Rincon Neigborhood Appeals Commonwealth Club Destruction Of ILA 1934 Strike HQ Building Facade

Rincon Neigborhood Appeals Commonwealth Club Destruction Of ILA 1934 Strike HQ Building Facade

Rincon Point Neighborhood Association
88 Howard Street Post Office Box 193015 San Francisco, CA 94119
December 13, 2014

Angela Calvillo
Clerk of the Board of Supervisors City Hall, Room 244
1 Dr. Carlton B. Goodlett Place San Francisco, CA 94102

Re: Appeal of Mitigated Negative Declaration, 110 The Embarcadero (2011.1388E) Via email and USPS Priority Mail
Dear Ms Calvillo:

The Rincon Point Neighbors Association, with the support of numerous individuals and approximately 20 community groups, hereby appeals the Planning Commission’s denial of its appeal of the Mitigated Negative Declaration (MND) for the proposed project at 110 The Embarcadero. This proposal amounts to the destruction of one of the city’s most historic buildings and one of the most important union-related buildings on the west coast. The ILWU unanimously called for landmarking this building at its 34th International Convention in Seattle.

Testimony shows that this project should have received an Environmental Impact Report. Historical issues have been glossed over and ignored. The building is eligible for listing on the California Register under Criterion A, association with important events, for its direct association with the 1934 waterfront and general strikes in San Francisco. The building was the headquarters of the International Longshoremen’s Association (ILA) and its leader, Harry Bridges, during the 1934 longshoremen’s strike. It was the site of one of the slayings on “Bloody Thursday,” and was the location where the bodies of the slain men lay in state.


The Commonwealth Club and Planning
Department are attempting to re-write history by
ignoring the association of the building with the
considerable contributions of the union and the
leadership of Harry Bridges. They have the gall to
state none of the building’s occupants appear “to
have made a significant contribution to local, state
or national history” (page 25, PMND). They have
declared Harry Bridges was not present at the
1934 strike committee (which he led) or at the
union local (where his leadership was consolidated during the 1934 strike). The historic

Rincon Point Neighbors Association

evidence overwhelmingly indicates this building was Harry Bridges’ headquarters during the strike. This makes the building eligible for listing in the California Register under Criterion 2 (persons) and requires the building to be preserved. The Planning Department and Commonwealth Club do not want this historic building preserved. That is why they are re-writing history. Of course it was the city’s powerful elite (mayor, downtown business interests, and the wealthy) who opposed the union in 1934. Today, their counterparts are still downplaying the union and Mr. Bridges by supporting the Commonwealth Club’s plans.

History was made on the Embarcadero, but the Commonwealth Club would remove ALL character-defining features of the building’s Embarcadero façade. The MND tries to excuse this by arbitrarily claiming “the significance of the property under Criterion 1 is most closely tied to the Steuart Street façade.” That is nonsensical and there is no basis for this proclamation. The Commonwealth Club bought one building, not two. The slain men lay in state inside the building. The building (not the façade) was headquarters of the union during the strike. On Bloody Thursday the SFPD shot gas canisters through the windows on both sides of this building. Harry Bridges obviously worked at the headquarters of the union he headed which was housed inside the building. The claim that only the Steuart Street façade is significant is absurd. This seems to be based on a photograph of preparations of the slain men’s funeral procession down Market Street. The great historic events focus on the strike, most of which took place on the Embarcadero. The personal leadership for these events emanated from this building.

In any event, the façade being proposed for the Steuart Street side would not be an accurate restoration anyway. The most visible first floor is completely different from 1934, and the newly inserted third floor would be visible and too close to the existing façade (set back only six- to eight-feet).


This historic Classical Revival building has handsome columns flanking five large windows. It is the same design on both sides of the building. Though poorly painted at this time, the historic design needs to be maintained to stay in sync with the rest of the block.

The MND is incorrect when it states a new modern glass curtain wall “would not have a significant impact upon the existing character of the Project’s vicinity.”


This is the last block in the city of mostly 100-year old buildings on the waterfront. It deserves to become a historic district. It is even more important because it faces the open waterfront. One building on the block survived the earthquake and fire and still exists at the north end (the Audiffred Building). Most

maintain much of their ornamentation, such as the
YMCA. The rest of the buildings were designed with a
dignified, classic look including the streamline
moderne (a style developed in the 1930s) office
building at the south end of the block. None have the
uninteresting glass curtain wall appearance that the
club is proposing. (Most world-class cities would
protect a block of buildings on the water. For
example, London, Paris, Florence, St. Petersburg,
Amsterdam (right) and other great cities would require
them to be either preserved or designed to maintain the historic look.)


It should be noted that the San Francisco Board of Supervisors found on March 31, 2009 that some of these same issues were significant at this location. Their motion stated the following about this existing building:

•  “There is substantial evidence that the existing building at 110 The Embarcadero, which also fronts 113-115 Steuart Street, is an historical resource.”

•  “...there is substantial evidence in the record that the building retains integrity...”

•  “...the building remains in its original location, the historic Audiffred Building remains next door and five of the buildings in the vicinity visible from a 1934

photograph still stand, resulting in a blockface the retains integrity. The massing and scale of the building, the shaped parapet with coping and the stucco cladding of the building remain the same as they were in 1934. Bradley Wiedmaier states that the second floor window opening dimension, the number of openings, the depth of the glazing from the wall surface and framing remain the same.”

•  “...alterations (already made) to the façade details mentioned by Page and Turnbull are largely reversible.”

•  “Given the substantial evidence in the record to support a determination that the building is an historical resource because it retains integrity associated with important historic events, there is a fair argument that the project, which proposed the demolition of the resource, may result in a substantial adverse change in the significance of an historical resource requiring the preparation of an EIR.”

•  “Planning Department staff found the project inconsistent with Planning Code Section 101.1(b)(2), which calls for conserving and protecting ... neighborhood character.”

•  “Written and oral testimony presented at the hearing identified the potentially significant impact on birds flying into the “mostly glass” walls....”

There is no reason demolition of the east façade of the building which faces the heavily traveled (pedestrian, bike, auto, streetcar) Embarcadero should be allowed now.


Members of the Rincon Point Neighbors Association and the Rincon Center Tenants Association have been actively tracking neighborhood projects since the 1990s. Residents have testified about the over-development of Rincon Park, the loss of the city’s 125-year-old transit terminal in front of the Ferry Building, the proposal for 75 Howard that would be nearly 50% over the height limit, and the rejected Hines project previously proposed for 110 The Embarcadero.


David Osgood President

Cc: Environmental Review Officer Enclosures