Honorable Tucson Mayor and Council,
On behalf the Tucson Historic Preservation Foundation (THPF) and our thousands of members and supporters throughout Tucson and Pima County we are writing to outline our concerns regarding the proposed River Road and Campbell Avenue “Karma del Sol” project and formally object to the merged annexation and rezoning process.
Since 1985 THPF has been working to preserve Tucson’s unique cultural environment. After reviewing the proposal we believe this project will: 1) have a direct adverse effect on the historic resources of the Santa Catalina Foothills Estates and National Register of Historic Places listed St. Philip's in the Hills; 2) will damage the area’s distinct sense of place; 3) will destroy the rural feeling of the gateway to the old foothills and; 4) is fundamentally antithetical to decades of public investment and policy that has worked to preserve the unique identity of this part of our community.
Additionally, THPF is concerned that the multiple regulatory steps of the process have been bundled into a single Mayor and Council meeting to create parallel process for both annexation and rezoning. This bundled process is creating confusion and is undermining the opportunity for public and stakeholder participation.
The Catalina Foothills Estates was developed in the first half of the 20th century by John and Helen Murphey and architect Josias Thomas Joesler. The rural Sonoran desert environment and Joesler unique architecture attracted titans of American industry, famous writers and celebrities to Tucson. The Mayos of The Mayo Clinic, the Drexels/Goulds of Drexel University, Louise N. Grace of Grace Shipping Lines, and authors Walt Coburn and Erskine Caldwell were just a few of the prominent families and individuals who lived in the Catalina Foothills Estates.
To help recognize this cultural contribution Pima County lead the effort to develop a Multiple Property Documentation Form to assist with the National Register of Historic Places designation of buildings developed by the Murpheys designed by Josias Joesler. The effort to create this federally-recognized context took over a decade.
This investment in survey and context development has been part of a sustained effort by Pima County to recognize and preserve the historic resources within the proposed annexation site and the surrounding area. In 1982, after public outcry, Pima County paid for the relocation of a Joesler-designed building impacted by the realignment of River Road; this building is included in the proposed annexation.
St. Philip's in the Hills, designed by Joesler in 1936 was listed in the National Register of Historic Places in 2004 and is recognized locally as a significant cultural site and is also included in the annexation.
The Pima Prospers Comprehensive Plan Initiative, 3.6 Cultural Resources, specifically calls out conservation of resources in and around the proposed annexation in “Catalina Foothills Planning Area (9)”:
The area encompasses significant historic and prehistoric cultural resources. The area is characterized by diverse cultural resource types. Supporting conservation and designating conservation areas are efforts that would make a substantial difference in cultural resources preservation.
One example includes County efforts in nominating historic buildings for listing in the National Register for Historic Places (NRHP). For instance, multiple properties (The Architecture and Planning of Josias Joesler and John Murphey in Tucson, Arizona, 1927-1956) have been listed on the NRHP.
Historic property types include single and multifamily residences, commercial projects, institutional buildings, and districts. One example is the Catalina Foothills Estates, a project which began in 1928 with the purchase of 7,000 acres of land to be developed into hacienda style homes with open patios and stylistic features that used the topography, view, and vegetation to best advantage. Additional buildings designed by Joesler are currently being nominated for listing in the NRHP. Listing such significant
standing structures is an important step in the preservation and management of historic properties.
The Plan further notes that:
Pima County has a long-term commitment to protect its cultural resources, beginning with Board of Supervisors Resolution 1983-104, which provides protection for archaeological and historic sites on County projects. Various existing County ordinances and policies also require the consideration and protection of cultural resources on projects permitted by the County. The County also ensures that appropriate State and Federal cultural resources requirements are met, as required on a project-specific basis[...]
In addition to the Pima County policy focused on protecting these cultural resources, the City of Tucson’s Plan Tucson provides definitive guidance on historic preservation. In particular, Plan Tucson policy, Historic Preservation 7, states: “Evaluate the benefits of new development relative to historic preservation in land use decisions.” and policy, Land Use, Transportation, & Urban Design 4, states: Ensure urban design that: a. is sensitive to the surrounding scale and intensities of existing development
Plan Tucson states in Set 1: Guidelines for Development Review that Apply to All Locations & Types of Development LT28.1.15 Protect historic and archaeological resources.
The nationally recognized assessment criteria used for the protection of historic resources is the evaluation of an undertaking to determine if the action is having an adverse effect. This criteria is a requirement for federal projects. Guidance on determining Adverse Effect criteria has been developed by the Federal Advisory Council on Historic Preservation.
“Adverse effects occur when an undertaking may directly or indirectly alter characteristics of a historic property that qualify it for inclusion in the National Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling, or association. Reasonably foreseeable effects caused by the undertaking that may occur later in time, are farther removed in distance, or are cumulative also need to be considered.” Which can include: “Change of use or physical features of a property's setting; and visual, atmospheric, or audible intrusions;
A recent D.C. Circuit Court decision has clarified the meaning of “direct” in Sections 106 and 110(f) of the National Historic Preservation Acts. The Advisory Council on Historic Preservation has issued a memo o utlining that ruling, noting that “visual effects could be direct effects”
Although these guidelines regarding Adverse Effects are specific to federal undertakings, they provide the County and City direct guidance and framework for the policy goal to: “protect historic and archaeological resources”
The proposed annexation and rezoning will have an overall direct adverse effect on the historic integrity of the Santa Catalina Foothills Estates, St. Philip's in the Hills, and the Architecture and Planning of Josias Joesler and John Murphey. Specifically, the aspects of Historic Integrity that will be impacted by the proposal are Setting and Feeling. The proposed project will alter and damage the character of the place and the aesthetic/historic sense of a past period of time.
This proposal is in conflict to the cultural resource priorities and goals outlined in both Pima Prospers and Plan Tucson and demonstrated priorities by Pima County over the last thirty five years.
It is also worth noting that the stretch of Campbell Avenue adjacent to the subject property is designated a “Scenic Route.” The purpose of the Scenic Route program is outlined in Pima County Zoning Code: 18.77.040: “The intent of this section is to preserve and enhance the visual resources of the natural and built environment from and along scenic routes in order to: 1. Protect property values and the character of neighborhoods; 2. Protect and enhance the unique character of a community, including vegetation, architecture and geology; 3. Protect and enhance the economic value of tourism; and 4. Protect natural resources.” The rezoning and proposed projects will undermine the purpose of this zoning designation.
Finally, as noted above we are very concerned the current process is inconsistent with Plan Tucson Redevelopment & Revitalization Policies 7: Undertake an inclusive community participation process in redevelopment and revitalization efforts. Additionally, based on questions and concerns raised at the August 29 meeting the bundled process has created significant public confusion.
We formally request the Mayor and Council separate this into two sequential steps: first, only consider annexation with transfer of the same zoning (translational), and then hold the initiation of rezoning/PAD public hearing at a later date.
We respectfully ask that the Mayor and Council prioritize and protect our historic resources.
Tucson Historic Preservation Foundation