Demolition Findings — Finding (xi)

SPMC 2.65(e)(10) requires three mandatory findings plus at least three of twelve project-specific findings before any Certificate of Appropriateness can issue. Finding (xi) is one of the twelve project-specific findings, and it is the finding the Commission must rely on to approve a Certificate for demolition of a cultural resource. Without a Finding (xi) determination supported by substantial evidence, demolition of a cultural resource is not approvable through the standard Certificate of Appropriateness path.

Finding (xi) is not a procedural checkbox. It is a heightened-evidence finding that reflects the city’s policy preference for preservation over demolition. The pillar entry on the findings architecture (linked below) describes the broader three-mandatory-plus-three-of-twelve structure; this entry covers the specific evidentiary content of Finding (xi).

Finding (xi) is structured around four sub-findings. Per the pillar, demolition is appropriate because of one or more of the following:

1. Substantial CEQA evidence (per Public Resources Code § 21080(e)) that no feasible alternative exists that would avoid a significant adverse impact on the resource;
2. The owner is approved for a Certificate of Economic Hardship per SPMC 2.65(e)(14);
3. The size, massing, and scale of the replacement structure is harmonious with other improvements and natural features that contribute to the historic district or neighborhood character; and
4. The replacement structure contributes to the integrity of the historic district or neighborhood.

The sub-findings are listed disjunctively — the Commission may rely on one path or another — but the demolition is approved only if at least one is satisfied with the supporting evidence in the record. In practice, demolition findings often rest on (a) or (b) combined with (c)/(d), since (c) and (d) address the replacement structure rather than the demolition itself.

Sub-finding (a) requires substantial evidence under CEQA — referenced to Public Resources Code § 21080(e) — that no feasible alternative exists that would avoid a significant adverse impact on the resource. “Substantial evidence” is the CEQA-defined standard, and the burden of producing that evidence sits with the applicant. The Commission’s role is to evaluate whether the evidence in the record satisfies the standard, not to develop the evidence itself.

Typical evidentiary content under sub-finding (a) could include feasibility studies analyzing rehabilitation alternatives, structural engineering reports addressing whether the existing structure can be retained, and documentation of why preservation alternatives are not feasible. The depth and quality of the evidence is what the Commission evaluates against the substantial-evidence standard.

Sub-finding (b) provides an alternative evidentiary path: the owner has been approved for a Certificate of Economic Hardship per SPMC 2.65(e)(14). A Certificate of Economic Hardship is its own discretionary process within Article IVH, with its own application requirements and findings. It is not a routine approval. An owner pursuing demolition through sub-finding (b) typically navigates the Economic Hardship procedure first, and brings the approved Certificate forward as the supporting evidence for the demolition Finding (xi).

Sub-findings (c) and (d) address the replacement structure rather than the demolition itself. (c) requires that the size, massing, and scale of the replacement structure be harmonious with other improvements and natural features that contribute to the historic district or neighborhood character. (d) requires that the replacement structure contribute to the integrity of the historic district or neighborhood. These sub-findings recognize that demolition of a cultural resource is consequential and ensure that what replaces it does not further compromise the surrounding context.

Demolition Major Project Review under SPMC 2.65(e) requires concurrent consideration of the replacement structure by the Cultural Heritage Commission and the Planning Commission. SPMC 2.65(e)(8)(A)(vii) requires that a building permit for the replacement structure be obtained before the cultural resource is relocated or demolished. This is the demolition-by-deferral safeguard built into the section: an owner cannot demolish first and figure out the replacement later. The replacement structure is part of the demolition application, and the building permit for the replacement gates the demolition itself.

Finding (xi) is the standard demolition-approval pathway under SPMC 2.65. Finding (xii) is a separate, narrower finding for cultural resources that pose an imminent threat and are unsafe to occupy. Under finding (xii), the Commission must rely on substantial evidence from at least two qualified sources (structural engineer, civil engineer, or architect) supporting one or more of three sub-findings: severe structural damage; that no economically reasonable, practical, or viable measures could adaptively reuse, rehabilitate, or restore the structure; or that a compelling public interest justifies demolition. Finding (xii) is the rarer of the two paths.

Finding (xii) operates alongside the SPMC 2.66 imminent-threat carve-out, but the two are different procedurally — Finding (xii) is a Commission finding made through the CoA process; SPMC 2.66 is a building-official-driven safety procedure. See the separate library entry on the Imminent-Threat Carve-Out for SPMC 2.66 mechanics.

The 45-year demolition-screening rule at SPMC 2.65(e)(3) is a separate procedure that operates upstream of Finding (xi). Where an owner proposes to demolish a building that is 45 years or older but not yet identified as a cultural resource, SPMC 2.65(e)(3) requires the property be evaluated for potential historic significance before demolition can proceed. The owner files a notice of intent to demolish, with an intensive-level Historic Resource Evaluation, replacement-project plans, and posting documentation.

The Commission then makes a determination. If the property is found not eligible at the federal, state, or local level, demolition proceeds through the city’s standard application process without further Article IVH restriction. If the property is found potentially eligible, the property is added to the Inventory and the proposed demolition becomes subject to the full SPMC 2.65(e) Certificate of Appropriateness procedure — at which point the Finding (xi) framework applies. The 45-year HRE process is a screening tool that determines whether Article IVH applies; Finding (xi) is the substantive demolition-approval finding once the property is on the Inventory.

Source: South Pasadena Municipal Code Chapter 2, Article IVH (Cultural Heritage Ordinance, Ord. No. 2315 § 2, 2017, amended Ord. No. 2400, 2025), §§ 2.65(e)(3), 2.65(e)(8)(A)(vii), 2.65(e)(10), 2.65(e)(10)(B)(xi), 2.65(e)(10)(B)(xii), 2.65(e)(14). California Public Resources Code § 21080(e); CEQA Guidelines § 15064.5(a).