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In the July 30, 2006, TOM BUTT E-FORUM: TROUBLE FOR TOLL BROTHERS, I included a PDF file describing “How the City of Richmond Subverted CEQA in the EIR for Terminal 1 (Point Richmond Shores). “ This was based on information I had been able to assemble from sources other than the City of Richmond. I had requested, on July 21, under the California Public Records Act and Richmond Municipal Code Section 2.40, records from the City of Richmond, some of which I received on July 31, 2006.

These new documents provided further insight into how the City of Richmond, aided and abetted by its paid consultants, evaded CEQA.

In 2003, the Richmond Community Redevelopment Agency had already procured one report from an architectural historian with an opinion about the historic significance of Terminal 1 that was inconsistent with the agency’s desired outcome. The agency then contacted a second architectural historian to solicit a proposal but dropped that initiative when the individual failed to guarantee the desired outcome.

In 2004, the agency apparently found an architectural historian who would provide the conclusion the agency desired. Preservation Architecture, located in Oakland, produced a report dated June 21, 2004. I have to give Preservation Architecture credit for their really out-of-the-box approach to stripping Terminal 1 of historic significance. I have provided a table in the attached PDF file that compares the historical summary of Circa (Sheila McElroy, who provided the agency’s first report) and that of Preservation Architecture.

Both authors acknowledge that Terminal 1, along with the Garrard Boulevard/Dornan Drive tunnel and the roadway (Dornan Drive) that connects Terminal 1 with Point Richmond was Richmond first municipal port project, constructed approximately 1915. They both also acknowledge that the original Terminal 1 building is substantially intact in its historic appearance.

Then they diverge. Both evaluated the historic significance with regard to criteria for eligibility for the California Register, which is the threshold for CEQA review.

Criterion A, of the California Register asks if “It is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States?”

Circa concluded that Criterion A was satisfied due to the significance of Richmond’s economic development based on and associated with port facilities (shipping and storage):

The Terminal One structure is the primary element of the port development and retains a high level of integrity especially in the aspects of location, design, materials, workmanship and feeling.  The Terminal strongly conveys the association of port facilities in northern California and the industrial growth of the City of Richmond.

Richmond’s Terminal One structure was constructed between 1912 and 1915 as the first storage and shipping terminal for the new outer harbor project connecting rail and ship traffic.  It was to provide sufficient storage room with easier access for the unloading of vessels.

Preservation Architecture, on the other hand, built a case for considering Terminal 1 somewhat of an orphan and an anomaly, to be judged not in the context of Richmond’s development but as just another undistinguished wharf among many up and down the Pacific Coast.

Whereas Terminal No. 1 was originally built as a transshipment point between Richmond’s industries, via the railroad and regional shipping routes, its use was converted to that of an independent, liquid storage and transport facility within just over a decade of its construction, and has served in that independent capacity for much of the past 80 years. Neither the nearby port facilities, once under the same ownership and operation as Terminal 1, nor the nearby shipyards share any historical or physical association with Terminal 1.

The story of Wharf No. 1 is, therefore, not that of a first and important municipal terminal, but is instead that of a contextually isolated, municipal terminal structure that comprised but a small component of a harbor that developed under private auspices, more than a decade later, and in a different location – at Richmond’s Inner harbor. Nor was wharf No. 1 built as an edifice of consequential design, as intended. Rather, it was and is a spare industrial structure that does not exploit or celebrate its location at the entrance to the Richmond Channel.

While Wharf No.1 is  consequence of events surrounding the Panama canal, specifically the attempt the create a harbor for the City of Richmond – due to its contextual isolation and its spare industrial character, Wharf No. 1 does not appear to fulfill these potential associations. Rather, its actual associations are to the few, adjoining yet non-historic public works and engineering structures, including the tunnel. Neither is Wharf No. 1 associated with other locally designated historic resources with which it may otherwise be geographically related. Terminal 1 therefore lacks associations with events with events or patterns of events that have made a significant contribution in national, state or local history.

Criterion C of the California Register asks if “It embodies the distinctive characteristics of a type, period, region, or method or construction, or represents the work of a master?”

Again, Circa responded in the affirmative, concluding that Terminal 1 is the remaining example of an original port facility on the outer harbor of the City of Richmond

In general, the main Terminal One structure remains as it was constructed and retains most of the materials, design and craftsmanship of the original design.

Preservation Architecture reached a different conclusion:

Despite the intentions of its planners and engineers, Terminal No. 1 is without architectural, engineering or material significance. Completed in 1915, at a time when the use of reinforced concrete for industrial engineering and architecture was relatively widespread, it is an innocuous, industrially engineered wharf and transit shed combining reinforced concrete and steel construction. Its engineering character is limited to the inherent quality of its vast, shed-like interior space, and to the quality of construction of its wharf. Moreover, its warehouse additions of 1920 are of negligible substance and interest. Wharf No. 1 also fails to substantiate its potentially memorable location.

Finally, the two consultants summed up their opinions, as follows:


The City of Richmond’s Terminal One structure is potentially an historic resource.  It is eligible for the California Register of Historical Resources for significance at a local level for its association with the City of Richmond’s port development and related industry.  As proposed demolition of Terminal One does not conform to the Secretary of the Interior Standards and would be considered a Negative Impact under the California Environmental Quality Act. 

Preservation Architecture:

Although a relatively old structure locally, as well as an early port shed, Terminal 1 does not appear to fulfill any of the eligibility criteria for the Richmond Register.

How could two supposedly qualified professionals come up with such diverse opinions?  I could take the high road and acknowledge that applying the California Register criteria to evaluation of old buildings is not an exact science and is, by nature, somewhat subjective. Different conclusions should not be unexpected. Historical significance, like beauty, is in the eye of the beholder.

But I’m not going to do that. I am going to use this as an illustration that, in my opinion, there is a certain amount of prostitution going on in the environmental impact industry, including the cultural and historic resources part of it. These EIR firms know that “the customer is always right,” and when that customer is the owner of a piece of property bent on its development, and in fact has already factored the proceeds from the sale into its annual budget, that EIR had better meet that customer’s expectations.

I believe that both Preservation Architecture and the Richmond Community Redevelopment Agency knew the outcome of the Terminal 1 report before it even started. Preservation Architecture was hired by the project owner, the Richmond Community Redevelopment Agency. The company hat prepared the Environmental Impact Report for both Point Richmond Shores and the Terminal 1 Contaminant remediation, LSA Associates, took the Preservation Architecture opinion and ran with it, without any independent verification. LSA Associates does a lot of EIR work for the City of Richmond, including the EIR for Seacliff Esates, and I am sure the company would like to do more. The customer is always right.

I tried to contact Preservation Architecture to discuss my concerns with them. They have a telephone listed in Oakland, but no one answers. I tried to Google them for some information, but there was not a single hit. I asked around the preservation community, but no one seems to know who Preservation Resources is.