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Report regarding a request for a Certificate of Alteration for the temporary painting of the letters on the South San Francisco Hillside Sign and determination that the project is categorically exempt from CEQA, per Class 31, Section 15331 (Historic Resource/Restoration/Rehabilitation). (Megan Wooley-Ousdahl, Deputy City Manager)
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MOTION TO ADOPT STAFF RECOMMENDATION
1. Move to determine the Project is exempt from CEQA.
2. Move to approve and issue the Certificate of Alteration, subject to the attached draft Findings and draft Conditions of Approval.
RECOMMENDATION
Recommendation
Staff recommends that the Planning Commission conduct a public hearing and take the following actions:
1. Move to find the Project is exempt from further CEQA review pursuant to CEQA, Section 15331, Class 31 Historic Resource Restoration/Rehabilitation categorical exemption.
2. Move to make findings to approve and issue the Certificate of Alteration, subject to the attached draft Findings and draft Conditions of Approval.
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EXECUTIVE SUMMARY
The City of South San Francisco is applying for a Certificate of Alteration to temporarily paint the concrete letters on Sign Hill the colors of red, white, and blue in celebration of the United States’ Semiquincentennial (250th Anniversary). The letters would remain red, white, and blue for a few months and would be repainted the historic, and current, color of white in Fall 2026.
The City hired the consulting firm Michael Baker International, Inc. (“Michael Baker”) to prepare a historic analysis of the proposed project, analyzing whether the project conforms to the Secretary of Interior’s Standards (“SOI Standards”) and whether the project is exempt from CEQA. Per Attachment 4: Historic Analysis Report, Michael Baker found:
• The Project conforms to the SOI Standards. The proposed scope of work is limited to the application of new paint to a concrete surface that has historically been painted and regularly repainted; this constitutes typical maintenance and will not materially impair the integrity of the historical resource. The proposed red, white, and blue palette deviates from existing conditions, but this change is easily reversible and the scope of work calls for the sign to be repainted and restored to its original white color later in 2026.
• The Project meets the City’s review standard for issuance of a Certificate of Alteration. As noted, the proposed scope of work conforms to the SOI Standards and will not be detrimental to the historic sign.
• The Project qualifies for a Section 15331, Class 31 CEQA Exemption because the proposed scope of work is limited to maintenance and conforms to the SOI Standards, per the CEQA Guidelines.
Therefore, staff recommends that the Planning Commission issue a Certificate of Alteration for the temporary painting of the South San Francisco Hillside Sign (P26-0041), subject to the Findings (Attachment 1) and Conditions of Approval (Attachment 2) and determine that the project is exempt under CEQA, Section 15331, Class 31 Historic Resource Restoration/Rehabilitation.
BACKGROUND
In recent years, the City of South San Francisco has orchestrated an annual event as recommended by the Mayor. This year’s event will be an honoring of the United States’ Semiquincentennial, the 250th anniversary of the signing of the Declaration of Independence. This milestone, occurring on July 4, 2026, is branded nationally as “America 250.”
The City’s Semiquincentennial celebration includes year-long programming, a July 4th parade and picnic at City Hall, communications, signage, and branded giveaways. A key piece of the celebration is the proposed temporary painting of the South San Francisco Hillside Sign (“Sign Hill”) letters in the colors of red, white, and blue.
The Sign Hill letters are owned by the City of South San Francisco and are maintained by the City’s Parks and Recreation Department. The letters, which were historically and are currently painted white, vary in size (48-65’ tall and 10-23’ wide), but appear uniform due to their anamorphic arrangement on the contoured hillside. The letters are repainted white every two to three years; the letters are due for another repaint this year. The letters are painted by City staff and often by volunteers.
In 1996, the South San Francisco Hillside Sign was listed in the National Register of Historic Places by the United States Department of the Interior under Criterion A for its association with broad patterns of economic history and civic boosterism. Resources that are listed in the National Register are also automatically listed in the California Register of Historic Resources. Since Sign Hill is listed in the National Register and the California Register, Sign Hill is subject to the City’s Certificate of Alteration process and also meets the definition of a “historical resource” for purposes of CEQA.
DISCUSSION
The City of South San Francisco is applying for a Certificate of Alteration to apply a new coat of paint to the Gunite (sprayed concrete) letters on Sign Hill in the colors of red, white, and blue, as shown in Figure 1 in Attachment 3. Staff considered additional options for the color scheme, as shown in Attachment 3. After much consideration and in consultation with the Mayor, Figure 1 was selected as the preferred painting scheme due to its visual legibility and ease of painting.
If the Certificate of Alteration is approved, the letters will be painted by volunteers and City staff in early June. The proposed colors for the repainting are Old Glory Red, White, and Old Glory Blue, which are the official colors of the American flag (see Attachment 3). The letters would remain red, white, and blue for a few months and would be repainted to their existing and historic color (white) later in 2026. The only proposed change is painting the letters; no other change will be made to the historic resource itself.
Prior to painting the letters, the Parks and Recreation Department will remove all brush around the letters in May. The Department will also mark areas that contain sensitive habitat, so that these areas will not be impacted by staff and volunteers when painting.
This proposed temporary alteration is for the rare, nationwide celebration of America 250. The City recognizes that this is a unique event and moment in time and also recognizes that multiple paintings of the letters would diminish the integrity of the sign. Therefore, the City proposes the painting of the Sign Hill letters as a one-time occurrence.
ANALYSIS
Certificate of Alteration Review
Pursuant to South San Francisco Municipal Code (SSFMC) Section 2.56.130: Certificate of Alteration, a Certificate of Alteration is required for any material change through alteration, construction, relocation, or demolition of a designated historic resource. A Certificate of Alteration may be approved by the Planning Commission if the required findings are made pursuant to SSFMC Section 2.56.130, subsection (f):
1. The action proposed is consistent with the purposes of Chapter 2.56 of the Municipal Code; and
2. The action proposed will not be detrimental to a structure or feature having significance as an historic resource; or
3. The applicant has demonstrated that the action is necessary to correct an unsafe or dangerous condition on the property; or
4. The applicant has demonstrated that denial of the application will result in immediate, undue, or substantial hardship because of conditions peculiar to the particular site or improvement.
In evaluating an application for a Certificate of Alteration, the Planning Commission shall consider, among other things, the following:
• The historic value, architectural value and significance of the historic resource, as well as present and prospective effects or hardships upon the owners and occupants of the affected properties.
• The Design Review Board’s report and recommendations, architectural features of the building or structure in question.
• The landscaping or natural features of the site in question, and the position of such buildings, structures or sites in relation to the street or public way and to other buildings, structures, or sites.
• The United States Secretary of the Interior’s Guidelines for Rehabilitation shall provide base criteria for evaluating proposed alterations to an historic resource.
As set forth under SSFMC Section 2.56.080: Historic Preservation Findings and Purpose, the purpose of historic preservation in the City includes:
• The identification, protection, enhancement, perpetuation and use of structures, sites and areas that are reminders of past eras, events and persons important to local, state or national history, or which provide significant examples of architectural styles of the past or are elements in the history of architecture or which are unique and irreplaceable assets to the city of South San Francisco and its neighborhoods, or which provide for this and future generations examples of the physical surroundings in which past generations lived.
• The development and maintenance of appropriate settings and environments for such structures, in such sites and areas.
• The enhancement of property values, the stabilization of neighborhoods and areas of the city, and the increase of economic and financial benefits to the city and its inhabitants.
• The preservation and encouragement of a city of varied architectural styles, reflecting the distinct phases of its history: cultural, social, economic, political and architectural.
• The enrichment of human life in its educational and cultural dimensions in order to serve spiritual as well as material needs by fostering knowledge of the living heritage of the past.
Historic Analysis
The City hired Michael Baker International, Inc. (“Michael Baker”) to prepare a historic analysis of the South San Francisco Hillside Sign repainting project. Michael Baker reviewed the project’s conformance with the Secretary of Interior’s Standards (“SOI Standards”). These standards are a set of technical standards developed by the National Park Service to broadly guide the treatment of historic properties. SSFMC Section 2.56.130(d) states that the SOI Standards “shall provide base criteria for evaluating proposed alterations to an historic resource.”
The SOI Standards address four treatment approaches, each of which guides certain types of projects involving historical resources: preservation, rehabilitation, restoration, and reconstruction. The City’s proposed project falls under the Rehabilitation category which is defined as:
The act or process of making possible a compatible use for a property through repair, alterations, and additions while preserving those portions or features which convey its historical, cultural, or architectural values.
Michael Baker reviewed the proposed project against the ten SOI Standards for Rehabilitation and found:
It is Michael Baker’s professional opinion that the Project, as proposed, conforms with the SOI Standards because the temporary application of hued paint to already-painted concrete surfaces constitutes regular maintenance, is reversible, and will not materially impair or otherwise impair the historical resource.
Land Use Analysis
The South San Francisco Hillside Sign is located in the Parks and Recreation (PR) zoning district. This project does not propose a change of use or function for the historic resource which was constructed as signage and will continue to be used as such.
General Plan Consistency Analysis
The proposed project is consistent with the City’s General Plan, which designates the site as Parks and Recreation (PR), and does not propose any changes to this designation. This land use designation encompasses parks, recreation complexes, public golf course, and greenways.
DESIGN REVIEW BOARD
The Design Review Board considered the proposed project during their meeting on April 21, 2026, and provided the following comments, as detailed in Attachment 5:
1. The Board liked the proposed color palette for the temporary painting of the Sign Hill letters for the America 250 celebration.
2. The Board suggested the consideration a color scheme painting “South” & “City” white to bring attention to the City of South San Francisco.
The Design Review Board stated that they were in favor of recommending approval of the Certificate of Alteration, regardless of the color scheme selected. The Board suggested consideration of a new painting scheme which seeks to emphasize the words “South” and “City” by painting them white so that they would stand-out (see Attachment 3, Figure 4). After much consideration and in consultation with the Mayor, Figure 1 (rather than the DRB-proposed option) was selected as the preferred painting scheme due to its visual legibility and ease of painting.
ENVIRONMENTAL REVIEW
The project proposes the temporary application of hued paint to the already-painted concrete surfaces of Sign Hill and is considered to be regular maintenance, reversible, and not materially impairing or otherwise impairing the historical resource. Per the California Environmental Quality Act (CEQA), the proposal can be exempted from further environmental review in accordance with Section 15331, Class 31 Historic Resource Restoration/Rehabilitation.
The Class 31 CEQA Exemption applies to projects “limited to maintenance, repair, stabilization, rehabilitation, restoration, preservation, conservation or reconstruction of historical resources in a manner consistent with the [SOI Standards]” (California Office of Historic Preservation 2001).
CONCLUSION
Staff recommends that the Planning Commission issue a Certificate of Alteration for the temporary painting of the South San Francisco Hillside Sign (P26-0041), subject to the Findings (Attachment 1) and Conditions of Approval (Attachment 2) and determine that the project is exempt under CEQA, Section 15301, Class 31 Historic Resource Restoration/Rehabilitation.
Attachments
1. Findings of Approval
2. Conditions of Approval
3. Sign Hill Letters - Painting Design & Colors
4. Historic Analysis Report
5. Design Review Board Comment Letter dated April 29, 2026