historical Building Code (Title 24, Part 8); and Government Code § 65915 density-bonus restrictions for projects affecting California Register resources.

At least three of the following twelve must also be made. The findings are alternatives — different projects support different combinations:

1. The project removes inappropriate alterations of the past.
2. The project is appropriate to the size, massing, and design context of the historic neighborhood.
3. For an addition or enlargement, the project provides a clear distinction between the new and historic elements of the cultural resource or improvement.
4. The project restores original historic features in accordance with the Secretary of the Interior’s Standards.
5. The project adds substantial new living space (for example, a second story toward the rear of a residence) while preserving the single-story streetscape character.
6. The project enhances the appearance of the residence or building without adversely affecting its original design, character, or heritage.
7. The project will not adversely affect the character of the historic district in which the property is located.
8. The project will be compatible with the appearance of existing improvements on the site, with the new work compatible in massing, size, scale, and character-defining features to protect the historic integrity of the property and its environment.
9. The project is consistent with the Secretary of the Interior’s Standards and is therefore exempt from CEQA under Class 31.
10. Relocation as an alternative to demolition is appropriate, with sub-criteria including substantial CEQA evidence that no feasible alternative exists, compatibility of the new location with the resource’s character and use, retention of historic features after relocation, and a definitive series of preservation actions.
11. Demolition is appropriate, with sub-criteria including either substantial CEQA evidence (per Public Resources Code § 21080(e)) that no feasible alternative exists that would avoid significant adverse impact, OR an approved certificate of economic hardship, AND a replacement structure harmonious in size/massing/scale and contributing to the integrity of the historic district or neighborhood.
12. For a structure that poses an imminent threat and is unsafe to occupy: substantial evidence from at least two qualified sources (structural engineer, civil engineer, or architect) of severe structural damage; OR that no economically reasonable, practical, or viable measures could adaptively reuse, rehabilitate, or restore the structure; OR that a compelling public interest justifies demolition.

The Commission has to identify at least three of the twelve project-specific findings the project demonstrably satisfies. A design narrative for Major Project Review should be structured around the findings — explaining how the project meets the chosen findings with reference to specific design moves, materials, and Secretary of the Interior’s Standards compliance.

The “at least three” framing is important. A weaker application that only nominally touches one or two findings, or that relies on the mandatory findings alone, will not result in approval — the Commission cannot make findings that are not supported by the record.

Source: South Pasadena Municipal Code Chapter 2, Article IVH (Cultural Heritage Ordinance, Ord. No. 2315 § 2, 2017, amended Ord. No. 2400, 2025), §§ 2.58B, 2.65(e)(8), 2.65(e)(10). California Public Resources Code § 21080(e); CEQA Guidelines § 15331. Government Code § 65915. Title 24, Part 8 of California Code of Regulations (State Historical Building Code).