CITY OF LAGUNA BEACH
COMMUNITY DEVELOPMENT DEPARTMENT
505 Forest Avenue, Laguna Beach, CA 92651
Tel. (949) 497-0713 Fax. (949) 497-0759
MILLS ACT CONTRACT APPLICATION
REVISED: JANUARY 2025 Page | 2
GENERAL INFORMATION (must be typed):
Property Address:
Property Owner
(as noted on Grant Deed):
Mailing Address:
City: State: Zip Code:
Telephone No: E-Mail:
Applicant:
Address:
City: State: Zip Code:
Telephone No: E-Mail:
PROPERTY INFORMATION:
Address of property: Assessor Parcel No(s):
Tract: Block: Lot(s):
Legal
Description:
HISTORIC DESIGNATION CATEGORY:
Staff Only: Application No.: _____________ HR Designation No.: ___________ Date of Designation: _________ REQUIRED MATERIALS (must be submitted with this application):
COMPLETED AND SIGNED APPLICATION FORM
$3,201 APPLICATION FEE
COPY OF GRANT DEED, INCLUDING LEGAL DESCRIPTION
$4,000 DEPOSIT FOR HISTORIC ASSESSMENT (must be a separate check)1 The assessment will include current photographs of street views, each exterior or side elevation and all other improvements/features on the parcel. The photographs will be used to create a table identifying character-defining features and provide recommendations for treatments. The assessment will also include a recommended rehabilitation/maintenance plan and timeline which includes all work to be completed within the next 10 years.
DRAFT 10-YEAR REHABILITATION/MAINTENANCE PLAN AND COST ESTIMATE OF ITEMIZED WORK
COPY OF MOST RECENT PROPERTY TAX BILL
MOST RECENT REAL PROPERTY REPORT
I hereby certify that I am the present owner of the subject property described above and that I have reviewed the subject application and apply for consideration for a Mills Act Contract. I further understand that a Mills Act Application does not result in an automatic entitlement and each application is evaluated on its own merits on its historical significance and inclusion in the City’s program.
Owner’s Signature: Date:
1 Properties with more than two historic-age buildings (including ancillary buildings such as a garage or guest house) will require an additional fee to be determined based on the size and complexity of the property and number of historic-age buildings.
Attachment 4 74
501 Lombardy Lane R&R Assets LLC 8026 Terrace Ridge Dr Tampa FL 33637 863-398-3083 [email protected] Susan Rogers, R&R Assets LLC 8026 Terrace Ridge Dr Tampa FL 33637 863-398-3083 [email protected] 501 Lombardy Lane 644-097-32 844 10 HCR-25-0952 ✔ 8/22/2025 N TR 844 BLK LOT 10 TR 844 LOT 10 ALL -INC 20 FT STRIP ADJ ON SW- 501 Lombardy Lane
Laguna Beach, CA
Mills Act Application Report
Prepared by:
July 2025
Attachment 4
75 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Table of Contents
TABLE OF CONTENTS
1. INTRODUCTION........................................................................................................................................................................ 1
1.1 Purpose and Methodology.............................................................................................................1
1.2 Qualifications ................................................................................................................................1
1.3 Secretary of the Interior’s Standards for Rehabilitation ..................................................................2
1.4 Definitions and Terminology ..........................................................................................................3
2. SUMMARY OF SIGNIFICANCE...........................................................................................................................................5
3. PROPERTY DESCRIPTION AND HISTORY .................................................................................................................. 6
3.1 Location Map ................................................................................................................................6
3.2 Property Description .....................................................................................................................6
3.3 Current Photographs .....................................................................................................................7
3.4 Construction History....................................................................................................................12
4. EXISTING CONDITIONS AND RECOMMENDED TREATMENTS......................................................................14
4.1 Existing Conditions Assessment Summary ...................................................................................14
4.2 General Treatment Recommendations ........................................................................................14
4.1 Character-Defining Features and Recommended Treatments......................................................15
4.2 Incompatible Features ................................................................................................................21
5. PROPOSED REHABILITATION/MAINTENANCE PLAN AND TIMELINE (WORK PLAN)..................... 22
6. ADDITIONAL PRESERVATION GUIDANCE...............................................................................................................24
7. SOURCES .................................................................................................................................................................................. 25
APPENDICES
Appendix A: Résumés
Appendix B: Guidelines for the Treatment of Historic Fabric Attachment 4
76 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 1
1. INTRODUCTION
1.1 Purpose and Methodology
501 Lombardy Lane, Assessor Parcel Number (APN) 644-097-32 (property), is located within the Laguna-South neighborhood (historically known as Arch Beach) in the City of Laguna Beach (City). The property comprises a one-story single-family residence constructed between 1927 to 1931.1It was placed on the City’s Historic Register (Register) on September 15, 1999. As such, it is eligible for a Mills Act Historic Property Contract (Mills Act Contract).
The Mills Act was enacted in 1972, giving local governments the authority to grant property tax relief to owners of “qualified” historic properties. In Laguna Beach, a ”qualified” historic property is one that is listed on the Register. To pursue the historic preservation tax reduction incentive, an owner of a qualified historic property must enter a Mills Act Contract with the City. Under this contract agreement, the property owner agrees to protect, preserve, and maintain the property in accordance with specific preservation standards and other conditions in exchange for property tax relief.
GPA Consulting (GPA) was retained by the City to prepare this Mills Act Application Report (report) as part of the Mills Act Contract application for the property. In the preparation of this report, GPA performed the following tasks:
1. Reviewed Mills Act Contract application materials prepared by the property owner(s).
2. Reviewed existing information, including building permit records, planning documents, and historic maps.
3. Conducted a site visit to ascertain the current condition of the property and all buildings and features thereon. Digital photographs were taken for use in this report.
4. Prepared a detailed table of architectural features to document existing conditions, identify character-defining features, and provide recommended treatments following the Secretary of the Interior’s Standards for Rehabilitation (Standards).
5. Coordinated with the City and property owner(s) regarding the Rehabilitation/Maintenance Plan and Timeline for the property and provided recommendations for prioritization of work. The Rehabilitation/Maintenance Plan and Timeline (work plan) included in this report (see Section 5) is based on the work plan submitted by the applicant to the City in the initial Mills Act Application Form. The applicant-submitted work plan was reviewed by GPA for consistency with the intent of the Mills Act program and revised based on a review of existing information and observations made on site. GPA provided a draft of the revised work plan to the applicant to review and to provide the cost estimates included in this report.
1.2 Qualifications
Phoebe Rayburn, Architectural Historian I at GPA, was responsible for the preparation of this report. Audrey von Ahrens, Senior Architectural Historian at GPA, reviewed the report for quality assurance and quality control. Ms. von Ahrens meets the qualifications for a historic preservation professional outlined in Title 36 of the Code of Federal Regulations Part 61. Their résumés are included as Appendix A. 1 Kathleen Les, “Laguna – South,” California Department of Parks and Recreation (DPR) Form Set, Environmental Coalition, Laguna Beach, California, April 1980, 72.
Attachment 4
77 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 2
1.3 Secretary of the Interior’s Standards for Rehabilitation In exchange for the Mills Act property tax incentive, property owners must protect, preserve, and maintain the historic property following the Standards, among other specific contract conditions. 2 The definition of
“rehabilitation” assumes that at least some repair or alteration will be needed in order to provide for an efficient, contemporary use; however, these repairs and alterations must not damage or destroy the materials, features, or finishes that are important in defining the property’s historic character. The Standards for Rehabilitation are as follows:
1. A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.
2. The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.
3. Each property will be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.
4. Changes to a property that have acquired historic significance in their own right will be retained and preserved.
5. Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.
6. Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.
7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible.
Treatments that cause damage to historic materials will not be used.
8. Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.
9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.
10. New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
2 The Standards relevant to the Laguna Beach Mills Act program are codified at 36 Code of Federal Regulations (CFR) Section
68. Attachment 4
78 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 3 The Standards and associated Guidelines can be accessed online by visiting the National Park Service website using the following address:
https://www.nps.gov/orgs/1739/secretary-standards-treatment-historic-properties.htm.
1.4 Definitions and Terminology
Character-Defining Features (CDFs)
This report discusses the architectural features of the property and specifically identifies the CDFs, which are the physical components that contribute to a property’s sense of time and place. For Laguna Beach Mills Act Application Reports, they include two categories: the overall visual character, and exterior materials and craftsmanship.
Some CDFs are more important than others in conveying the significance of a property. This report ranks each CDF as primary or secondary, which are defined as follows:
Primary CDF
• The most essential physical elements to conveying to the significance of the property. • Generally includes features that date from the period of significance; directly relate to the original use, type, and style; display craftsmanship; are highly visible; and retain integrity.
Secondary CDF
• Generally includes features that date from the period of significance but may not directly relate to the original use, type, and style; are common features or materials; and/or are less visible due to location on rear elevations.
• A feature that replaced or modified an original or altered component of the property in a way that maintains or restores the historical appearance and does not detract from its historic character and significance.
o New features on the historic portions of the property were only considered if they were replaced in kind, or if they were placed within original openings. Such features may compromise the property’s integrity of materials but contribute to its integrity of design. • Materials and/or features that were historically located on the property based on physical or documentary evidence.
Non-Character-Defining Features
Non-historic additions and/or ancillary buildings and their individual features were eliminated from consideration as character-defining, since they do not contribute to the to the Mills Act property’s historic character.
Incompatible Features
This report identifies incompatible features when they are relevant to the Mills Act application and proposed work plan. Incompatible features include the following:
• A feature that replaced or modified an original or altered component of the property in a way that deviates from the historical appearance.
Attachment 4
79 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 4 • Materials that were not, or would not have been, historically located on the property, such as materials that were not utilized for the style or type of building, or contemporary materials that did not exist at the time of construction.
Existing Conditions
This report also analyzes the overall existing condition of the property and each of its CDFs. The existing conditions are ranked on a scale of good, fair, and poor. These terms are defined as follows:
Good
• Intact, structurally sound, and performing its intended purpose; and • Needs no repair or rehabilitation beyond routine or preventative maintenance.
Fair
• Signs of wear, failure, or deterioration; and
• Needs repair or rehabilitation beyond routine or preventative maintenance; but • Structurally sound and performing its intended purpose overall.
Poor
• Signs of wear, failure, or deterioration to the point that it is no longer structurally sound or performing its intended purpose.
The condition of non-character-defining and incompatible features is not assessed in this report.
Attachment 4
80 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 5
2. SUMMARY OF SIGNIFICANCE
501 Lombardy Lane was identified in the 1981 Laguna Beach Historic Resources Inventory (LBHRI) and was automatically listed in the Register as a “K” rated property, which at the time referred to a building that strongly maintained its original integrity and demonstrated a particular architectural style or time period.3 However, a revised Historic Preservation Program and ordinance approved by City Council in April 2022 and certified by the California Coastal Commission in July 2022 no longer assigns a rating system to historical resources and eliminated all references to the 1981 LBHRI.4
Never-the-less, the property was officially listed on the City’s Register on September 15, 1999, as a “Victorianized Bungalow.” The assumed periods of significance are 1927-1931, encompassing initial construction, and circa 1945-1972, capturing the period during which Victorian elements were added.
Figure 1: Photo of 501 Lombardy Lane, view facing east. Source: 1981 LBHRI. 3 Les, 65.
4 Laguna Beach Municipal Code, Chapter 25.45 Historic Preservation, 25.45.004 General Provisions.
Attachment 4
81 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 6
3. PROPERTY DESCRIPTION AND HISTORY
3.1 Location Map
The property is in the Laguna-South neighborhood of the City of Laguna Beach, formerly known as Arch Beach.
The area is primarily beach cottages and second houses. 501 Lombardy Lane is located near the center northwest portion of the Laguna-South neighborhood, east of South Coast Highway. It is a rectangular parcel bounded by Lombardy Lane on the north and neighboring parcels on the east, south, and west (see Figure 2).
Figure 2: 2025 aerial photo showing subject property outlined in orange.
3.2 Property Description
The property comprises a rectangular parcel with a one-story single-family residence. The residence has an irregular shaped plan, asymmetrical massing, and fills the parcel. It has a multi-gabled roof with front, shed, flat, and mansard gables clad in composition shingles. Metal cresting runs along the roofline with wood cresting above the eaves. There are decoratively carved wood brackets under the eaves on the west portion of the primary elevation that wrap around to the north portion of the west elevation. The exterior walls are clad in straight edged wood shingles with half-round wood shingles within the gable peaks. Fenestration consists of ribbon windows, a fixed leaded window, multi-light picture windows, multi-light casements, multi-light sidelights, single-light casements, fixed single-light, fixed multi-light window, fixed multi-light pentagon-shaped window, and multilight wood doors.
The main entrance is located on the north (primary) elevation and is centered beneath the front-facing gable. It consists of partially glazed, multi-light wood double doors that are flush with the elevation and articulated by a fixed multi-light pentagon-shaped window above. West of the main entrance is a canted bay that projects from the rest of the elevation and has four arched windows with fixed one-over-one divided lights with decoratively carved wood mullions. The east portion of the elevation is set back and has a fixed leaded glass window.
Attachment 4
82 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 7 Toward the south end of the west elevation is a box bay window with fixed multi-light center and multi-light side casement sash. The rear (south) elevation has a secondary entrance on the west with partially glazed wood double doors flanked by casement windows with four horizontally divided lights. To the east, the elevation projects slightly at an angle where an arched window with paired multi-light casements and transom are located adjacent a rectangular projecting volume. The south face of the projecting volume has three single-light casement windows. On the east end of the elevation is a vinyl window with paired casements. There are no openings on the east elevation.
The front yard is enclosed by a metal picket fence and entrance gate. The rear and side yards are enclosed with a wood fence. There is a brick driveway and a brick front porch that wraps around to the rear and side yards.
Landscaping consists of vines and shrubs along the picket fence in the front yard and west side yard.
3.3 Current Photographs
Figure 3: Photo Key. Photographs of building(s) indicated in blue and landscaping indicated in green.
Project North
Attachment 4
83 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 8 Photo 1. View of property from Lombardy Lane, looking southwest. Source: GPA, May 2025.
Photo 2. North (primary) elevation, main entrance, looking southeast. Source: GPA, May 2025.
Attachment 4
84 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 9 Photo 3. East (side) elevation, view facing southwest. Source: GPA, May 2025.
Photo 4. South (rear) elevation, view facing northwest. Source: GPA, May 2025.
Attachment 4
85 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 10 Photo 5. South (rear, at left) and west (side, at right) elevations, view facing northeast. Source: GPA, May 2025.
Photo 6. North (front) yard hardscaping, view facing northwest. Source: GPA, May 2025.
Attachment 4
86 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 11 Photo 7. South (rear) yard hardscaping, view facing southwest. Source: GPA, May 2025.
Photo 8. Southwest (rear, side) hardscaping, view facing south. Source: GPA, May 2025.
Attachment 4
87 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 12
3.4 Construction History
The single-family residence at 501 Lombardy Lane was initially constructed between 1927 and 1931 (see Figure 4).
5 The original building permit is not on file with the City, and the original builder and architect, if any, are unknown. The earliest building permit dates to May 1945 when a skylight was added to the living room roof and indicates that the residence had board and batten exterior walls and a shingle roof.6In September of 1945, a one-room addition with mansard roof and Victorian elements was constructed on the northwest (see Figure 5). 7 In 1956, the residence was “remodeled” and an addition was constructed on the southwest (see Figure 7). 8 In
2001, what is described in the building permit as a “solarium” was demolished and replaced with a new dining room and sunroom addition on the southwest.
9 The existing fence and entrance gate were replaced in 2002.10 See Table 1 for a summary list of relevant building permits.
Figure 4: 1931 historical aerial photo showing property soon after initial construction. Source: Flight X_8, Frame 26, May 22, courtesy of UCSB Library Geospatial Collection.
Figure 5: 1948 Sanborn showing property with northwest
addition. Source: Sanborn Map Company, Laguna Beach,
Sheet 16, courtesy of Historical Information Gatherers, Inc.
Figure 6: 1962 Sanborn showing property prior to
construction of southwest addition. Source: Sanborn Map Company, Laguna Beach, Sheet 16, courtesy of Historical Information Gatherers, Inc.
Figure 7: 1973 historical aerial photo showing property with southwest addition. Source: Flight WAS_G14, Frame 83,
January 19, courtesy of UCSB Library Geospatial Collection. 5 Les, 72.
6 City of Laguna Beach, Building Permit No. 8406, May 31, 1945. 7 Building Permit No. 8617, September 29, 1945.
8 Building Permit No. 14992, August 10, 1956.
9 Building Permit No. 14992, August 10, 1956.
10 Building Permit No. B00-0320, November 11, 2001.
Attachment 4
88 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 13 No other alterations are documented in building permit records; however, additional modifications identified through a comparison of historical and current photographs, and visual observations made during the site visit conducted by GPA are listed below:
• Original board and batten exterior wall cladding replaced with wood shingles and application of Victorian features “salvaged from old Pasadena homes,” circa 1945-1972. 11 • Replacement of main entrance door (north elevation), unknown date. • New window opening added above main entrance door with fixed multi-light wood window on the north elevation, circa 1980-2007.
12 • Replacement of straight edge wood shingle cladding on the north elevation within the front-facing gable with half-round wood shingles, circa 1980-2007.
13 • Replacement of roof cresting on northwest addition with existing metal cresting, circa 1980- 2007.
14 Table 1: Building Permit History15
Date Permit Work Completed Architect (A)/
Builder (B) Owner
1945/05/31 8406 Construct sky light in living room. Ross Shattuck (B)
Margaret E.
Shattuck
1945/09/29 8617 Construct a 17’ x 20’ one-room addition to existing residence.
Owner (B) Margaret E.
Shattuck
1956/08/10 14992 Construct addition to kitchen and remodel existing residence.
Clifford R. Hill
(B)
Ross Shattuck
1998/07/06 B98-1259 Remove existing roof and re-roof with composition shingles.
Joe Smalldon
(B)
Robert A. Di
Tullio
2001/11/29 B00-0320 Demolish existing solarium and add new dining room/sunroom.
Ron Guley (A);
Owner (B)
Robert and
Mary Di Tullio
2002/03/04 B02-409 In kind replacement of approximately 10’ to 12’ of fence and gate, with the max height of 6’ on side &
year yard.
Owner (B) Robert A Di
Tullio
11 “Emphasis on Charm: Group Plans Tour of Eight Laguna Homes,” Los Angeles Times, November 16, 1972, 10, Newspapers.com, accessed June 2025, https://www.newspapers.com/image/386034829/; Building Permit No. 8406, May 31, 1945.
12 Les, 72; Google Street View, September 2007, Google Maps, accessed June 2025, https://www.google.com/maps. 13 Les, 72; Google Street View, September 2007.
14 Les, 72; Google Street View, September 2007.
15 The building permit history table is not a complete list of all building permit records on file for the subject property. It includes only those permits pertaining to alterations to the building(s) exterior, site, and only major electrical and/or MEP upgrades.
Attachment 4
89 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 14
4. EXISTING CONDITIONS AND RECOMMENDED TREATMENTS
The property’s CDFs, their existing condition, and recommended treatments are summarized below and detailed in table format in Section 4.1. See Section 1.4 for definitions of the terminology used throughout this section.
4.1 Existing Conditions Assessment Summary
The property and building thereon appear to be in good overall condition. No visible signs of damage to the roof or foundation were observed. The exterior wood shingles and decorative features such as wood brackets and trim and metal cresting, and windows and doors all appear to be in good condition.
4.2 General Treatment Recommendations
All work, including maintenance and repair, should be completed following the Standards (see Section 1.3).
Generally, all primary CDFs identified in this report (see Section 4.1) should be retained to the greatest extent feasible and inspected annually to determine if maintenance or repair is necessary as the building ages. If deterioration necessitates replacement, the feature should be replaced in kind. Secondary CDFs should be retained or may be replaced with an option that is equally compatible with the historic character of the property in terms of style and materials. Additionally, if documentary evidence is or becomes available, restoring original features that were previously removed or replaced is encouraged.
Because the property is in good condition, as detailed in Section 4.1, the proposed work primarily entails continued maintenance and as-needed repairs of the historic features. Because the roof was last refinished in 2010, full re-roofing will likely be needed within the next ten years. Features expected to need the most regular maintenance are primarily constructed of wood and metal, though masonry features require monitoring and asneeded repairs. Appendix B: Guidelines for the Treatment of Historic Fabric includes guidance adapted from the Standards as well as the National Park Service’s series of Technical Preservation Briefs, specific to the materials that contribute to the historic character of the property. Additional preservation guidance and links to resources are included in Section 6. This guidance should be consulted when planning and carrying out applicable work on the property.
Attachment 4
90 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 15
4.1 Character-Defining Features and Recommended Treatments The following table identifies all existing exterior CDFs of the property. If applicable, incompatible features that detract from the historic character and are recommended for removal/replacement in the proposed Restoration, Rehabilitation, and Maintenance Plan (Section 5) are addressed in Section 4.2. Any minor or utilitarian features (e.g., crawlspace covers, contemporary light fixtures, attic vents) not identified in this report may be assumed to be non-character-defining; however, any proposed modifications to these features should be compatible with the historic character of the building and comply with the Standards.
Character-Defining Features (CDFs)
Type Description Location Photo (If Applicable) Importance Condition Recommended Treatment OVERALL VISUAL CHARACTER Massing
• Irregular in plan
• One story in height
• Asymmetrically
arranged elevations
☒ Total
Building
☐ Roof
☐ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain and maintain.
OVERALL VISUAL
CHARACTER
Roof Form
• Multi-gabled
o Front-gabled
o Mansard
o Shed
• Flush and overhanging
eaves
• Wood corbels
• Metal and wood
cresting
☐ Total
Building
☒ Roof
☐ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain and maintain.
Attachment 4
91 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 16 Character-Defining Features (CDFs)
Type Description Location Photo (If Applicable) Importance Condition Recommended Treatment FEATURE / MATERIAL Exterior Cladding Type A
• Wood shingles
• Straight edge
☒ Total
Building
☐ Roof
☐ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain, and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
FEATURE / MATERIAL
Exterior Cladding Type B
• Wood shingles
• Half-round
• Gable peaks and below
roof perimeter
☐ Total
Building
☐ Roof
☒ North el.
☒ East el.
☐ South el.
☒ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain, and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
FEATURE / MATERIAL
Door Type A
• Main entrance
• Wood
• Double doors
• Fully glazed
o Ten divided lights
• Projecting wood
surround; decorative
molding
☐ Total
Building
☐ Roof
☒ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain, and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
Attachment 4
92 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 17 Character-Defining Features (CDFs)
Type Description Location Photo (If Applicable) Importance Condition Recommended Treatment FEATURE / MATERIAL Door Type B
• Rear entrance
• Wood
• Double doors
• Fully glazed
o Eight divided lights
• Wood casement
sidelights
• Dual pane
☐ Total
Building
☐ Roof
☐ North el.
☐ East el.
☒ South el.
☐ West el.
☐ Primary
☒ Secondary
☒ Good
☐ Fair
☐ Poor
• Maintain and repair as needed.
• May be replaced with new,
compatible option. Consider
replacing with single panes, which
would be more compatible with
the historic character of the
property.
FEATURE / MATERIAL
Window Type A
• Canted bay
• Group of four
o Rounded arch
o One-over-one
divided lights
• Wood surround
• Decorative wood
moldings
☐ Total
Building
☐ Roof
☒ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain, and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind. FEATURE / MATERIAL
Window Type B
• Wood
• Fixed
• Leaded glass
• Wood surround
• Wood sill
☐ Total
Building
☐ Roof
☒ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
Attachment 4
93 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 18 Character-Defining Features (CDFs)
Type Description Location Photo (If Applicable) Importance Condition Recommended Treatment FEATURE / MATERIAL Window Type C
• Wood
• Tripartite
o Fixed center
o Side casement
sash
• Multi-light
• Dual pane
• Wood surround
☐ Total
Building
☐ Roof
☐ North el.
☐ East el.
☐ South el.
☒ West el.
☐ Primary
☒ Secondary
☒ Good
☐ Fair
☐ Poor
• Maintain and repair as needed.
• May be replaced with new,
compatible option. Consider
replacing with single panes, which
would be more compatible with
the historic character of the
property.
FEATURE / MATERIAL
Window Type D
• Wood
• Paired casements
• Rounded arch transom
• Multi-light
o Three divided
lights
• Wood surround
☐ Total
Building
☐ Roof
☐ North el.
☐ East el.
☒ South el.
☐ West el.
☐ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Maintain and repair as needed.
• May be replaced with new,
compatible option. Consider
replacing with single panes, which
would be more compatible with
the historic character of the
property.
FEATURE / MATERIAL
Window Type E
• Wood
• Casement
• Single light
• Wood surround
• Wood sill
☐ Total
Building
☐ Roof
☐ North el.
☐ East el.
☒ South el.
☐ West el.
☐ Primary
☒ Secondary
☒ Good
☐ Fair
☐ Poor
• Maintain and repair as needed.
• May be replaced with new,
compatible option. Consider
replacing with single panes, which
would be more compatible with
the historic character of the
property.
Attachment 4
94 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 19 Character-Defining Features (CDFs)
Type Description Location Photo (If Applicable) Importance Condition Recommended Treatment FEATURE / MATERIAL Decorative Cresting Type A
• Metal
• Low railing
• Filagree
• Rooftop perimeter
(mansard roof)
☐ Total
Building
☒ Roof
☐ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
FEATURE / MATERIAL
Decorative Cresting Type B
• Wood
• Carved
• Roof perimeter
(mansard roof)
☐ Total
Building
☒ Roof
☐ North el.
☐ East el.
☐ South el.
☐ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
FEATURE / MATERIAL
Decorative Corbels
• Wood
• Carved
• Eaves of mansard roof
☐ Total
Building
☐ Roof
☒ North el.
☐ East el.
☐ South el.
☒ West el.
☒ Primary
☐ Secondary
☒ Good
☐ Fair
☐ Poor
• Retain, maintain and repair as
needed.
• If ever damaged or deteriorated
beyond repair, replace in kind.
Attachment 4
95 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 20 Character-Defining Features (CDFs)
Type Description Location Photo (If Applicable) Importance Condition Recommended Treatment SITE Brick Hardscaping
• Herringbone pattern
• Basketweave pattern
☒ Front
☒ Rear
☒ Side
☐ Primary
☒ Secondary
☒ Good
☐ Fair
☐ Poor
• Maintain and repair as needed.
• May be replaced if desired with
equally compatible option/
configuration.
Attachment 4
96 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 21
4.2 Incompatible Features
The following table identifies only those incompatible non-character-defining features that detract from the historic character of the property, and should therefore be addressed as part of the potential Mills Act contract and proposed Work Plan (see Section 5).
Incompatible Features
Description Location Photo (If Applicable) Recommended Treatment Vinyl Window ☐ Total Building
☐ Roof
☐ North el.
☐ East el.
☒ South el.
☐ West el.
• Replace incompatible vinyl window with
new windows that are compatible with
the historic character of the property in
terms of materials
Concrete and Tile Planters/Fountains ☒ Front
☒ Rear
☒ Side
• Consider removing or replacing
incompatible hardscaping with new
options that are more compatible with
the historic character of the property in
terms of style and materials.
Attachment 4
97 Mills Act Application Report –501 Lombardy Lane, Laguna Beach 22
5. PROPOSED REHABILITATION/MAINTENANCE PLAN AND TIMELINE (WORK PLAN) (Cost Estimates Provided by the Applicant)
Contract Year Building Feature Proposed Work/Task Est. Cost
1. 2026 Foundation Engage a qualified structural engineer experienced in working with historic properties to inspect the foundation and make recommendations for any work, including seismic retrofit, with an implementation plan. Submit report to the City for review and execute any recommended work in a sensitive manner to avoid causing damage to historic fabric or visually impacting the historic character of the property.
$8,000
2. 2026 Chimney Engage the services of a chimney specialist or structural engineer with experience in historic preservation to investigate the existing condition of chimney and prepare an implementation plan for any recommended work to ensure chimney is structurally sound and weathertight. Commence and complete any necessary work as recommended.
$2,000
3. 2026-2036
(annually)
Total Building Treat property for pests such as rodents and termites. $10,000*
4. 2026-2036
(annually)
Roof Property owner to inspect roof and clean of debris. Make any necessary repairs in a timely and sensitive manner.
$3,000*
5. 2026-2036
(annually)
Gutters/Downspouts Property owner to inspect gutters and downspouts for damage or deterioration and clean out debris at least once per year, or more often as needed. Make any necessary repairs in a timely manner to prevent water damage to building.
$5,000*
6. 2026-2036
(annually)
Wood Siding,
Windows, Doors, and
Trim
Property owner to inspect all exterior wood features for chalking, blistering, peeling, or cracking paint. Where necessary, gently scrape failing paint, inspect wood, and make any necessary repairs in a sensitive manner. Replace in kind individual wood units only if severely damaged or deteriorated beyond repair. Carefully repaint in the same, or similar, historically appropriate color. $22,000*
7. 2026-2036
(annually)
Windows and Doors Property owner to inspect wood windows and doors for proper operation and seal and make any necessary repairs to ensure they remain weathertight.
$10,000*
8. 2026-2036
(annually)
Metal Weathervane
and Cresting
Clean metal of corrosion by gently sanding, make any necessary repairs, and refinish. $750*
9. 2026-2036
(annually)
Landscaping Property owner to inspect landscaping and trim plants/trees away from the building exterior. $30,000*
10. 2028-2036
(triennially)
Fences and Gates Inspect wood fences and gates for damage and/or peeling paint and repair/repaint as needed. $6,000* Attachment 4
98 Mills Act Application Report –501 Lombardy Lane, Laguna Beach 23 Contract Year Building Feature Proposed Work/Task Est. Cost
11. 2028-2036
(triennially)
Brick Hardscaping
(Driveway and
Walkways)
Property owner inspect for loose or damaged bricks. Repoint as needed using mortar to match the existing in terms of color, composition, and texture.
$3,000*
12. 2036 Vinyl Windows Replace all vinyl window(s) with new, historically appropriate, compatible multi-light wood windows within existing opening(s).
$1,000*
TOTAL: $100,750
*Estimate total of reoccurring costs over 10-year contract.
Attachment 4
99 Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 24
6. ADDITIONAL PRESERVATION GUIDANCE
Preservation Briefs16
In addition to the Standards and Guidelines, the National Park Service has produced a variety of publications, including the Preservation Briefs (https://www.nps.gov/orgs/1739/preservation-briefs.htm) and Preservation Tech Notes (https://www.nps.gov/orgs/1739/preservation-by-topic.htm), on a broad range of topics and techniques for the treatment of historic buildings and their materials. They can be accessed online by visiting the National Park Service website.
Some Preservation Briefs that may be relevant to the subject property are:
#2 Repointing Mortar Joints in Historic Masonry Buildings. #3 Improving Energy Efficiency in Historic Buildings.
#4 Roofing for Historic Buildings.
#6 Dangers of Abrasive Cleaning to Historic Buildings.
#9 The Repair of Historic Wooden Windows.
#10 Exterior Paint Problems on Historic Woodwork.
#14 New Exterior Additions to Historic Buildings: Preservation Concerns. #16 The Use of Substitute Materials on Historic Building Exteriors. #17 Architectural Character- Identifying the Visual Aspects of Historic Buildings as an Aid to Preserving Their Character.
#24 Heating, Ventilating, and Cooling Historic Buildings: Problems and Recommended Approaches. #33 The Preservation and Repair of Stained and Leaded Glass. #35 Understanding Old Buildings: The Process of Architectural Investigation. #39 Holding the Line: Controlling Unwanted Moisture in Historic Buildings. #41 The Seismic Rehabilitation of Historic Buildings.
#47 Maintaining the Exterior of Small and Medium Size Historic Buildings.
State Historical Building Code
One of California’s most valuable tools for the preservation of historic buildings is the State Historical Building Code (SHBC). While the California Building Code (CBC, section 3403.5) makes provisions for the special treatment of qualified historic buildings, the SHBC amplifies and codifies this protection. The SHBC recognizes and endorses the need to find and adopt reasonable alternatives or reasonable levels of equivalency on a caseby-case basis for situations where strict compliance with the regular code would negatively affect a historic building’s appearance or jeopardize its economic viability. The City includes use of the CHBC as an incentive that may be requested by owners of properties listed in the Register. 16 “Technical Preservation Services: Preservation Briefs,” U.S. Department of the Interior, National Park Service, accessed June 2025, https://www.nps.gov/orgs/1739/preservation-briefs.htm.
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach 25
7. SOURCES
California Code of Regulations, California Office of Administrative Law, State of California Government.
City of Laguna Beach. “Historic Preservation.” Accessed June 2025. https://www.lagunabeachcity.net/government/departments/community-development/planningzoning/historic-preservation.
City of Laguna Beach Community Development Department Building Division. Building Permits. Various Dates.
City of Laguna Beach Municipal Code. Chapter 25.45.
Google Street View Images. Various Dates.
Les, Kathleen. “Laguna – South.” California Department of Parks and Recreation (DPR) Form Set.
Environmental Coalition. Laguna Beach, California. April 1980.
Newspapers.com. “Emphasis on Charm: Group Plans Tour of Eight Laguna Homes.” Los Angeles Times.
November 16, 1972. 10. Accessed June 2025. https://www.newspapers.com/image/386034829/.
Sanborn Map Company. Various Dates. Accessed June 2025. www.proquest.com.
Sanborn Map Company. Various Dates. Accessed June 2025. fims-historicalinfo-com UCSB Geospatial Collection. Various Dates. Accessed June 2025. https://mil.library.ucsb.edu/.
US Department of the Interior, National Park Service. “Technical Preservation Services: Preservation Briefs.” Accessed June 2025. https://www.nps.gov/orgs/1739/preservation-briefs.htm.
US Department of the Interior. National Park Service. “The Secretary of the Interior’s Standards for the Treatment of Historic Properties.” Accessed June 2025.
https://www.nps.gov/tps/standards/treatment-guidelines-2017.pdf.
Attachment 4
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix A
APPENDIX A
Résumés
Attachment 4
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix A
AUDREY VON AHRENS
Audrey von Ahrens is a Senior Architectural Historian at GPA. She has been involved in the field of historic preservation since 2013. Audrey graduated from the University of Pennsylvania with a Master of Science in Historic Preservation and City Planning where she focused on preservation planning and community economic development. She has since worked in private historic preservation consulting in California. Audrey joined GPA in 2017 and her experience has included the preparation of environmental compliance documents in accordance with the California Environmental Quality Act and Section 106 of the National Historic Preservation Act; historic context statements; Secretary of the Interior’s Standards analysis; large-scale historic resources surveys; and evaluations of eligibility for a wide variety of projects and property types throughout Southern California. Audrey is also experienced in coordinating with property owners and local governments in the preparation and review of Mills Act Property Contract applications and the inspection and reporting of properties applying for or with existing contracts.
Educational Background: Selected Projects:
• M.S., Historic Preservation, University of Pennsylvania, 2016
• Master of City Planning, University of Pennsylvania,
2016
• B.A., Architectural Studies and Urban Studies,
University of Pittsburgh, 2013
• 20 E. Colorado Boulevard, Pasadena, Los Angeles
County, Mills Act Application, 2019.
• 26 E. Colorado Boulevard, Pasadena, Los Angeles
County, Mills Act Application, 2019
• 34-38 E. Holly Street, Pasadena, Mills Act
Application, 2022
• Casa de Rosas, Federal Rehabilitation Tax Credit,
2017-2022
• City of Anaheim, Mills Act Program, Inspections of
Existing Contracts, 2024-2025
• City of Costa Mesa, Mills Act Program, Applications
Processing and Contract, Costa Mesa, Orange
County, 2024
• City of San Clemente Historic Property Preservation
Agreements, Pre-Approval Inspections, San Clemente,
Orange County, 2018-2024
• City of San Clemente Historic Property Preservation
Agreements, Periodic Inspections, San Clemente,
Orange County, 2018-2024
• Los Angeles Mills Act Historical Property Contract
Program, Inspections of Existing Contracts, Los
Angeles, 2017-2025
• Los Angeles Mills Act Historical Property Contract
Program, Pre-Contract Services, Los Angeles, 2018-
2020
• North Beach Historic District, San Clemente, National Register Nomination, 2021
• Whittier Public Library, Construction Monitoring,
2021-2023
• Vortox Co. Building, 121 S. Indian Hill Boulevard,
Claremont, CEQA Historical Resource Documentation
Report, 2022
Professional Experience:
• GPA Consulting, Senior Architectural Historian, 2024- Present
― Associate Architectural Historian, 2021-2024
― Architectural Historian II, 2017-2021
• Heritage Consulting, Inc., Intern, 2015-2016
• Tacony Community Development Corp., Intern, 2014
• Pittsburgh History & Landmarks Foundation, Intern,
2013
• University of Pittsburgh, Teaching Assistant, 2012-
2013
• Pittsburgh Planning Department, Intern, 2012
• Pittsburgh Downtown Partnership, Intern, 2011
Qualifications:
• Meets the Secretary of the Interior’s Professional
Qualification Standards for history and architectural
history pursuant to the Code of Federal Regulations, 36 CFR Part 61, Appendix A.
• National Preservation Institute, Section 106: An
Introduction
Professional Activities:
• Downtown Los Angeles Neighborhood Council,
Planning and Land Use Committee (DLANC), 2018-
2024
• DLANC, Board of Directors, Alternate, 2019-2024
Attachment 4
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix A
PHOEBE RAYBURN
Phoebe Rayburn is an Architectural Historian I at GPA. She has been involved with the field of historic preservation since 2024. Phoebe graduated from the College of Charleston with a bachelor’s degree in historic preservation and community planning and a minor in art history. At GPA, she assists the architectural historian team with the preparation of environmental compliance documents in accordance with the California Environmental Quality Act (CEQA), National Environmental Policy Act (NEPA), Section 106 of the National Historic Preservation Act (NHPA), and the Secretary of the Interior’s Standards (SOIS). Prior to GPA, Ms. Rayburn was a preservation intern at the Historic Charleston Foundation, where she performed historic property inspections, coordinated inspection schedules, prepared and mailed inspection reports, and performed archival research on endangered historic properties for presentation. She is proficient in a number of software programs, including AutoCAD, Adobe InDesign, SketchUp, Adobe Photoshop and Lightroom, and Microsoft Office. She uses these skills to add depth to her analyses and reports in the form of maps, illustrations, and graphics.
Educational Background: Selected Projects:
• B.A., Historic Preservation and Community Planning,
Minor in Art History, College of Charleston, 2024
• 5679 Corso di Napoli, CEQA Historical Resource
Evaluation Report, Long Beach, 2025
• Kensington Historic District, National Register of
Historic Places Nomination Form, San Diego, 2025
• 8910-8924 Ardendale Avenue, CEQA Historical
Resource Evaluation Report, San Gabriel, 2025
• Lodi Downtown Specific Plan Historic Resources
Inventory, Lodi, 2025
• Telegraph Road over San Gabriel River Bridge, Section 106 Historic Property Survey Report, Los Angeles
County, 2025
• 1323 South Pacific Street, CEQA Historical Resources
Evaluation Report, Oceanside, 2025
• Henningsen-Lotus Road Multi-Use Trail, Section 106
Historic Property Survey Report, El Dorado County,
2025
• I-405 Auxiliary Lanes from I-110 to Wilmington, Section 106 Historic Property Survey Report, Los Angeles
County, 2025
• Max Berg Plaza Park Fountain Rehabilitation, Section
106 Historic Property Survey Report, San Clemente,
2025
• Washington Boulevard Bridge over Rio Hondo Channel,
Section 106 Historic Property Survey Report, Pico
Rivera, 2025
Professional Experience:
• GPA Consulting, Architectural Historian I, February
2025 – Present
• Historic Charleston Foundation, Preservation Intern,
January 2024 – May 2024
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix B
APPENDIX B
Guidelines for the Treatment of Historic Fabric
The following guidelines are derived from the Secretary of the Interior’s Standards for Rehabilitation as well as the National Park Service’s series of Technical Preservation Briefs.
Attachment 4
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix B Guidelines for the Treatment of Wood
Retain all original wood features such as siding, window and door surrounds, windows, doors, decorative features, and trim, as applicable.
Protect and Maintain
• Inspect all wood elements annually as follows:
o Check for signs of moisture and/or insect damage.
o Ensure water is being properly diverted away from wood elements by means of flashing, caulking, gutters, etc. Keep all plants trimmed away from building(s). o If insect or moisture damage is discovered, determine and abate the cause right away.
Treat and/or repair wood members immediately to prevent widespread damage.
Treatment should be carried out in the least invasive way possible, as determined by an extermination specialist, contractor, and/or experienced practitioner. • Repaint (or stain) regularly to protect the wood from moisture, sunlight, and other elements that cause deterioration.
o Remove any damaged or deteriorated paint to the next sound layer using the gentlest method possible (e.g., hand scraping and hand sanding). o Apply compatible coating by hand following proper surface preparation. o Repaint (or stain) with a color that is consistent with the age and style of the building.
Repair
• When necessary, repair using in-kind materials and appropriate construction methods such as by patching, piecing-in, consolidating, or otherwise reinforcing the wood using recognized preservation methods.
Replace
• If a wood element is damaged or deteriorated beyond repair, it should be replaced in kind to the extent feasible using the existing feature as a guide. Replacement wood feature should match the historic as closely as possible in design, color, texture, and other qualities to retain the building’s architectural character.
Attachment 4
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix B Guidelines for the Treatment of Masonry
Retain all original masonry features such as such as walls, brackets, steps, columns, window sills, and chimneys as applicable.
Protect and Maintain
• Inspect all masonry elements annually as follows:
o Check for signs of moisture damage.
o Ensure water is being properly diverted away from masonry elements by means of flashing, caulking, gutters, etc. Keep all plants trimmed away from building(s). o If signs of moisture damage are discovered, such as efflorescence or mildew, determine and abate the cause right away. Treat and/or repair masonry immediately to prevent widespread damage. Treatment should be carried out in the least invasive way possible, as determined by a contractor or experienced practitioner. • Clean only when absolutely necessary using the gentlest means possible, e.g., to halt deterioration or to remove heavy soiling.
o Clean masonry surface with low-pressure water, gentle detergent, and natural bristle brushes.
o Spot-test cleaning methods over a sufficient period of time to determine any potential long-term effects of the cleaning process/solution.
o Do not apply harsh chemicals.
o Never sandblast. Masonry can be irreparably damaged.
Repair
• Repair when necessary using in-kind materials, appropriate construction methods, and experienced practitioners to avoid damage to the historic fabric. o Repair brick by patching or piecing-in limited masonry units using recognized preservation methods.
o If repointing is needed, use a mortar that duplicates the existing in binder type, aggregate type, strength, composition, color, and texture. Duplicate existing mortar joints in width and joint profile.
o Regularly repaint only if feature was historically painted.
Replace
• If a masonry element is damaged or deteriorated beyond repair, it should be replaced in kind to the extent feasible using the existing feature as a guide.
For more information and guidance, see the following Preservation Brief 1. Cleaning and Water-Repellent Treatments for Historic Masonry Buildings, 2. Repointing Mortar Joints in Historic Masonry Buildings, 6. Dangers of Abrasive Cleaning to Historic Building, and 15. Preservation of Historic Concrete.
Attachment 4
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Mills Act Application Report – 501 Lombardy Lane, Laguna Beach Appendix B Guidelines for the Treatment of Metals
Retain all original metal features such as windows and door, railings, light fixtures, brackets, and door/window hardware as applicable.
Protect and Maintain
• Inspect all metal elements annually as follows:
o Check for signs of moisture damage or deterioration.
o Ensure water is being properly diverted away from the metal feature and is not accumulating or pooling on any curved or flat surfaces. o If signs of moisture damage are discovered, such as corrosion or loose/broken joints, determine and abate the cause right away. Treat and/or repair metal element immediately to prevent widespread damage. Treatment should be carried out in the least invasive way possible, as determined by a contractor or experienced practitioner. • Cleaning may be necessary prior to repair or repainting/recoating. o Clean surface with wire brush or by hand scraping. If more extensive cleaning is needed, hire an experienced practitioner to assist with other appropriate methods such as lowpressure grit blasting or chemical rust removal. o Immediately after cleaning, protect the newly cleaned metal with a new layer of an appropriate paint or coating. If a metal was not historically painted, use a clear protective coating.
Repair
• When necessary, repair using in-kind materials and appropriate construction methods such using patching compounds or limited replacement in kind (e.g., a single baluster in a railing) using the existing feature as a guide.
Replace
• If a metal element is damaged or deteriorated beyond repair, it should be replaced in kind to the extent feasible using the existing feature as a guide. Replacement feature should match the historic as closely as possible in design, color, texture, and other qualities to retain the building’s architectural character.
For more information and guidance, see Preservation Brief #13. The Repair and Thermal Upgrading of Historic Steel Windows.
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