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City Responds No to SHPO – Update 3: SHPO Also Says No

Application removed from agenda, Wellness Center may proceed.

Updated August 5, 10 a.m. with the results from the August 5 meeting.
Updated July 26, 9:50 a.m. with info about the applicant’s appeal.
Updated July 22, 10:30 a.m. with info about the application being pulled from the SHRC agenda.

Previous Alameda Post reports have covered the confusion over the application to nominate the US Maritime Service Officers Training School for inclusion in the National Register of Historic Places (NHRP) last month. The nomination was submitted by Carmen Reid [PDF], a neighbor of the affected property. Because of information submitted with the application, it was unclear if Reid was acting as an agent of the Alameda Architectural Preservation Society (AAPS) or independently. Statements from AAPS leadership supporting the nomination and public records conflict with AAPS assertions that Reid acted alone and listed the AAPS “for affiliation purposes only.” The Post previously reached out to Reid for clarification but received no answer.

Alameda Post- Aerial view shows the US Maritime Service Officers Training School in 1943
This 1943 photo shows the original peninsula that the campus resided on that was surrounded on three sides by water. The east and west shorelines have since been filled and developed with urban uses. US Department of the Interior photo.

If the nomination of the US Maritime Service Officers Training School site were to be approved, it would prevent the construction of a wellness center on McKay Avenue providing housing for 100 unhoused seniors along with additional services. The 100 units of housing would count towards Alameda’s Regional Housing Needs Allocation (RHNA). The project was approved in a 2019 vote by Alameda voters, and at the same time a competing proposal to preserve the area as open space was rejected by the same voters.

The nomination was removed from the State Historic Resources Commission (SHRC)’s agenda at the end of April, due to the overwhelming number of public comments on the completeness of the application. In the beginning of June, the nomination was added back to the agenda for the SHRC‘s August 5 meeting.

State guidelines for historic preservation

National historic preservation guidelines state that before a property can be considered for inclusion on the National Register, the State Historical Preservation Officer (SHPO) “shall notify the owner, the applicable chief local elected official, and the local historic preservation commission… Within 60 days of notice from the State Historic Preservation Officer, the chief local elected official shall transmit the report of the commission and the recommendation of the local official.”

The historic preservation guidelines further state: “If both the commission and the chief local elected official recommend that a property not be nominated to the National Register, the State Historic Preservation Officer shall take no further action” unless an appeal is filed.

City response

In response, the City Planning Department prepared a report [PDF], and Mayor Marilyn Ezzy Ashcraft wrote a letter [PDF]. Neither the letter nor the report provides any support for Reid’s current application to place the US Maritime Service Officers Training School on the NHRP. In fact, both the 27-page report and the three-page letter from the mayor document no substantial new information from previously rejected applications and list numerous factual errors and inaccuracies with the nomination. Both strongly urge the removal of the nomination of the US Maritime Service Officers Training School site.

Alameda Post - aerial view of Neptune Beach
The wing of a biplane adds interest this photograph of Neptune Beach taken in the early 1920s. The area later became McKay Avenue and the site of the US Maritime Service Officers Training School. Photo Calisphere.

The City’s report, authored by Alan Tai and Henry Dong of the Planning Department, begins by stating, “The nomination was reviewed by the City in April and found to have incomplete, inadequate, and erroneous information, and a previous evaluation for NRHP eligibility was also completed in 1996 which determined the site was not eligible for inclusion on the NRHP. The nomination, which SHPO describes as ‘revised’ and ‘new,’ does not provide any new information that has not already been considered by the Alameda Historical Advisory Board (HAB) and the City Council as part of the public record in 2021. The nomination contains numerous inaccuracies and distortions in the [sic] its portrayal of facts, particularly those regarding the proposed boundaries of the historic district as it relates to the original use of the site, as well as those relating to the integrity of the few remaining buildings, and attribution of the design of the complex to architects Harry Bruno and Joseph Esherick.”

Proposed site lacks integrity

The report details the history of Reid’s application and the City’s repeated responses to reject and oppose the proposed nomination. The City elaborates on several reasons that “the site does not retain sufficient integrity to be eligible for inclusion,” including the demolition of 18 of the original 25 structures, the removal of the central Parade Ground, the changes to the physical environment, arbitrary boundaries, and alterations to the buildings on the site.

Alameda Post - Current aerial view of the US Maritime Service Officers Training School site showing which buildings have been demolished.
This Google satellite view shows the current aerial of the site of the US Maritime Service Officers Training School along McKay Avenue with apartments and shopping center to the east side of McKay and parking lot and vacant land to the west. Photo from City of Alameda report.

The current application, submitted in early 2022, claims to include new and/or revised information for the City to review, but according to the City’s report, it is unchanged from a previous application considered in 2021. At that time, both the City and the HAB determined the nomination of the US Maritime Service Officers Training School property to be ineligible for inclusion on any historic register. The property also was the subject of another rejected nomination in 1996.

The report concludes: “Substantial evidence continues to demonstrate that the majority of the campus has been demolished and modified to the point that the remnants cannot physically convey its significance as a historic district. Both the [City of Alameda] and the chief local elected official have recommended that the site not be nominated to the NRHP. Therefore, the City requests that SHPO and the SHRC take no further action on the nomination as required by 54 U.S.C. Section 302504(c)(2)

Letter from the Mayor

Mayor Ashcraft’s letter, dated July 18, 2022, echoes the conclusion of the City report, asking the SHPO “…not to proceed with the US Maritime Service Officers Training School nomination.” She cites that the General Services Administration (GSA) and the SHPO previously determined that the site was ineligible for inclusion in the NHRP because of the site’s lack of integrity due to building demolition. She explains that following the determination in 2003, the GSA demolished additional buildings on the site, further diminishing the integrity and historical significance.

Alameda Post - former Government Buildings on McKay Avenue
These buildings are on the site proposed for the wellness center for 100 unhoused seniors on McKay Avenue. Photo City of Alameda.

She urged the SHPO to take no further action on the nomination, listing eight bullet points that document numerous factual errors and inaccuracies in the nomination. In her conclusion, the Mayor agreed with the Historical Advisory Board’s 2021 finding that the site is ineligible for NRHP listing.

The combination of the Mayor’s letter and the City’s report citing the previous decision by the HAB appears to satisfy the historic guidelines cited previously, directing the SHPO and SHRC to take no further action on the nomination of the US Maritime Service Officers Training School. This should mean the end of the nomination, allowing the wellness center project on McKay Avenue to proceed. However, at this time, the nomination is still listed on the SHRC agenda for its August 5 meeting. The Post will continue to follow the story and provide updates. Blogger Lauren Do continues to research the nomination and the history of the property and shares her findings on her site, Blogging Bayport.

Update: Lauren Do posted that the nomination has been removed from the SHRC agenda. The applicant will have 30 days to appeal.

Update 2: The applicant has filed an appeal, and the item is back on the August 5 agenda.

Update 3: The Office of Historic Preservation met August 5 to consider nominations. During the meeting, State Historic Preservation Officer Julianne Polanco stated the site had lost integrity to the degree that the site did not qualify for inclusion on the National Register of Historic Places. Carmen Reid’s application to place The US Maritime Officer School on the registry has been withdrawn by the SHPO.

Adam Gillitt is the Publisher of the Alameda Post. Reach him at [email protected]. His writing is collected at AlamedaPost.com/Adam-Gillitt.

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