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Attach 9 - 6-3-21 HRG Historic Assessment Peer Review

Laguna Beach City Council
January 27, 2026

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Attach 9 - 6-3-21 HRG Historic Assessment Peer Review
Meeting
January 27, 2026
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Laguna Beach City Council
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Text extracted from the city's file for reading and search. Open the original on lagunabeachcity.primegov.com. That file is the official record.

To: City of Laguna Beach
Attn: Martina Caron, AICP, Senior Planner
From: Laura Janssen
Senior Architectural Historian
Date: June 3, 2021
IITIROD lC IOR
At the request of the City of Laguna Beach, Historic Resources Group (HRG) was asked to peer review the historic resources assessment for 1796 South Coast Highway prepared by ESA in March 2019.` The commercial building at 1796 South Coast Highway is located in the South Coast Highway survey area, which was included in the City' s 1980- 81 historic resources survey; however, the subject property was not included in the survey. The property has not been previously identified as a potential heritage property and is not currently listed in the Laguna Beach Historic Resources Inventory, adopted in December 1982. 2The ESA historic resources assessment was prepared to determine if the property should be considered a historic resource at the national, state, or local level.

The purpose of this peer review is to determine if the assessment adequately evaluates the subject property for historic significance and integrity. This peer review includes an examination of the ESA assessment, observation of the site,. and additional review of building permits and property files, Sanbom fire insurance maps, historic aerials, and other primary and secondary sources.

The ESA assessment found the property eligible for listing in the National Register of Historic Places, Califomia Register of Historical Resources, and listing in the Laguna Beach Historic Register. This peer review finds there is not enough conclusive information to 1796 South Coast Highway, City of Laguna Beach, California; State of California DPR Form 523 prepared by ESA March 2019.

City of Laguna Beach Historic Resources Inventory' ( Resolution No. 82. 111), adopted December 21, 1982. a
HRG conducted a site visit on Apa I2 2021.

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
2S. Fair Oaks Avenue, Suite loo, Pasadena, CA 91105- 3816 Telephone 626 793 240o, Facsimile 626 793 2401
histoncresourcesgroup. com
Attachment 9
91 adequately evaluate its eligibility for listing in the National Register or California Register; however, there is enough information to determine eligibility at the local level.

PEER REVIEW FINDINGS
This peer review was conducted to ensure that the historic resource assessment of the subject property as presented by ESA is sufficiently researched and accurately evaluated to determine its eligibility as an historic resource.

Content and Format
The ESA assessment is documented on a State of Califomia Department of Parks and Recreation ( DPR) form 523. This format is cumbersome because of its use of continuation sheets. DPR forms are generally used by the Califomia Office of Historic Preservation for recording and evaluating resources and for nominating properties to the California Register of Historical Resources. The downside to using a DPR form for an assessment is the exclusion of explanatory information as to why and how (methodology) the building is being evaluated and introductory information ( regulatory framework) which sets up and guides the reader through the assessment and evaluation. Historic resource assessments are typically produced in a report format.

The content of the ESA assessment appears to be well researched in certain contexts; however, it falls short of establishing adequate associations for evaluation purposes at all three levels of criteria. In addition, there appears to be some confusion in the evaluation of the property under local criteria. It is evaluated for the National Register and the California Register using established criteria; however, the City of Laguna Beach uses a two -tiered system of ratings and criteria, which is not properly applied in this assessment The rating system was developed during the survey for the Historic Resources Inventory in 1981 and was meant to determine the level of integrity for buildings that had changed over time.

The criteria were established with the Historic Preservation Ordinance in 1989. The ESA assessment conflates the rating system and criteria.

There are some grammatical errors and typos, and misleading sentences which could have been avoided by a final proofreading. In addition, there are some inconsistencies in content, technical errors, and duplication of information.

Property Description and Construction History
The physical description of the subject property, including alterations that have occured over time, and construction history appear adequately developed and described in the report However, there is one error that will affect subsequent arguments made during the property' sevaluation. The report describes the budding as an example of Spanish Colonial

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite loo, Pasadena, CA 91105- 3516 Telephone 626 793 240o, Facsimile 626 793 2401
histoncresourcesgroup. com
92 Revival design when it is actually Mission Revival. The two styles have much in common and were both derived from Spanish architecture in the colonial era; however, their styles are markedly different.

In addition, the assessment does not document the date of construction within the construction history narrative. Assessor records accessed from the Orange County Archives confirm the building was constructed in 1926; however, the assessment states the date as an approximate (using circa) with no information as to how it was obtained. In addition, the assessment does not state that the building permit history begins in 1945 and that research did not reveal an associated architect or builder. This basic introductory information would inform the reader as to why no information is available for the first 20 years after the building was constructed.

Property Significance
1796 South Coast Highway has the potential to be significant for its association with the early development of Laguna Beach, association with persons who may have made an impact to local history, as the site of a historic local event, or for having distinctive physical characteristics of a particular architectural style.

The ESA assessment develops several themes associated with the property including a brief history of Laguna Beach as a tourist destination, alternative culture in Laguna Beach, Spanish Colonial Revival architecture, ownership history, and occupancy history.

The context of Laguna Beach as a tourist destination is an important part of the city' s history; however, the subject property is not directly associated with tourism. The property is located in Arch Beach, which was a separate city prior to Laguna' s incorporation in 1927. Arch Beach attempted to establish itself as a destination resort with the construction of the Arch Beach Hotel in the 1880s; however, that was short lived and the hotel was moved, but it did give rise to the development of Arch Beach as a beach cottage community for local and summer residents. In addition, the property is located on South Coast Highway ( previously Coast Boulevard, South) an important commercial corridor which developed in the mid - 1920s when it was improved from a dirt road into a paved thoroughfare. The subject property is a commercial building constructed in 1926 right at the time South Coast Highway was changing from residential to commercial use. The commercial uses associated with these early properties, including grocery stores, car dealerships, real estate offices, etc. were generally for the local community. This theme needs further development to adequately evaluate property' sassociation with the early commercial development of South Coast Highway.

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite Zoo, Pasadena, CA 91105- 3St6 Telephone 626 793 2400, Facsimile 626 793 2401
histoncresourcesgmup. com
93 The alternative culture and social history of Laguna Beach context developed by ESA is thorough in its research of gay culture in Laguna Beach; however, it does not establish the Sea Horse bar as being singularly important. In fact, it is not mentioned within the context whereas several other bars are mentioned as having more important roles in Laguna' s (and Orange County' s) gay culture. Additionally, it is not made clear whether any of the locations of the other bars are still extant or have been identified as being historically significant for their association with gay culture. So, it is difficult to evaluate a single location of a
gay bar that no longer exists as being historically significant without sufficient context. That is not to say the Sea Horse was not important in and of itself, but it should be added to the context to show how it compares to the other bars in order to establish its significance.

As noted above, the architectural style assigned to the property is inaccurate. Spanish Colonial Revival is an omate form of architecture that drew directly from Spanish and other Mediterranean precedents. Spanish Colonial Revival was a deliberate attempt to develop a " native" California architectural style and romanticize the area' scolonial past but bore little resemblance to the missions and rustic adobe ranch houses that comprised the states actual colonial -era buildings. Mission Revival, on the other hand, is indigenous to California and grew out of the romanticized image of old California. Architects freely adapted features of the Califomia missions, including bare plaster walls, shaped parapets, arcades, and tile roofs, often in combination with elements of other styles. The subject property does not possess the features that are commonly associated with Spanish Colonial Revival including but not limited to asymmetrical design, decorative grillwork and pattemed tilework, but rather is more associated with Mission Revival with simple massing shaped parapets, and little to no decorative features.

There are two themes that are touched on in the occupancy history that should be further expanded. The ceramic studio of Freeman Leidy (also known as Ceramic Originals) was in the building for approximately 10 years. Their role in the California pottery market needs to be adequately evaluated to determine the significance of their association with the subject property. In addition, it appears the building was originally constructed as an auto - showroom, which explains the four bays of large display windows. George W. Smith and Rose Camplin purchased the property in 1925 and constructed the building in which they briefly ran a Hudson and Essex automobile dealership. Their role promoting and servicing the early automobile needs to be evaluated to determine the significance of their association with the subject property.

If the assessment is going to establish a period of significance it should be in this section.

The period of significance, which is used prominently in the evaluation of significance and integrity, is not discussed, nor how it was determined. This also reveals an inconsistency.

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite Zoo, Pasadena, CA 91105- 3St6 Telephone 626 793 2400, Facsimile 626 793 2401
histoncresourcesgroup. com
94 On page two of the DPR form under B I 0 in the field for Period of Significance the evaluator marked " N/ A"; however, on page 17 the report states: The period of significance for the property is from its construction in ca. 1926 until 1969." If a period of significance is being established, it should be consistent throughout the report. Also, it is not clear how the end date was determined. It can be inferred from information in other areas of the report, but a section should be included that clearly states the period of significance and how it was determined. The period of significance refers to the span of time during which significant events and activities occured. For properties that are historically or culturally significant, the period of significance is the length of time when a property was associated with significant events, businesses, persons, or cultural groups. The historic context will inform the period of significance, which why it is important to further develop and expand the important themes and associations that determine the property' s significance.

Significance Evaluation
A technical note: On the second page of the DPR form under " NRHP Status Code the property is assigned a status code of 553, meaning it "appears to be individually eligible for local listing or designation through survey evaluation." However, in the report' sconclusion it is assigned three status codes; a status code of 3S, " appears eligible for the National Register as an individual property through survey evaluation," and a status code of 3CS, appears eligible for the California Register through survey evaluation," and a status code of 5S3, " appears to be individually eligible for local listing through survey evaluation." Since it was evaluated under national, state, and local criteria and it was concluded the property was eligible for all three, all three status codes should be listed on page two.

The ESA assessment evaluates the subject property for the National Register and California Register concurrently and finds it eligible for listing under Criteria A/ 1. As noted above in this peer review, the themes and associations need further development and clarification. There is currently not enough information to reach a conclusion on National Register or Califomia Register eligibility.

In addition, the evaluations should be clear and succinct. The evaluations for the National Register and California Register add information that should have been introduced in the contexts. Because the themes are not adequately developed in the previous section, there is a disconnect when they are used as an argument for meeting certain criterion. For example, under Criteria A/ 1, the report argues the building is associated with the arts community because Ceramic Originals occupied the budding; however, that context is not fully developed to hold much weight as an important or significant association under Criteria A/ 1. Additionally, the building' sassociation with Ceramic Originals, and its founders Cloyd Leland Freeman and Russell Leidy, should be evaluated under Criteria

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite 20 o, Pasadena, CA 911n5 -38t6 Telephone 626 793 2400, Facsimile 626 793 2401
histoncresourcesgroup. com
95 2/ B as well because of their association with the building. Also, the context for the Sea Horse bar within the gay culture of Laguna Beach is not adequately developed (Was the bar the first, most representative, most important, or last of its kind?) to be accurately evaluated under Criteria A/ 1. Information on the Sea Horse is scattered throughout the assessment. Because it is being assessed for its association with gay culture, the context should include information about the subject building, otherwise it is speculative.

Integrity
As stated previously in this peer review, the themes and associations in the ESA assessment need further development and clarification. Integrity cannot properly be assessed without determining a property' s significance. The report states the property retains integrity of setting, workmanship, materials, feeling, and association from its period of significance;" however, a period of significance is not adequately established. It is not clearly stated how the end date was determined. Once the significance is adequately established then integrity may be analyzed.

Lastly, the ESA assessment evaluates the property using the City' scriteria as outlined in the Historic Preservation Ordinance. The evaluator for the ESA assessment gets tripped up at the outset by the rating system included in Criterion A The rating system is based on integrity and is used to determine classification of a property. A property can only have one rating assigned to it. The ESA assessment erroneously evaluates the property under all three ratings and states it merits each rating. A property can only have one rating it cannot be "unique and distinctive" and " modest" at the same time. The property is then evaluated under the remaining Criteria, finding it eligible under Criteria B and E. However, as explained previously in this peer review, the themes and associations need further development and clarification.

There are errors and omissions in the evaluation, as well. In particular, under Criterion B the ESA assessment states the property is " not associated with post -Prohibition development" when the report repeatedly uses a period of significance of 1926-969.

Prohibition ended in 1933. This statement is incorrect. Also, the omission of additional information about Ceramic Originals could be evaluated under Criterion D for its association with its founders Cloyd Leland Freeman and Russell Leidy, and Criterion E as a ceramic studio and showroom which is an example of a particular way of life important to the city. The fact that the building retains integrity from their tenure is also important.

In the conclusion, the ESA assessment states the property is " eligible for the National Register under the local level of significance and the California Register under Criterion A/ 1 for its strong association with the historical pattem of commercial development in Laguna Beach from the 1920s through the 1960s." This statement does not mention the

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite Zoo, Pasadena, CA 911n5 -38t6 Telephone 626 793 2400, Facsimile 626 793 2401
histoncresourcesgroup. com
96 association with gay culture, which the assessment goes to great length to research and evaluate. This appears to be an oversight. However, the association with the Sea Horse bar is tenuous at best as detailed in the assessment. There is simply not enough evidence to suggest that the fact it was a gay bar in Laguna Beach in the 1960s that it is somehow significant just for that reason. In its bulletin " How to Apply the National Register Criteria for Evaluation the National Park Service states, "Mere association with historic events or trends is not enough, in and of itself, to qualify under Criterion A: the property' sspecific association must be considered important as well."•
In addition, the assessment finds the property eligible for Criterion A ( under City criterion) as an " E" -rated property " as a unique and distinctive example of a 1920s commercial building, which contradicts the fact that the property is consistently called a modest commercial building within the assessment. Then it refers to the other ratings, "K" and " C, as Criteria, which is incorrect, and it does not summarize that the property was found to meet Criteria B and E. These are grave errors.

CONCLUSION
The ESA historic assessment has multiple errors and omissions in research and evaluation methodology. Certain contexts were developed, and others were only partially developed or missing. This peer review finds there is not enough conclusive information to adequately evaluate its eligibility for listing in the National Register or Califomia Register; however, there is enough information to determine eligibility at the local level.

HRG ultimately agrees with the ESA assessment that the property is eligible for listing the local historic register; however, there are a few things that should be clarified for the record.

The style of the building is Mission Revival and not Spanish Colonial Revival, for reasons stated above in this peer review.

The property is not eligible for the National Register or California Register. It does not rise to that level of significance.

The evaluation for local listing is conflated and incorrectly applied. Also, it was given an " E" -rating which appears to be an oversight. The property is not in excellent condition or distinct (" E" -rating) and does not maintain its original c " National Rester Boileau I5: How to Apply the National Register Crirena for Evaluation.' Washington, DC: US.

Department of the Intoner, National Park Service, 2002, p. 12.

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91no5- 36t6 Telephone.. 6793 2400, Facsimile . 6 793 2401
histoncresourcesgroup. com
97 integrity ("K" -Rating), but it does contribute to the overall historic character of its neighborhood (" C" -rating).

Below are the strongest arguments for eligibility, which are sufficient for listing in the Laguna Beach Historic Register.

The commercial building was constructed in 1926 in Arch Beach. It retains sufficient integrity to convey its historic significance as an intact example of 1920s commercial architecture located along South Coast Highway. It is representative of the early commercial development in Laguna Beach.

It was constructed as an automobile showroom along a developing commercial thoroughfare. The auto showroom is a building type that evolved as a facility for exhibiting selling, and often servicing automobiles. Even though the property retains less integrity from this association, as originally designed, it is an example of early auto -related architecture, which was a storefront that retained a traditional relationship to the street, and in this case had four bays of large display windows to show the product. Essentially the bays are still recognizable even if they have been somewhat altered.

It once housed Ceramic Originals, manufacturer and showroom for Freeman Leidy art pottery. They operated at this location in Laguna Beach for ten years until the death of Cloye Leland Freeman in 1955. Their pottery is highly collectable nationwide, and they were active in the Laguna Beach art community.

The subject property retains integrity from their association because the alterations they made in 1945 are still extant.

The association with the Sea Horse bar is tenuous because there is not enough information about it currently to make that determination; however, the property has other important associations that meet the City' scriteria and make it eligible as a " C" -rated property for listing in the Laguna Beach Historic Register.

PEER REVIEW
1796 South Coast Highway
Laguna Beach, California

HISTORIC RESOURCES GROUP
12S. Fair Oaks Avenue, Suite 20 o, Pasadena, CA 91105- 3St6 Telephone 626 793 2400, Facsimile 626 793 2401
hirtnncresourcesgroup. com
98

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